Muldrow v. City of St. Louis
View Official PDFBelow are plain-language sections to help you understand what the Court decided in Muldrow v. City of St. Louis and why it matters. Quotes are taken from the syllabus (the Court’s short summary at the start of the opinion).
Summary
A short, plain-English overview of Muldrow v. City of St. Louis.
In Muldrow v. City of St. Louis, the Supreme Court addressed whether a job transfer under Title VII requires proof of significant harm to employment terms or conditions. Muldrow claimed her transfer was discriminatory based on sex, affecting her job responsibilities and schedule. The Court vacated the Eighth Circuit's decision, which had required a showing of significant disadvantage.
Holding
The single most important “bottom line” of what the Court decided in Muldrow v. City of St. Louis.
The Court held that an employee challenging a job transfer under Title VII must show harm to an identifiable term or condition of employment, but the harm need not be significant.
Constitutional Concepts
These are the Constitution-related themes that appear in Muldrow v. City of St. Louis. Click a concept to see other cases that involve the same idea.
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Why Equal Protection is relevant to Muldrow v. City of St. Louis
The case involves allegations of sex-based discrimination in employment, which implicates equal protection principles.
Syllabus excerpt (verbatim)Muldrow maintains that her employer, the St. Louis Police Department, transferred her from one job to another because she is a woman.
Key Quotes
Short excerpts from the syllabus in Muldrow v. City of St. Louis that support the summary and concepts above.
Muldrow need show only some injury respecting her employment terms or conditions.
The statutory text itself provides a different shared trait: Each kind of prohibited discrimination occurs by way of an employment action.
What the transferee does not have to show is that the harm incurred was 'significant' or otherwise exceeded some heightened bar.
