Supreme Court Unanimously Rejects Heightened Burden for Majority-Group Plaintiffs in Title VII Claims
On June 5, 2025, the United States Supreme Court issued a unanimous opinion in Ames v. Ohio Department of Youth Services , rejecting a longstanding rule applied by the Sixth Circuit and other circuit courts that imposed a heightened evidentiary burden on majority-group plaintiffs bringing claims for discrimination under Title VII of the Civil Rights Act. Specifically, the Court held that such plaintiffs are not required to demonstrate “background circumstances” to establish a prima facie case of discrimination under the McDonnell Douglas framework. In doing so, the Court resolved a circuit split and reaffirmed that Title VII’s protections apply uniformly to “any individual,” regardless of demographic status. Background: Sixth Circuit’s “Background Circumstances” Rule Marlean Ames, a heterosexual woman, sued the Ohio Department of Youth Services after she was denied a promotion and demoted, with her previous position filled by a gay man. She alleged that the...