JATONYA CLAYBORN MULDROW, PETITIONER v. CITY OF ST. LOUIS, MISSOURI, ET AL., 601 U.S. 346

Summary

HOLDINGS: [1]-To make out a 42 U.S.C.S. § 2000e-2(a)(1) discrimination claim, a transferee had to show some harm respecting an identifiable term or condition of employment, but did not have to show that the harm incurred was significant, serious, or substantial; [2]-The lower court erred in requiring a police sergeant to show that an allegedly discriminatory transfer produced a significant employment disadvantage. The allegations that she was moved from a plainclothes job in a prestigious specialized division with substantial responsibility over priority investigations and frequent opportunity to work with police commanders to a uniformed job supervising one district’s patrol officers with less involvement in high-visibility matters, primarily performing administrative work, a less regular schedule, and no take-home car were sufficient.