On 5 June 2025, the Supreme Court ruled in Ames v. Ohio Department of Youth Services¹ that, in order to establish a Title VII claim, a plaintiff who is a member of a “majority group” is not required to show “background circumstances” that the defendant-employer discriminates against the majority. Writing for a unanimous court, Justice Jackson held that Title VII protects “any individual” from discrimination based on race, color, religion, sex, or national origin—without regard to whether the plaintiff is a member of a majority or minority group.

Factual and Procedural Background

Plaintiff Marlean Ames, a straight woman, applied for a promotion with her employer, the Ohio Department of Youth Services (Agency). Her application was denied, and the Agency filled the position with a lesbian candidate. A few days later, Ames was demoted, and her original position was filled with a gay man. Ames filed a lawsuit claiming the Agency discriminated against her because of her sexual orientation, in violation of Title VII.

The district court granted summary judgment to the Agency, analyzing Ames’s claims under the familiar McDonnell-Douglas burden-shifting framework for disparate-treatment cases.² The district court concluded that Ames failed to establish a prima facie showing of discrimination because she had not presented evidence of background circumstances that the Agency was the “unusual employer” who discriminates against members of a majority group.³ The Sixth Circuit affirmed,...

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