For years, courts often told workers they hadn’t suffered enough to prove workplace discrimination. A recent ruling by the U.S. Supreme Court changed the standards governing claims of discrimination.

In Muldrow v. City of St. Louis, a unanimous U.S. Supreme Court lowered the legal bar for workers claiming discrimination under Title VII of the Civil Rights Act. The decision expands what counts as a legitimate employment discrimination case. If you're a worker in Connecticut who’s suffered harm as a result of being reassigned, transferred, or treated differently because of your race, sex, or another protected trait, Muldrow gives you more ground to stand on.

What Happened in Muldrow v. City of St. Louis?

Sergeant Jatonya Clayborn Muldrow, a decorated officer with the St. Louis Police Department, was moved out of her prestigious Intelligence Division role and reassigned to a more routine, uniformed patrol position. Her pay and rank didn’t change, but everything else did.

She lost access to her take-home unmarked car, worked less predictable hours, and took on responsibilities that were widely seen as less desirable. The reason was that her new supervisor wanted to replace her with a man—someone he felt was a “better fit” for the “very dangerous” work.

Muldrow thought this decision sounded discriminatory. But lower courts threw out her case because they said the harm she experienced wasn’t “significant” enough under Title VII.

That used to be the standard in many employment discrimination court cases—if there wasn’t a firing, pay cut, or demotion, courts often said there wasn’t a case. But in April 2024, the U.S. Supreme Court unanimously disagreed.

In reversing the lower court’s ruling, the Supreme Court held that Muldrow didn’t need to prove “materially significant” harm. All she had to show was “some harm” to the terms or conditions of her employment. That’s a big and employee-friendly shift in how Title VII is interpreted.

Why “Some Harm” Is a Big Deal for Workers

The Court’s ruling in Muldrow v. St. Louis might sound subtle on paper, but in practice, it gives workers across the country—including in Connecticut—a clearer path to challenge unfair treatment.

Here’s what the ruling actually changes.

1. Lowered Bar for Proving Discrimination

Before Muldrow, many federal courts required employees to show a material or significant disadvantage in order to sue under Title VII. This meant that if you were transferred to a worse schedule, lost responsibilities, or missed out on workplace perks—but kept the same salary—you might have been out of luck.

Muldrow changed that. Now, employees only need to show “some harm” with respect to a term, condition, or privilege of employment. The Court was clear that the harm need not be significant. It doesn’t have to be drastic. It just has to be real.

2. Not Everything Has to Be Economic

Muldrow also reinforced that workplace discrimination isn’t always about dollars and cents. Job duties, work hours, access to vehicles, office location, prestige, and growth opportunities all shape your employment. If you’re being treated worse in any of these areas because of your race, sex, or other protected characteristic, that may now be enough to support a claim.

This is especially important for workers in professional, administrative, or service roles where shifts in schedule, responsibility, or visibility can have long-term career implications even if pay stays the same.

3. Rejection of Heightened Standards

The Court flatly rejected the idea that only “materially significant” changes trigger Title VII protections. Justice Elena Kagan, writing for the Court, emphasized that the statute prohibits employers from discriminating against any individual with respect to his compensation, terms, conditions, or privileges of employment. Nowhere does it say the harm must be “major.”

Put plainly: if you’re worse off because of a discriminatory decision, that’s enough. Courts shouldn’t make you jump through hoops to prove the harm was severe.

What This Means for Employees in Connecticut

If you work in Connecticut, you already benefit from strong state protections against discrimination. But federal law still matters, especially when you’re filing in federal court or raising claims under federal antidiscrimination statutes such as Title VII.

The Muldrow decision expands the types of workplace decisions that can now be challenged:

• Transfers and Reassignments: Even if your title and pay remain the same, being moved to a less desirable department, shift, or location could support a claim if the reason is discriminatory.
• Loss of Perks or Prestige: Losing access to things like a company car, high-profile projects, or flexible hours might seem small, but they can now add up to “some harm.”
• Neutral on the Surface, Biased in Practice: The decision may also increase scrutiny of DEI rollbacks or “neutral” policies that disproportionately impact women, people of color, or older workers.

You no longer have to wait until things get “bad enough.” If you’ve been treated differently and worse because of a protected characteristic, you have the right to speak up.

Looking Ahead: What Else Could Change?

This decision is already making waves. Courts have started citing Muldrow in other cases, including those under the Age Discrimination in Employment Act (ADEA). That suggests the “some harm” standard could be applied to other anti-discrimination statutes too.

Legal observers also predict an uptick in employment discrimination cases that previously might not have made it past the initial stages of litigation. That includes challenges to:

• Reassignments following complaints of bias
• Performance reviews altered after disclosure of a disability or pregnancy
• Transfers justified by vague reasons like “fit” or “culture”
• Reductions in duties or prestige without formal demotions

For employers, this means it’s no longer safe to assume a change is non-discriminatory just because it didn’t affect pay. And for employees, it means the law may finally catch up to how subtle and insidious workplace discrimination can really be.

If You’ve Been Moved, Sidelined, or Treated Unfairly, You’re Not Powerless

Muldrow v. City of St. Louis is more than just a legal technicality. It’s a reminder that the law doesn’t only protect workers from the most obvious forms of discrimination. It also protects against the quiet decisions that diminish someone’s role, stall their career, or send the message that they don’t belong.

At Madsen, Prestley & Parenteau, LLC, we represent workers across Connecticut who’ve experienced this kind of unfair treatment. If you’ve been transferred, stripped of responsibilities, or reassigned under suspicious circumstances, you may have a case, even if your paycheck hasn’t changed.

Call us at 860-246-2466 or contact us online to schedule a consultation. We’re here to help you understand your rights and take action when your employer crosses the line.