The definitions in our glossary are primarily sourced from Nolo’s Plain-English Law Dictionary and Cornell Law School’s Legal Information Institute. We have made slight modifications where needed for brevity and to better tailor the definitions to the specific needs of users of this website. For more detailed explanations of the terms, users are encouraged to review the definitions on these websites or conduct their own independent research.
CASE NAME
Ames v. State of Ohio Department of Youth Services
Overview
Plaintiff (Ames), a former employee of the Ohio Department of Youth Services, sued Defendant arguing that she was discriminated against based on her sexual orientation (heterosexual) when Defendant denied her a promotion to Bureau Chief and demoted her from the position of PREA Administrator.
Details
The Sixth Circuit Court of Appeals rejected Ames's claim. The court found that Ames lacked evidence of “background circumstances to support the suspicion that the defendant is that unusual employer who discriminates against the majority.”
Ames appealed to the Supreme Court, requesting that the Court answer the question whether a majority-group plaintiff (e.g., heterosexual or white individuals) must show “background circumstances to support the suspicion that the defendant is that unusual employer who discriminates against the majority.”
On February 26 2025, the Supreme Court heard oral argument in the case, and on June 5, 2025, the Supreme Court held that Title VII does not impose a heightened evidentiary standard on dominant groups. As a result, the "background circumstances" test was removed.
Significance
Some circuits required plaintiffs in "reverse discrimination" cases to provide evidence that their employer was the unusual employer who discriminates against the majority. The Supreme Court decision makes it easier for "reverse discrimination" plaintiffs to succeed in their lawsuits in some circuits.
Nonetheless, given that many circuits already apply the same standard to majority and minority plaintiffs, the implications of this decision are limited.