Seyfarth Synopsis: The United
States Supreme Court issued its opinion in one of the most
anticipated employment cases of this term. In Muldrow v. City of
St. Louis, the Court considered whether Title VII of the Civil
Rights Act of 1964 prohibits discrimination in transfer decisions
absent a separate showing that the transfer caused a
"significant" harm. In its opinion, the Court rejected
this heightened harm requirement, which will have profound effects
on Title VII litigation, and on the way employers think about
related areas such as their DEI programming.
Background
Plaintiff Jatonya Muldrow is a sergeant in the St. Louis Police
Department. She was promoted to the Department's Intelligence
Division, where her work included at various times public
corruption and human trafficking cases, serving as head of the Gun
Crimes Intelligence Unit, and overseeing the Gang Unit. At one
point, she also was deputized as a Task Force Officer to work with
the Federal Bureau of
