The Supreme Court has ruled unanimously that members of majority groups in protected classes under Title VII do not need to meet heightened evidentiary standards to prove workplace discrimination. The decision in Ames v. Ohio Department of Youth Services overturns a Sixth Circuit rule that required such evidence, focusing on the case of Marlean Ames, a heterosexual woman passed over for promotions in favor of LGBTQ candidates. Justice Ketanji Brown Jackson’s opinion in the 9-0 decision states that Title VII does not impose such a standard on majority group plaintiffs. Ames, who worked for the Ohio Department of Youth Services since 2004, argued she was discriminated against for her sexual orientation after being passed over for a promotion in 2,019 and later demoted by a gay man. The ruling strikes down the ‘background circumstances’ rule used by the Sixth Circuit, but the Court leaves Ohio’s alternative justifications for the treatment of Ames to be addressed in lower courts.
The Supreme Court ruled unanimously in favor of an Ohio woman who claimed she faced workplace discrimination, overturning a rule that required majority groups in protected classes to meet higher evidentiary standards under Title VII. In the case of Ames v. Ohio Department of Youth Services, the Court’s 9-0 decision, authored by Justice Ketanji Brown Jackson, rejected the Sixth Circuit’s ‘background circumstances’ rule, which had required such evidence from majority group plaintiffs. The ruling marks a significant shift in how Title VII discrimination cases are handled, particularly for members of majority groups who are not in protected classes.
Marlean Ames, a heterosexual woman who had worked for the Ohio Department of Youth Services since 2004, argued she was discriminated against on the basis of her sexual orientation after being passed over for a promotion in 2019 in favor of a lesbian woman and later demoted by a gay man. In her argument, Ames pointed to evidence that would ordinarily satisfy her prima facie burden, including being qualified and having been denied a promotion in favor of a gay candidate. The court found that the previous requirement imposed a burdensome standard on plaintiffs, particularly those not part of protected categories, and that such a standard is not mandated by Title VII.
Title VII, which prohibits employers from discriminating based on race, color, religion, sex, or national origin, forms the legal foundation of the case. The Court’s decision voids the ‘background circumstances’ rule, which had required majority group plaintiffs to demonstrate additional evidence of discrimination. While the ruling does not fully resolve Ames’ case, it leaves it to the lower courts to assess Ohio’s remaining arguments about the justification for its actions. The Court emphasized that it was not weighing in on these alternative justifications, merely rejecting the heightened standard.
The case garnered support from various organizations, including the Justice Department, the American First Legal Foundation, and the libertarian Pacific Legal Foundation. However, the NAACP Legal Defense and Education Fund and other groups backed Ohio in the case. This divergence in support highlights the broader implications of the ruling, which could reshape how discrimination claims are evaluated in the workplace, particularly for members of majority groups who are not part of protected categories.