In a landmark decision issued on June 5, 2025, the U.S. Supreme Court unanimously ruled that plaintiffs who are members of a majority group—such as white, male, or heterosexual employees—do not face a higher evidentiary burden than minority-group plaintiffs when bringing employment discrimination claims under Title VII of the Civil Rights Act of 1964. 

Marlean Ames, a heterosexual woman, had worked for the Ohio Department of Youth Services for 15 years, rising from executive secretary to program administrator. In 2019, she applied for a management promotion but was passed over in favor of a lesbian woman. Shortly thereafter, Ames was demoted to her original secretarial position, and her former role was filled by a gay man. Ames filed suit under Title VII, alleging she was denied the promotion and demoted because of her sexual orientation.

Both the federal district court and the U.S. Court of Appeals for the Sixth Circuit ruled against Ames. They applied the so-called “background circumstances” rule, which required majority-group plaintiffs to provide additional evidence suggesting their employer is “the unusual employer who discriminates against the majority.” This heightened standard was not required of minority-group plaintiffs, who only needed to show basic facts suggesting discrimination.

Writing for a unanimous Court, Justice Ketanji Brown Jackson rejected the “background circumstances” rule, declaring it inconsistent with the text and purpose of Title VII. The Court emphasized that Title VII prohibits discrimination against “any individual” because of race, color, religion, sex, or national origin, without regard to whether the individual is a member of a majority or minority group.

The Court vacated the lower courts’ decisions and remanded the case for further proceedings under the correct, uniform standard. The justices made clear that all Title VII plaintiffs, regardless of group status, must meet the same requirements to establish a prima facie case of discrimination, no more, no less.

The decision resolves a split among federal appellate courts, some of which had imposed the heightened “background circumstances” standard for majority-group plaintiffs, while others had not. Now, all courts must apply the same standard to all Title VII plaintiffs.

The Supreme Court sent Ames’s case back to the lower courts for reconsideration under the proper, uniform standard. The Ohio Department of Youth Services may still argue that its actions were not discriminatory, but it can no longer rely on the “background circumstances” rule to defeat Ames’s claim at the outset.