Legislative Partner
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BY STORM LARSON
I n 2024, the U.S. Supreme Court ruled in Muldrow v. City of St. Louis, Missouri, 601 U.S. 346 (2024) that plaintiffs need only show “some harm” in the workplace to state a claim for employment dis- crimination under Title VII. Since that time, lower federal courts have been deciding cases which apply this new standard. Recently, the U.S. Court of Appeals for the Seventh Circuit (which covers Wisconsin, Illinois, and Indiana) decided Thomas v. JBS Green Bay, Inc. and held that an employee alleged enough to show that his employer may have violated Title VII. In that case, Miko Thomas sued his em- ployer, JBS Green Bay, Inc. (“JBS”), and alleged that it discriminated against him because of his color. Among his allegations were that JBS delayed his training on a particular machine, de- nied him vacation while granting va- cation requests to other workers, and that JBS transferred him to a different shift while knowing that the transfer would cause him difficulty with raising a young child. The trial court original- ly dismissed Mr. Thomas’s complaint because it found that these types of actions were not sufficiently serious to allege a violation of Title VII.
Mr. Thomas appealed that dismissal and the Seventh Circuit reversed the trial court’s decision. The Seventh Circuit held that the standard an- nounced in Muldrow does not require Mr. Thomas to show that any alleged harm he suffered was significant. Ac-
The U.S. Court of Appeals for the Seventh Circuit (which covers Wis - consin, Illinois, and Indiana) decid - ed Thomas v. JBS Green Bay, Inc. and held that an employee alleged enough to show that his employer may have violated Title VII.
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