The 2024 U.S. Supreme Court decision in Muldrow v. City of St. Louis represented a pivotal shift in employment law. For years, employees contesting job reassignments or lateral moves were required to prove they experienced “significant” work-related detriment to establish a viable adverse employment action claim. Muldrow, however, eliminated this elevated threshold, ruling that plaintiffs must only show “some harm respecting an identifiable term or condition of employment” to state a valid claim. See Muldrow v. City of St. Louis, 601 U.S. 346, 355 (2024). The question that remained for courts was how to define “some harm.”
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