Muldrow v. City of St. Louis, Missouri

Jatonya Muldrow (plaintiff) was a sergeant in the St. Louis Police Department (department). From 2008 to 2017, Muldrow worked as a plainclothes officer for a prestigious intelligence division that worked high-priority cases. Muldrow had substantial responsibility, overseeing the division’s gang and gun-crime units. She also worked alongside the Federal Bureau of Investigation (FBI), an affiliation that came with FBI credentials and a take-home vehicle. When a new commander took control of the division in 2017, he asked the department to transfer Muldrow from the division and replace her with a male officer better suited to the division’s highly dangerous work. The department moved Muldrow to a uniformed role in which she supervised local patrol officers. Although Muldrow’s rank and pay remained the same, her responsibilities were heavily reduced, and she performed mostly administrative functions. Additionally, her predictable weekday schedule changed to a rotation schedule that included weekend work. She also lost her FBI status and associated vehicle. Muldrow sued the City of St. Louis (city) (defendant), alleging that her transfer constituted sex-based discrimination violating Title VII of the Civil Rights Act of 1964 (Title VII). The district court granted summary judgment in the city’s favor, holding that Muldrow needed to show that her allegedly discriminatory transfer caused a significant change in working conditions, which she had not because her rank and pay remained the same. After the court of appeals affirmed, the United States Supreme Court granted certiorari to resolve a circuit split regarding whether a Title VII plaintiff must show merely harm from an adverse employment action or significant harm.