By Annette Tyman, Matthew J. Gagnon, Brandon L. Dixon, and Taylor Iaculla
Seyfarth Synopsis: The United States Supreme Court issued its opinion in one of the most anticipated employment cases of this term. In Muldrow v. City of St. Louis, the Court considered whether Title VII of the Civil Rights Act of 1964 prohibits discrimination in transfer
Continue Reading SCOTUS Issues Highly Anticipated Muldrow Decision, Rejecting Heightened Harm Requirement in Adverse Action Analysis
By Rachel See, Dawn Solowey and Adrienne Lee
Seyfarth Synopsis: In a written opinion issued on March 7, 2024, the EEOC confirmed that an employee must not only show a sincerely held religious belief, but that the employee’s religious belief is actually in conflict with the workplace training or program. The EEOC’s opinion also confirmed that an undue
Continue Reading EEOC Weighs in on Alleged Conflict Between Religious Beliefs and Civil Rights Training
By: Christine M. Costantino, Taylor Iaculla, and Andrew Scroggins
Seyfarth Synopsis: One of the most anticipated employment cases of the term was recently argued before the United States Supreme Court. In Muldrow v. City of St. Louis the Court requested the parties address the issue: Whether Title VII of the Civil Rights Act of 1964 prohibits discrimination in
Continue Reading Justices Mull Fundamental Element of Proof in Title VII Case During Oral Argument In Muldrow v. City of St. Louis
Seyfarth Synopsis: Yesterday the Supreme Court held oral argument in Groff v. DeJoy, a case in which the Court is considering whether to overturn decades of precedent established by the seminal religious accommodation case, Trans World Airlines Inc., v. Hardison. Decided in 1977, Hardison is the seminal case establishing that an employer is
Continue Reading Takeaways From SCOTUS Oral Argument in Groff v. Dejoy: Justices Attempt to Find “Common Ground” on Religious Accommodation Test
By Darien C. Harris and Dawn Reddy Solowey
Seyfarth Synopsis: Gerald Groff was a carrier for the United States Postal Service, but his religious beliefs prohibited him from working on Sundays in observation of the Sabbath. USPS offered to find employees to cover Groff’s shifts, but on more than twenty Sundays no co-worker was available to swap with him. When
Continue Reading Will SCOTUS Stiffen Employers’ Obligation To Accommodate Employees’ Religious Beliefs, Overturning Decades-Old Precedent?By Rachel A. Duboff and Erin Dougherty Foley
Seyfarth Synopsis: Employers can take precaution against discrimination claims by ensuring they have legitimate, nondiscriminatory reasoning for their decision-making. An honest explanation of their behavior makes it credible.
The Eighth Circuit’s recent opinion in Banford v. Board of Regents of UM affirms the steps required to prove a discrimination claim. Plaintiff
Continue Reading The Devil is in the Pretext: No Successful Discrimination Claim If Employee Does Not Carry Burden to Prove Ulterior Explanation for Employer’s Actions
By Samantha L. Brooks and Eric J. Janson
Seyfarth Synopsis: In Lyons v. City of Alexandria, No. 20-1656, 2022 WL 1739987 (4th Cir. June 1, 2022), the Court issued an employer-friendly decision under Title VII of the Civil Rights Act of 1964, 42 U.S.C. § 2000e et seq., (“Title VII”), reiterating that employers should not be punished “for
Continue Reading Fourth Circuit Reaffirms That Consistently Implementing Lawful Business Practices and Policies is Not Discrimination
By Erin Dougherty Foley and James Nasiri*
Seyfarth Synopsis: On April 14, 2022, the U.S. Court of Appeals for the Seventh Circuit affirmed summary judgment in the employer’s favor on Title VII race discrimination claims filed by an Indiana University lecturer. In rejecting the lecturer’s claims of unequal pay and failure to promote, the Court shed light on how
Continue Reading Seventh Circuit Rejects University Lecturer’s Title VII Failure to Promote, Unequal Pay Claims
By Matthew J. Gagnon and Tyler Z. Zmick
Seyfarth Synopsis: Following the March 8, 2021 Executive Order establishing the White House Gender Policy Council, on October 22, 2021 the White House released the first-ever U.S. Government National Strategy on Gender Equity and Equality. The EEOC contributed to the Strategy and supports its full implementation, suggesting that gender-related issues –
Continue Reading White House Releases First-Ever “National Strategy On Gender Equity And Equality”
By Fritz Smith and Becca Mitchell
Seyfarth Synopsis: In Roberts v. Glenn Indus. Grp., Inc., No. 3:17-CV-745-GCM, 2019 WL 356809, at *2 (W.D.N.C. Jan. 29, 2019), aff’d in part, vacated in part, remanded, No. 19-1215, 2021 WL 2021812 (4th Cir. May 21, 2021), the plaintiff employee filed a lawsuit against his former employer alleging same-sex sexual harassment and retaliation in
Continue Reading Title VII: The Fourth Circuit Expands the Evidentiary Routes for Same-Sex Sexual Harassment Claims and Rejects Attempt to Impute Knowledge to the Decisionmaker for Retaliation Claims