The Supreme Court of the United States lowered the bar for establishing a discrimination claim under Title VII of the Civil Rights Act of 1964 in its 2024 opinion, Muldrow v. City of St. Louis, holding that an employee need only show “some” harm—not a significant change—in working conditions. According to the U.S. Court of Appeals for the Tenth Circuit, however, Muldrow’s relaxed standard does not apply to hostile work environment harassment claims under Title VII.

• Muldrow’s lowered standard of harm for discrete discriminatory acts under Title VII does not apply to hostile work environment claims, according to the Tenth Circuit.
• A circuit split exists on this issue, with the Sixth Circuit reaching the opposite conclusion.
• Employers may face different standards for hostile work environment claims depending on jurisdiction.

In Russell v. Driscoll, a civilian employee at a U.S. Army hospital alleged that his female supervisor treated the men in her division poorly compared with female employees. Following multiple complaints, the Army investigated and determined that the supervisor had, in fact, engaged in gender discrimination in violation of the Army’s equal-opportunity policy.

The employee filed internal complaints, followed by a lawsuit claiming that his supervisor had created a hostile work environment in violation of Title VII. The federal district court granted summary judgment for the Army, finding that the supervisor’s actions did not meet the standard for...

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