The U.S. Supreme Court's Muldrow v. City of St. Louis decision established that employees need only demonstrate some harm to advance discrimination claims under Title VII. The case involved Ms. Muldrow's involuntary transfer, which, while not affecting her pay, did remove certain benefits and privileges. Following this decision, various courts have applied the some harm standard in favor of employees. For instance, in Riggs v. Akamai Techs, a sales representative successfully alleged discrimination based on her gender due to assignments that negatively impacted her performance and networking opportunities.
In Riggs v. Akamai Techs, the court found that an employee could plead plausibly that the assignment of challenging accounts and exclusion from client events constituted some harm under the Muldrow standard.
The precedent set in Muldrow v. City of St. Louis allows employees to claim discrimination by demonstrating some form of disadvantage in their employment terms, without the need for significant harm.
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