The United States Supreme Court recently ruled that an employee who brings a lawsuit alleging she was transferred to another position for a discriminatory reason does not have to prove the transfer caused her significant harm.
Jatonya Clayborn Muldrow is a police sergeant in the St. Louis Police Department. She served as a plainclothes officer in the Department’s specialized Intelligence Division. In that position, she investigated public corruption and human trafficking cases, oversaw the Gang Unit, and was the head of the Gun Crimes Unit. As part of her position, she also was a Task Force Officer with the FBI, which gave her FBI credentials, an unmarked vehicle that she took home, and the right to conduct investigations outside of St. Louis.
After a new Intelligence Division commander took over the Division, he decided to transfer Sergeant Muldrow out of the unit so he could replace her with a male Sergeant who he considered a better fit for the unit’s “very dangerous” work. As a result, Sergeant Muldrow was reassigned to a uniformed position in its Fifth District.