SCOTUS Unanimously Lowers Bar for “Reverse Discrimination” Claims: Ames v. Ohio Department of Youth Services Redefines Title VII Litigation

on July 03, 2025

Ames v. Ohio Department of Youth Services is a significant Supreme Court case that ruled on June 5, 2025, that majority-group plaintiffs, such as heterosexual individuals, do not need to meet a heightened evidentiary standard to prove discrimination under Title VII of the Civil Rights Act. 

The Supreme Court unanimously held that Title VII of the Civil Rights Act does not require majority-group plaintiffs to meet a heightened "background circumstances" standard to prove employment discrimination. The case centered on whether Marlean Ames, a heterosexual woman, needed to prove her employer, the Ohio Department of Youth Services, was an "unusual employer" who discriminated against the majority when she claimed she was denied a promotion and demoted due to her sexual orientation. The Court found that this heightened standard, which had been applied by some lower courts, was inconsistent with Title VII's text and purpose.

Case History

Ames v. Ohio Department of Youth Services, 87 F.4th 822 (6th Cir. 2023), cert. granted, 145 S. Ct. 118 (2024), and vacated and remanded, 145 S. Ct. 1540 (2025)

Heterosexual female state employee brought Title VII reverse sexual orientation discrimination and sex discrimination claims against employer, alleging that she was demoted and replaced by gay man and was denied promotion in favor of gay woman. The United States District Court for the Southern District of Ohio, Judge Algernon L. Marbley, granted employer summary judgment. The employee, Marlean Ames appealed. The SCOTUS rejected the "background circumstances" rule, allowing for a more straightforward approach to reverse discrimination claims.

Case Importance

The core question before the Supreme Court was whether a majority-group plaintiff like Ames had to meet a higher burden of proof than minority-group plaintiffs when claiming discrimination under Title VII. This decision simplifies the legal process for all discrimination claims, ensuring equal treatment regardless of the plaintiff's group status, which may lead to an increase in "reverse discrimination" lawsuits.