On April 17, 2024, the U.S. Supreme Court issued a unanimous decision in Muldrow v. City of St. Louis, holding that a mandatory job transfer can constitute illegal discrimination under Title VII of the Civil Rights Act of 1964 (Title VII) if it causes harm with respect to an identifiable term or condition of employment, even if the harm is not significant.
Employers may consider greater care in mandating employee transfers, including lateral job transfers, to ensure that such decisions are not discriminatory and do not result in even insignificant harm with respect to identifiable terms and conditions of employment.
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