Supreme Court Affirms Uniform Legal Standard for All Discrimination Claims
June 09, 2025
- Alexandra Glunt Williams
The United States Supreme Court issued a unanimous opinion in Ames v. Ohio Department of Youth Services, rejecting a heightened burden for plaintiffs in “majority-groups” to meet their evidentiary burden in discrimination cases under Title VII.
Marlean Ames, a heterosexual woman, worked for the Ohio Department of Youth Services. In 2019, Ames applied for a newly created management position in the agency. The agency interviewed Ames for the new position but hired a different candidate, a lesbian woman, for the position. The agency, after interviewing Ames for the new position, demoted her and then hired a gay man in her place. Ames filed a lawsuit against the agency claiming that she was discriminated against based on her sexual orientation.
The Sixth Circuit created a rule that requires plaintiffs who are members of “majority-groups,” like heterosexual individuals, to meet a heightened evidentiary burden to establish their discrimination claims. Specifically, the Sixth Circuit required majority-group plaintiffs to show additional “background circumstances to support the suspicion that the defendant is that unusual employer who discriminates against the majority.” Following this precedent, the district court, as affirmed by the Sixth Circuit, dismissed Ames’s claim because she did not produce enough evidence to establish these “background circumstances.”
The Supreme Court unanimously rejected that requirement. Relying on Title VII’s text, the Supreme Court held that the statute’s language draws “no distinction between majority-group plaintiffs and minority-group plaintiffs;” rather, Title VII’s protections extend to “any individual” regardless of the individual's membership in a majority group. The plain language of the statute leaves “no room for courts to impose special requirements on majority-group plaintiffs alone,” making it clear that courts may not impose a heightened burden on plaintiffs based on their membership in a categorical group.
This decision establishes that all discrimination claims arising under Title VII, whether asserted by a minority or majority-group member, are analyzed under the same evidentiary standard.
For questions or more information on this topic, please contact Alex Williams.
The Sixth Circuit created a rule that requires plaintiffs who are members of “majority-groups,” like heterosexual individuals, to meet a heightened evidentiary burden to establish their discrimination claims. Specifically, the Sixth Circuit required majority-group plaintiffs to show additional “background circumstances to support the suspicion that the defendant is that unusual employer who discriminates against the majority.” Following this precedent, the district court, as affirmed by the Sixth Circuit, dismissed Ames’s claim because she did not produce enough evidence to establish these “background circumstances.”
The Supreme Court unanimously rejected that requirement. Relying on Title VII’s text, the Supreme Court held that the statute’s language draws “no distinction between majority-group plaintiffs and minority-group plaintiffs;” rather, Title VII’s protections extend to “any individual” regardless of the individual's membership in a majority group. The plain language of the statute leaves “no room for courts to impose special requirements on majority-group plaintiffs alone,” making it clear that courts may not impose a heightened burden on plaintiffs based on their membership in a categorical group.
This decision establishes that all discrimination claims arising under Title VII, whether asserted by a minority or majority-group member, are analyzed under the same evidentiary standard.
For questions or more information on this topic, please contact Alex Williams.
