Here’s an analysis of the Supreme Court’s decision in Ames v. Ohio Department of Youth Services (June 5, 2025). You can read the full opinion by clicking here.
Case Background
Marlean Ames, a heterosexual woman, worked for the Ohio Department of Youth Services since 2004. In 2019, she applied for a management position but was passed over in favor of a lesbian woman. Shortly after, she was demoted from her program administrator role (with pay cut), and a gay man filled the vacancy she left. Ames sued, claiming she was denied promotion and then demoted because of her sexual orientation, invoking Title VII’s anti-discrimination provisions.
Lower Courts’ Rulings
Both the District Court and the Sixth Circuit sided with the state agency. They relied on a “background circumstances” rule: when a member of a majority group (like a heterosexual plaintiff) claims discrimination, she must show special evidence—“background circumstances”—suggesting that the employer is that rare case that discriminates against the majority. Without this extra showing, her case failed at the first step (prima facie case) under the McDonnell Douglas framework for employment discrimination.
Supreme Court’s Holding
The Supreme Court unanimously reversed. It held that Title VII does not impose a higher evidentiary burden on majority-group plaintiffs. The statute bars discrimination against any individual because of a protected characteristic, regardless of whether they’re in a majority or minority group. Imposing extra hurdles on majority-group claimants contradicts the statute’s text and the Court’s precedents.
Key Reasoning
- Title VII’s Text: The law protects “any individual,” not just minorities; it makes no distinction between groups.
- Precedent: In cases like Griggs v. Duke Power and McDonald v. Santa Fe Trail, the Court held that Title VII protects all employees equally.
- McDonnell Douglas Framework: The first step—a prima facie case—is “not onerous.” Requiring extra proof for majority-group plaintiffs is an unjustified judicial add-on.
- Circuit Split: The Sixth Circuit was among several that imposed this “background circumstances” rule, but other circuits do not. The Supreme Court resolved this split.
What Happens Next
The ruling vacated (erased) the lower court’s decision and sent the case back for reconsideration under the correct standard. Ames now only needs to meet the same “prima facie” requirements as anyone else claiming discrimination, regardless of her majority status.
Concurring Opinion (Justice Thomas, joined by Justice Gorsuch)
Justice Thomas agreed with the result but used the opportunity to criticize judge-made frameworks like “background circumstances” and even the McDonnell Douglas test itself, arguing these add confusion and aren’t rooted in the statutory text. He suggested the Court should, in the future, reconsider whether the McDonnell Douglas framework should apply at all.
Bottom Line
- The Supreme Court struck down the heightened “background circumstances” rule for majority-group plaintiffs in Title VII cases.
- Title VII protects every individual equally: straight, gay, white, Black, male, or female.
- This decision ensures that all workers have the same legal burden when alleging discrimination, no matter which “group” they belong to.
Girards Law Firm specializes in severe injury and wrongful death cases, especially those that involve birth injuries, brain damage, heart damage, spinal cord injuries or severe burns in Texas, Arkansas and Oklahoma. Contact us at www.girardslaw.com by using the chat feature for more information.