Muldrow v. City of St. Louis, 601 U.S. ___, 144 S. Ct. 967 (2024)

Sergeant Jatonya Clayborn Muldrow worked as a plainclothes officer in the Intelligence Division of the St. Louis Police Department until she was reassigned to a uniformed job elsewhere in the Department and replaced with a male officer. Although Muldrow’s rank and pay remained the same, her responsibilities, perks and schedule changed. Muldrow no longer worked with the high-ranking officials in the Department’s Intelligence Division — instead, she was supervising the day-to-day activities of neighborhood patrol officers. Also, she lost access to an unmarked take-home vehicle and had a less-regular schedule involving weekend shifts. Muldrow brought suit under Title VII, challenging the transfer as a discriminatory action based on her sex. The lower court affirmed summary judgment in favor of the City because the allegedly discriminatory transfer “did not result in a diminution to her title, salary, or benefits” and had caused “only minor changes in working conditions.” However, in this opinion, the United States Supreme Court vacated the judgment and held that Muldrow could proceed with her claim to the extent she could show that the transfer brought about “some” harm with respect to an identifiable term or condition of employment, even though the harm was not “significant.”