The U.S. Supreme Court has granted certiorari in Muldrow v. City of St. Louis, Mo., No. 22-193, to address a split in the circuit courts over whether a forced lateral transfer, with no change in pay or benefits, is an adverse employment action under Title VII of the Civil Rights Act of 1964. Such a finding would further expand the type of conduct that can give rise to a cause of action under Title VII.
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