The Supreme Court has ruled that a discriminatory job transfer that causes “some“ harm violates Title VII. Prior to the decision, the lower federal courts almost all required a transferee plaintiff to prove “material,” “substantial,” “significant,” or some other heightened level of disadvantage.

The Supreme Court’s April 17 decision in Muldrow v. St. Louis revives the sex discrimination case of a police sergeant involuntarily transferred from the intelligence division job she had performed successfully for 10 years to a patrol district job, when her new boss decided a male officer was more suited to the intelligence division’s “dangerous work.”