Marlean Ames alleged that the Ohio Department of Youth Services denied her a promotion and demoted her because she is heterosexual. The Sixth Circuit applied a background-circumstances test because Ames was a majority-group plaintiff. The Supreme Court unanimously rejected that extra requirement, holding that Title VII's text applies the same standard to every individual.
Ames worked for the Ohio Department of Youth Services and alleged she was treated worse because she is straight. Lower courts rejected her claim after applying an additional background-circumstances requirement used for majority-group plaintiffs. The Supreme Court focused on whether that special rule is compatible with Title VII.
May courts require majority-group Title VII plaintiffs to satisfy a heightened background-circumstances showing that minority-group plaintiffs do not have to satisfy?
Title VII does not impose a heightened background-circumstances requirement on plaintiffs who are members of a majority group. Courts must apply the same statutory standard to all Title VII plaintiffs.
How the justices lined up in this decision.
The ruling makes it easier for majority-group plaintiffs to get past the special threshold some circuits had imposed. It may increase litigation over employment decisions, including disputes tied to DEI politics, but the decision does not say Ames proved discrimination or that DEI programs are unlawful. It only removes an extra plaintiff-specific hurdle not found in Title VII.
Justice Jackson wrote for a unanimous Court. Justice Thomas concurred, joined by Justice Gorsuch.