艾姆斯诉俄亥俄州青年服务部案

Marlean Ames, a heterosexual woman employed by the Ohio Department of Youth Services since 2004, applied for a management promotion in 2019 but was passed over in favor of a lesbian woman. She was subsequently demoted from her program administrator role and replaced by a gay man. Ames sued under Title VII, alleging discrimination based on sexual orientation. The District Court and Sixth Circuit required her to show "background circumstances" suggesting the agency discriminated against majority-group members—a heightened standard applied to heterosexual plaintiffs. The Supreme Court granted certiorari on October 4, 2024, heard arguments on February 26, 2025, and issued its unanimous decision on June 5, 2025.

The Supreme Court unanimously vacated the Sixth Circuit's judgment and remanded the case. The Court held that the "background circumstances" rule imposing a heightened standard on majority-group plaintiffs is inconsistent with Title VII's text and precedents. Title VII prohibits discrimination against "any individual" based on protected characteristics without distinguishing between majority and minority groups. Justice Jackson delivered the unanimous opinion; Justice Thomas filed a concurring opinion joined by Justice Gorsuch.

Whether a Title VII plaintiff who is a member of a majority group must satisfy a heightened evidentiary standard—specifically, showing "background circumstances to support the suspicion that the defendant is that unusual employer who discriminates against the majority"—to establish a prima facie case of discrimination.

The decision eliminated the heightened evidentiary burden previously applied to majority-group plaintiffs in several circuits, establishing that all Title VII plaintiffs face the same prima facie standard regardless of majority or minority status. The ruling reinforced a formalist, text-based interpretation of Title VII and may influence future reverse discrimination litigation. Legal commentators noted the decision could affect workplace discrimination claims by majority-group employees and potentially impact debates over diversity, equity, and inclusion programs.