A buyer worked at an office-supply company, where he reported to the office manager. The buyer was Black, and the manager was White. The buyer applied for a promotion, for which he was well qualified. The manager instead gave the promotion to a less-qualified White employee. The buyer sued the company for race discrimination under Title VII.

The buyer’s claim was for individual disparate treatment. That is, the buyer alleged that the manager intentionally discriminated against him because of...