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.
The Supreme Court addressed whether an employee challenging a job transfer under Title VII must demonstrate significant harm. Sergeant Jatonya Muldrow claimed her transfer within the St. Louis Police Department was discriminatory based on sex. The Court vacated the lower court's decision, clarifying that harm need not be significant to pursue a Title VII claim.
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 with respect to an identifiable term or condition of employment, but it 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 a claim of sex-based discrimination in employment, which is central to the Equal Protection Clause.
Syllabus excerpt (verbatim)Muldrow brought this Title VII suit to challenge the transfer. She alleged that the City, in ousting her from the Intelligence Division, had 'discriminate[d] against' her based on sex 'with respect to' the 'terms [or] conditions' of her employment.
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Why Procedural Due Process is relevant to Muldrow v. City of St. Louis
The case discusses the procedural aspects of proving harm in employment discrimination under Title VII, which relates to procedural fairness.
Syllabus excerpt (verbatim)Muldrow need show only some injury respecting her employment terms or conditions. Her allegations, if properly preserved and supported, meet that test with room to spare.
Key Quotes
Short excerpts from the syllabus in Muldrow v. City of St. Louis that support the summary and concepts above.
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.
The words 'discriminate against,' the Court has explained, refer to 'differences in treatment that injure' employees.
What the transferee does not have to show is that the harm incurred was 'significant' or otherwise exceeded some heightened bar.