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Ames v. Ohio Department of Youth Services

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Supreme Court of the United States
Ames v. Ohio Department of Youth Services
Term: 2024
Important Dates
Argued: February 26, 2025
Decided: June 5, 2025
Outcome
vacated and remanded
Vote
9-0
Majority
Chief Justice John RobertsClarence ThomasSamuel AlitoSonia SotomayorElena KaganNeil GorsuchBrett KavanaughAmy Coney BarrettKetanji Brown Jackson
Concurring
Clarence ThomasNeil Gorsuch

Ames v. Ohio Department of Youth Services is a case that was decided by the Supreme Court of the United States on June 5, 2025, during the court's October 2024-2025 term. The case was argued before the Supreme Court of the United States on February 26, 2025.

In a 9-0 opinion, the court vacated and remanded the judgment of the United States Court of Appeals for the Sixth Circuit, holding that the Sixth Circuit has implemented a rule that requires Title VII plaintiffs who are members of majority groups to satisfy a heightened evidentiary standard to carry their burden under the first step of the McDonnell Douglas framework. The Supreme Court concluded that Title VII does not impose such a heightened standard on majority group plaintiffs. Justice Ketanji Brown Jackson delivered the opinion of the court.[1]

HIGHLIGHTS
  • The issue: The case concerned employment discrimination claims for majority groups. Click here to learn more about the case's background.
  • The questions presented: "Whether, in addition to pleading the other elements of Title VII, a majority-group plaintiff must show 'background circumstances to support the suspicion that the defendant is that unusual employer who discriminates against the majority.' App. 5a."[2]
  • The outcome: In a 9-0 opinion, the court vacated and remanded the judgment of the United States Court of Appeals for the Sixth Circuit.[1]

  • The case came on a writ of certiorari to the United States Court of Appeals for the Sixth Circuit. To review the lower court's opinion, click here.

    Background

    Case summary

    The following are the parties to this case:[3]

    • Petitioner: Marlean A. Ames
      • Legal counsel: Xiao Wang (University of Virginia School of Law)
    • Respondent: Ohio Department of Youth Services

    The following summary of the case was published by Oyez:[4]

    The Ohio Department of Youth Services hired Marlean Ames, a heterosexual woman, in 2004 and promoted her to Administrator of the Prison Rape Elimination Act (PREA) in 2014. In 2017, Ames was assigned a new supervisor, Ginine Trim, who is gay. Trim reported to Assistant Director Julie Walburn, and in 2019, Ryan Gies was appointed as the Department's Director. Both Walburn and Gies are heterosexual. In December 2018, Trim gave Ames a generally positive performance evaluation.


    In April 2019, Ames applied for the position of Bureau Chief of Quality but was not selected. Shortly after, Trim suggested that Ames consider retirement. On May 10, 2019, Ames was demoted from her PREA Administrator position, resulting in a significant pay cut. The Department then promoted Alexander Stojsavljevic, a 25-year-old gay man, to the PREA Administrator position. Later that year, Yolanda Frierson, a gay woman, was chosen as Bureau Chief of Quality. Following these events, Ames filed a discrimination charge with the Equal Employment Opportunity Commission and then sued the Department under Title VII of the Civil Rights Act of 1964, asserting claims of discrimination based on sexual orientation and sex. The district court granted summary judgment to the Department, holding that Ames lacked evidence of “background circumstances” necessary to establishing her prima facie case for her claim based on sexual orientation, and that Ames lacked evidence of pretext for purposes of her sex-discrimination claim. The U.S. Court of Appeals for the Sixth Circuit affirmed.[5]

    To learn more about this case, see the following:

    Timeline

    The following timeline details key events in this case:

    Questions presented

    The petitioner presented the following questions to the court:[2]

    Questions presented:
    Whether, in addition to pleading the other elements of Title VII, a majority-group plaintiff must show 'background circumstances to support the suspicion that the defendant is that unusual employer who discriminates against the majority.' App. 5a.[5]

    Oral argument

    Audio

    Audio of oral argument:[7]



    Transcript

    Transcript of oral argument:[8]

    Outcome

    In a 9-0 opinion, the court vacated and remanded the judgment of the United States Court of Appeals for the Sixth Circuit, holding that the Sixth Circuit has implemented a rule that requires Title VII plaintiffs who are members of majority groups to satisfy a heightened evidentiary standard to carry their burden under the first step of the McDonnell Douglas framework. The Supreme Court concluded that Title VII does not impose such a heightened standard on majority group plaintiffs. Justice Ketanji Brown Jackson delivered the opinion of the court.[1]

    Opinion

    In the court's majority opinion, Justice Ketanji Brown Jackson wrote:[1]

    As a textual matter, Title VII’s disparate-treatment provision draws no distinctions between majority-group plaintiffs and minority-group plaintiffs. Rather, the provision makes it unlawful ‘to fail or refuse to hire or to discharge any individual, or otherwise to discriminate against any individual with respect to his compensation, terms, conditions, or privileges of employment, because of such individual’s race, color, religion, sex, or national origin.’ 42 U. S. C. §2000e–2(a)(1) (emphasis added). The ‘law’s focus on individuals rather than groups [is] anything but academic.’ Bostock v. Clayton County, 590 U. S. 644, 659 (2020). By establishing the same protections for every ‘individual’—without regard to that individual’s membership in a minority or majority group—Congress left no room for courts to impose special requirements on majority-group plaintiffs alone.[5]

    —Justice Ketanji Brown Jackson

    Concurring opinion

    Justice Clarence Thomas filed a concurring opinion, joined by Justice Neil Gorsuch.

    In his concurring opinion, Justice Thomas wrote:[1]

    I join the Court’s opinion in full. I write separately to highlight the problems that arise when judges create atextual legal rules and frameworks. Judge-made doctrines have a tendency to distort the underlying statutory text, impose unnecessary burdens on litigants, and cause confusion for courts. The ‘background circumstances’ rule—correctly rejected by the Court today—is one example of this phenomenon. And, the decision below involves another example: The Sixth Circuit analyzed Ames’s Title VII claim under the three-step framework developed by this Court in McDonnell Douglas Corp. v. Green, 411 U. S. 792 (1973). As with the ‘background circumstances’ rule, the McDonnell Douglas framework lacks any basis in the text of Title VII and has proved difficult for courts to apply. In a case where the parties ask us to do so, I would be willing to consider whether the McDonnell Douglas framework is a workable and useful evidentiary tool.[5]

    —Justice Clarence Thomas

    Text of the opinion

    Read the full opinion here.

    October term 2024-2025

    See also: Supreme Court cases, October term 2024-2025

    The Supreme Court began hearing cases for the term on October 7, 2024. The court's yearly term begins on the first Monday in October and lasts until the first Monday in October the following year. The court generally releases the majority of its decisions in mid-June.[9]


    See also

    External links

    Footnotes