[22-193] Muldrow v. City of St. Louis, Missouri

Muldrow v. City of St. Louis, Missouri

Wikipedia · Justia · Docket · oyez.org

Argued on Dec 6, 2023.

Petitioner: Jatonya Clayborn Muldrow.
Respondent: City of St. Louis, Missouri, et al.

Advocates:

• Brian Wolfman (for the Petitioner)
• Aimee W. Brown (for the United States, as amicus curiae, supporting the Petitioner)
• Robert M. Loeb (for the Respondent)

Facts of the case (from oyez.org)

Sergeant Muldrow, initially assigned to the Intelligence Division where she worked on various high-profile cases and was deputized by the FBI, was transferred to the Fifth District by Interim Police Commissioner Lawrence O'Toole's appointee, Captain Deeba. This change led to a different work schedule, responsibilities, and loss of special FBI-related privileges including a potential $17,500 in annual overtime pay. After her transfer, Sergeant Muldrow was asked to return FBI-issued equipment, which she did, and her Task Force Officer status was revoked. She filed a discrimination charge with the Missouri Commission on Human Rights against the City of St. Louis and Captain Deeba, later filing an action in Missouri state court alleging Title VII violations.

The case was removed to federal court, where the district court granted summary judgment against her Title VII claims and dismissed her state law claims. On appeal, the U.S. Court of Appeals for the Eighth Circuit affirmed, holding that the employment decisions she alleged did not constitute “adverse employment action” and thus did not establish a prima facie case of gender discrimination under Title VII, nor were they “materially adverse action” as required for a prima facie case of retaliation under Title VII.

Question

Does Title VII of the Civil Rights Act of 1964 prohibit discrimination in transfer decisions absent a separate court determination that the transfer decision caused a signification disadvantage?