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UNANIMOUS SUPREME COURT RULING CLARIFIES LEGAL STANDARD FOR TITLE VII
EMPLOYMENT DISCRIMINATION CLAIMS  
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Alexandra Martinez
June 5, 2025
Prism
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_ Avatara Smith-Carrington, an attorney for the NAACP Legal Defense
Fund (LDF), emphasized that the ruling offers legal clarity without
endangering existing protections. _

The law “draws no distinctions between majority-group plaintiffs
and minority-group plaintiffs,” said Justice Ketanji Brown Jackson,
who wrote the opinion, (J. Scott Applewhite / Associated Press).

 

In a unanimous decision, the U.S. Supreme Court ruled
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that majority-group plaintiffs are entitled to the same legal standard
as minority-group plaintiffs when bringing employment discrimination
claims under Title VII of the Civil Rights Act of 1964. The decision
in _Ames v. Ohio Department of Youth Services_
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rather than changes, the legal framework for these claims, according
to the NAACP.

The case centered on the 6th Circuit’s application of the so-called
background circumstances test, a heightened evidentiary standard
applied when plaintiffs from majority groups, such as white workers,
allege employment discrimination. The Supreme Court did not overturn
Title VII standards or alter the foundational _McDonnell Douglas_ 
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framework used in employment discrimination cases. 

The _McDonnell Douglas_ framework
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a legal standard used to determine whether a plaintiff can prove their
claim of discrimination. The employee must first present evidence that
creates a reasonable inference of discrimination. Then, the burden
shifts to the employer to articulate a legitimate, nondiscriminatory
reason for their action. Finally, the burden shifts back to the
employee to prove that the employer’s reason is a pretext for
discrimination. It is typically used when there is a lack of direct
evidence of discrimination. Instead, the justices unanimously
concluded that the 6th Circuit misapplied the law.

In an interview with Prism, Avatara Smith-Carrington, an attorney for
the NAACP Legal Defense Fund (LDF), which submitted
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amicus brief in the case, emphasized that the ruling offers legal
clarity without endangering existing protections.

“It still allows for courts to consider the way that discrimination
shows up in the U.S., especially in employment against LGBTQ people,
Black people, and other historically marginalized people,”
Smith-Carrington said.

Smith-Carrington underscored that the ruling clarifies how the first
step of the _McDonnell Douglas_ test should be applied: Plaintiffs
alleging discrimination do not need to meet a heightened burden of
proof merely because they belong to a majority group.

Given the climate of backlash and legislative efforts aimed at
dismantling diversity, equity, and inclusion (DEI) initiatives, many
feared that the decision might weaken workplace protections or stoke
further anti-DEI sentiment
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The NAACP, however, sees the ruling as neutral on that front.

“The court continues to recognize that this kind of standard was
never intended to be rigid,” Smith-Carrington said. “There’s
supposed to be flexibility to account for the fact that when a person
is bringing a discrimination claim, the facts are going to differ
according to the person, according to the events that happened.”

They noted that DEI practices aren’t about giving advantages to
historically marginalized groups, but about “a recognition of
barriers” that have long blocked equal opportunities in employment.

With the decision vacated and remanded, the case returns to the lower
court, which must now re-evaluate plaintiff Marlean Ames’s
discrimination claim using the correct legal standard. Ames, a
straight white woman, alleged that she was discriminated against in
her employment at the Ohio Department of Youth Services. Ames, who had
worked in the department since 2004, claimed that she was denied a
promotion and demoted in favor of less-qualified LGBTQIA+
colleagues. 

Ames first filed a lawsuit in the Southern District of Ohio, which
granted summary judgment in favor of the department. The court applied
the background circumstances test, requiring Ames to provide evidence
that the employer discriminated against the majority group. 

The appellate court upheld the dismissal, stating that Ames failed to
meet the background circumstances requirement. The Supreme Court has
now ruled that that was a misapplication of the law.

The NAACP expects the lower court to apply the clarified framework,
but Smith-Carrington stopped short of predicting the outcome.

“What the court is doing is just essentially saying, ‘We’re
sending the case back to the lower court, we’re going to be
instructing them that they need to correctly apply the legal standard
to decide, essentially, whether Ms. Ames can continue her employment
discrimination claim,’” Smith-Carrington said. “I think what’s
fair to say is that the lower court maybe didn’t think of the right
steps to get there, which is clear, but it doesn’t take away from
the fact that the decision they reached was correct.”

The NAACP lawyer highlighted a broader context of inequality in how
discrimination claims are adjudicated. They pointed to statistics
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in LDF’s brief showing that white plaintiffs are significantly more
likely to succeed in Title VII lawsuits than nonwhite plaintiffs.

“There might be a narrative that because of how this background
circumstances test was being applied, that it disfavored, potentially,
members from majority groups,” said Smith-Carrington. “But the
statistics and the numbers are just not there. And in fact, what often
is happening is that historically marginalized people just continue to
face discrimination at much higher rates.”

The Supreme Court’s decision, while narrowly focused, lands at a
time of increasing scrutiny and politicization of workplace equity
programs. Advocates say that although the opinion does not change the
law, it is a reaffirmation of the law’s flexibility to meet the
complexities of discrimination in modern America, and a call to
continue fighting for equity in every workplace.

“That’s why we have Title VII. It’s there to protect all
individuals,” Smith-Carrington said. 

_Alexandra is a Cuban-American writer based in Miami, with an interest
in immigration, the economy, gender justice, and the environment. Her
work has appeared in CNN, Vice, and Catapult Magazine, among others.
Follow her on Twitter @alex__mar._

_When Prism was established in 2019, it was because we knew that the
status quo media landscape wasn’t reflecting enough of the
truth—and it wasn’t bringing us closer to our vision of collective
liberation and justice. We saw a different path forward, one that we
could forge by disrupting and dismantling toxic narratives, uncovering
the hard truths of injustice alongside the people experiencing the
acute impacts of injustice, and providing a platform for people of
color to tell their own stories, and those of their communities._

* employment discrimination
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* Title VII
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* Supreme Court Decision
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* NAACP Legal Defense Fund
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