On June 5, 2025, the United States Supreme Court made a significant ruling when they unanimously ruled against the Sixth Circuit, invalidating the “background circumstances” requirement for Title VII claims brought by majority-group plaintiffs. This decision resolved a Circuit split, holding that courts must evaluate Title VII claims brought by all plaintiffs, regardless of majority-group versus minority-group class, under the same evidentiary standard.

Petitioner, Marlean Ames, a heterosexual woman, worked for the Ohio Department of Youth Services since 2004. In 2019, the agency interviewed Ames for a new management position but ultimately selected another candidate—a lesbian woman. Ames was subsequently demoted from her current role, which the agency later filled with a gay man.

Ames filed a suit against her employer under Title VII of the Civil Rights Act of 1964, which prohibits an employer from failing or refusing to hire, discharging, or otherwise discriminating against any individual “because of such individual’s race, color, religion, sex, or national origin.” 42 U.S.C. § 2000e-2(a)(1). Ames alleged she was denied promotion and was demoted because of her sexual orientation as a straight woman.

The District Court granted summary judgment to the agency, and the Sixth Circuit affirmed. Lower courts relied on McDonnell Douglas Corp. v. Green, 411 U.S. 792 (1973), which sets forth the traditional framework for evaluating disparate treatment claims. The first step in this framework requires a plaintiff to establish a prima facie case of discrimination, showing that the defendant acted with a discriminatory motive. Both the District Court and the Sixth Circuit held that Ames failed to meet her prima facie burden because she had not shown “background circumstances”—a heightened evidentiary standard applied to members of a majority group bringing a Title VII claim—to support a suspicion that the defendant discriminated against members of a majority class.

The Supreme Court ruled that “the standard for proving disparate treatment under Title VII does not vary based on whether or not the plaintiff is a member of a majority group,” adding that this interpretation aligns with the text of the statute and caselaw construing the statue.

With the decision vacated and remanded, the case will return to the lower court, who will re-evaluate plaintiff, Marlean Ames’s discrimination claim using the correct legal standard.