Jatonya Muldrow v. City of St. Louis, State of Mo, No. 20-2975 (8th Cir. 2022)
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Plaintiff, a police officer, served in the Intelligence Division. When a new captain took over, he made personnel changes, including the transfer or detachment of 17 male officers and 5 female officers across the department. Two males and two females were transferred out of the Intelligence Division. Plaintiff was transferred to the Fifth District.
Shortly after her transfer, Plaintiff filed a discrimination charge with the Missouri Commission on Human Rights. Around the same time, Plaintiff sought to transfer out of the Fifth District. The Captain made an informal request for Plaintiff’s transfer, but no formal request was ever made. Eventually, the following year, Plaintiff was transferred back into the Intelligence Division.
Plaintiff filed gender discrimination and retaliation claim in state court. Defendants removed the case to federal court. The district court granted summary judgment in favor of Defendants.
The Eighth Circuit affirmed. The court held that Plaintiff’s transfer from the Intelligence Division to the Fifth District did not constitute an adverse employment action. Plaintiff’s pay and rank remained the same after the transfer. The transfer did not affect her future job prospects. An employee’s reassignment, absent proof of harm resulting from that reassignment, is insufficient to constitute an adverse employment action.
Court Description: [Shepherd, Author, with Loken and Stras, Circuit Judges] Civil case - Employment discrimination. The district court did not err in determining plaintiff had not suffered an adverse employment action and failed to make a prima facie case of a Title VII violation; a reassignment, absent proof of harm resulting from the assignment, is insufficient to constitute an adverse employment action; the district court did not err in determining that plaintiff had not suffered a material adverse action sufficient to deter a reasonable employee from making a claim of discrimination and failed to establish a prima facie case of retaliation.
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