The question
Whether a plaintiff who is a member of a majority group must satisfy a heightened evidentiary standard, by showing "background circumstances" suggesting the employer discriminates against the majority, to make out a Title VII disparate-treatment claim.
Ames v. Ohio Department of Youth Services
What the Court decided
Reversed. The Court held that the Sixth Circuit's "background circumstances" rule cannot stand. That rule required majority-group plaintiffs to carry an extra burden at the first step of the McDonnell Douglas framework, and the Court found it incompatible with the text of Title VII and its own precedents. The statute bars discrimination against "any individual" because of protected characteristics and draws no distinction between majority-group and minority-group plaintiffs, so courts may not impose special requirements on majority-group plaintiffs alone.
How the justices split
UnanimousThe Court's opinion
Jackson, joined by Roberts, Thomas, Alito, Sotomayor, Kagan, Gorsuch, Kavanaugh, Barrett
Writing for a unanimous Court, Jackson held that the text of Title VII's disparate-treatment provision bars discrimination against any individual because of protected characteristics and draws no distinction between majority-group and minority-group plaintiffs. The provision focuses on individuals rather than groups, so Congress left no room for courts to impose special requirements on majority-group plaintiffs alone. The Court's precedents reinforce that the standard for proving disparate treatment does not vary based on whether the plaintiff belongs to a majority group, and the background-circumstances rule improperly subjects all majority-group plaintiffs to a rigid evidentiary standard contrary to the instruction to avoid inflexible applications of the prima facie standard.
Concurring in the judgment
Thomas, joined by Gorsuch
Thomas filed a concurring opinion, joined by Gorsuch.
How we know · 5 sourced claims
The Court held that the Sixth Circuit's 'background circumstances' rule cannot be squared with the text of Title VII or the Court's precedents.
Source: syllabus, Held
The background-circumstances rule required members of a majority group to satisfy a heightened evidentiary standard to prevail on a Title VII claim.
Source: syllabus, Held
Title VII's disparate-treatment provision bars discrimination against 'any individual' because of protected characteristics and draws no distinction between majority-group and minority-group plaintiffs.
Source: syllabus, Held
Jackson delivered the opinion for a unanimous Court.
Source: syllabus, lineup
Thomas filed a concurring opinion, in which Gorsuch joined.
Source: syllabus, lineup