(Last Updated On: October 25, 2024)
Employment discrimination in Boston and Natick can take various forms, and employees can suffer various degrees of harm as a result of employment discrimination. In some situations, an employee might realize that they have experienced harm as a result of action taken by an employer, but they might be concerned that the harm is not great enough to file a discrimination claim. In particular, in situations involving job transfers, employees can experience some harm if they do not seek the job transfer and do not have the option to decline it. Can these types of job transfers constitute unlawful discrimination? In some cases, the answer is yes.
Earlier this year, the US Supreme Court heard a case concerning employment discrimination and job transfers. The Court’s decision in that case makes clear that certain job transfers can give rise to employment discrimination claims for which the affected employee may be entitled to a remedy. Our Boston and Natick employment discrimination attorneys can provide you with more information about the case, as well as the implications of the case for employees in Massachusetts.
Getting the Facts in Muldrow v. City of St. Louis
The US Supreme Court heard the case Muldrow v. City of St. Louis (2024) and issued its ruling earlier this year. In this case, the plaintiff argued that her employer transferred her to a different position because of her sex/gender, and she experienced some harm as a result of the transfer. She filed an employment discrimination claim, and the Court ultimately ruled in her favor. It is essential to understand some of the key facts of the case in order to understand the Court’s ruling and how it may be applied in subsequent employment discrimination cases.
In Muldrow, the plaintiff worked for the St. Louis Police Department. From the years 2008 until 2017, the plaintiff worked as a plainclothes officer in a specialized intelligence division of the department. In 2017, a new commander of that division transferred the plaintiff out of that unit and had her replaced with a male employee. The plaintiff was reassigned to a different role within the department. In the new role, she kept the same rank and pay, but the responsibilities of the job, as well as the perks and schedule she had previously enjoyed, changed. More specifically, the plaintiff “no longer worked with high-ranking officials on the departmental priorities lodged in the intelligence division, instead supervising the day-to-day activities of neighborhood patrol officers,” and “she also lost access to an unmarked take-home vehicle and had a less regular schedule involving weekend shifts.”
The plaintiff filed a federal lawsuit under Title VII.
Reasoning in Muldrow
In the lower courts, the defendant (the St. Louis Police Department) argued that the plaintiff did not have a legitimate claim because her transfer “did not result in a diminution to her title, salary, or benefits” and because her transfer resulted in “only minor changes in working conditions.” In other words, the defendant argued that the plaintiff did not experience enough harm to have a valid discrimination claim.
The Court disagreed and ruled: “An employee challenging a job transfer under Title VII must show that the transfer brought about some harm with respect to an identifiable term or condition of employment, but that harm need not be significant.”
Implications of Muldrow in Massachusetts Employment Discrimination Cases Involving Job Transfers
The language that the harm “need not be significant” is extremely important because it means that just some harm can be enough to file and win an employment discrimination claim arising out of a job transfer.
In other words, if you are transferred to a different position by your employer for discriminatory reasons (with protections under Title VII or another law), then you can be eligible to file an employment discrimination claim and to receive a remedy even if you only experience some harm as a result of the job transfer. To be clear, the harm you experience due to the discriminatory job transfer does not need to be significant in order for the job transfer to be unlawful under federal law.
Contact a Massachusetts Employment Discrimination Lawyer Serving Clients in Natick and Boston
It is important for employers and employees alike to understand the implications of Muldrow in any job transfers that occur and involve allegations of discrimination. If you have any questions about Muldrow or how it applies to you or your situation, you should get in touch with an experienced Boston employment discrimination lawyer as soon as possible to discuss the details. Contact Rodman Employment Law today to speak with a Massachusetts employment law attorney and find out more about your options.