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Suppose an employer transfers an employee, and that employee believes that unlawful bias fueled the decision. Does that transfer have to significantly disadvantage that employee to give rise to a discrimination claim under Title VII of the Civil Rights Act of 1964?
The Supreme Court addressed that issue yesterday in Muldrow v. City of St. Louis, Missouri.
The plaintiff worked as a plainclothes police officer in the Intelligence Division from 2008 to 2017. In 2017, the new Intelligence Division commander requested her transfer to replace her with a male officer. The Department approved the transfer against the plaintiff’s wishes,