On June 3, 2022, the full court of the U.S. Court of Appeals for the District of Columbia held in a 9-3 decision in Chambers v. District of Columbia, that when an employer transfers an employee or denies an employee’s request for a transfer because of the employee’s race, color, religion, sex, or national origin, the employer violates Title VII by discriminating against the employee in her “terms, conditions, or privileges” of employment.[1] The decision is momentous because it overruled a 23-year old precedent—Brown v. Brody[2]—that said discriminatory transfers or denials of transfers are not actionable unless the employee suffered “objectively tangible harm.” The D.C. Circuit, in common with many other federal courts, has long imposed this tangible harm requirement articulated in Brown because of the view that Title VII is not a general “civility code” and that employees challenging discriminatory decisions should show more than de minimis harm lest courts be involved in supervising myriad routine business decisions.
Mary Chambers worked for the DC Office of the Attorney General (OAG) for more than 20 years prior to this litigation, first as a clerk and later as a Support Enforcement Specialist and investigator. In 2000, she began working as an enforcement specialist in the Child Support Services Division, initially in the Interstate Unit, where after 2005, she worked on cases in which she helped parents who reside outside the...
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