Legal Alert: Supreme Court Rejects Elevated Proof Requirement for Majority-Group Plaintiffs Under Title VII

On June 5, 2025, the U.S. Supreme Court issued a unanimous ruling in Ames v. Ohio Department of Youth Services, addressing how Title VII of the Civil Rights Act of 1964 applies to plaintiffs who belong to majority demographic groups. The Court struck down an elevated proof standard used by some lower courts that had required plaintiffs in majority groups to satisfy additional and more demanding requirements when bringing claims of workplace discrimination.

This case arose from a dispute between Marlean Ames, a heterosexual female employee, and her employer,  the Ohio Department of Youth Services. Ames alleged that she was denied a promotion and subsequently demoted because of her sex and sexual orientation. She asserted that her employer favored LGBTQ candidates over straight candidates. The District Court and the U.S. Court of Appeals for the Sixth Circuit both ruled against Ames, relying on prior Sixth Circuit caselaw holding that, as a member of a majority group, she had to present evidence suggesting that the employer was the “unusual employer who discriminates against the majority.” This heightened standard, known as the “background circumstances” requirement, had been used in five circuits to screen claims brought by majority-group plaintiffs.

The Supreme Court reversed, rejecting the background circumstances rule. In a unanimous decision, Justice Jackson explained that requiring different proof of different Plaintiffs was at odds with the text of Title VII and longstanding Supreme Court precedent, noting that “Title VII’s disparate-treatment provision draws no distinctions between majority-group plaintiffs and minority-group plaintiffs.”  The Court also reaffirmed that a plaintiff’s burden at the early stage of a Title VII case is intended to be modest and uniform. The Court reversed the District Court’s decision and returned the case for further proceedings consistent with its ruling.

Key Takeaways for Employers

• Consistent Legal Standard: Employers should be aware that all employees, regardless of whether they belong to a majority or minority group, and regardless of what Circuit they file suit in, must be treated equally under Title VII. Courts cannot impose additional proof requirements based on the Plaintiff’s status.
• Review of Policies and Practices: Human resources departments and legal counsel should examine anti-discrimination policies, training materials, and practices to ensure that minority and majority employees are treated the same in all aspects of their employment, including hiring, promotions, and evaluation of reports of discrimination.

Conclusion

The decision in Ames v. Ohio Department of Youth Services reinforces the principle that Title VII applies equally to all individuals. The ruling eliminates the use of special evidentiary burdens for majority-group plaintiffs, clarifying that courts must apply the same legal standards to every claimant. This case serves as a timely reminder for employers to maintain equitable practices and to ensure that internal policies reflect a consistent approach to discrimination prevention.

For additional guidance or to schedule a review of your employment policies, please contact us.

This summary is provided for informational purposes only and is not intended to constitute legal advice nor does it create an attorney-client relationship with Rimon, P.C. or its affiliates.

Tara Humma is a Litigation attorney who focuses her practice on labor and employment matters. Tara has over a decade of experience representing public and private employers of all sizes in states across the country. Tara represents clients in all phases of employment litigation, from initial pleadings, discovery, and motion practice to trial preparation and appeals. Her experience includes a broad range of litigation matters including, but not limited to, claims brought under Title VII of the Civil Rights Act, the Americans with Disabilities Act (ADA) (including accessibility cases), the Family and Medical Leave Act (FMLA), the Fair Labor Standards Act (FLSA), breach of contract cases related to employment contracts and restrictive covenants and various other state and federal employment laws. Read more here.

Chris Kelly has extensive experience representing both public and private employers. He regularly litigates complex employment matters, including discrimination, restrictive covenant, employee raiding/mobility, and employment-related trade secret matters in state and federal courts across the country. He also represents clients in state and federal wage and hour audits, conducts employment-related due diligence in mergers and acquisitions, assists clients in handling reductions in force, represents management in grievance arbitrations, conducts internal investigations, drafts uniform employment policies for employers on training, leave, and other requirements of multiple states, and drafts physician and executive compensation agreements. Read more here.