## Facts

- Marlean Ames, a heterosexual woman, worked for the Ohio Department of Youth Services (ODYS) starting in 2004 and became Administrator of the Prison Rape Elimination Act (PREA) in 2014.
- In 2017, ODYS assigned Ames a new supervisor, Ginine Trim (gay), who reported to Assistant Director Julie Walburn; ODYS’s director, Ryan Gies, was appointed in 2019.
- In December 2018, Trim gave Ames a generally positive performance evaluation.
- In April 2019, Ames applied for a management position (Bureau Chief of Quality/Quality Assurance and Improvement), interviewed, and was not selected; ODYS chose Yolanda Frierson (a gay woman).
- On May 10, 2019, ODYS demoted Ames from the PREA Administrator role, resulting in a significant pay cut, and promoted Alexander Stojsavljevic (a gay man) to that position.
- Ames filed an EEOC charge and sued ODYS under Title VII, alleging denial of promotion and demotion because of sex and sexual orientation.

## Issues

1. Whether Title VII permits courts to require majority-group plaintiffs, as part of their prima facie case under McDonnell Douglas, to prove “background circumstances” suggesting the employer is unusually likely to discriminate against the majority.
2. Whether the Sixth Circuit erred by applying a heightened evidentiary standard to a heterosexual plaintiff asserting disparate-treatment discrimination under Title VII.

## Decision

- The Supreme Court unanimously vacated the Sixth Circuit’s judgment and remanded.
- The Court held that Title VII does not allow a heightened “background circumstances” requirement for majority-group plaintiffs.
- The Court directed the lower courts to evaluate Ames’s claims using the same McDonnell Douglas prima facie standard applied to all Title VII plaintiffs, without extra hurdles based on majority status.
- Justice Thomas, joined by Justice Gorsuch, concurred, agreeing the heightened rule was impermissible while questioning continued reliance on the McDonnell Douglas framework.

## Legal Principles

- Title VII’s disparate-treatment provision protects “any individual” from adverse employment actions taken “because of” protected characteristics; the statute does not create different evidentiary regimes based on group status.
- Courts may not “ratchet up” the prima facie burden for majority-group plaintiffs by requiring “background circumstances” or similar showings beyond the ordinary prima facie elements.
- Under McDonnell Douglas, the prima facie burden is “not onerous” and requires evidence sufficient to permit an inference of discrimination; that standard applies uniformly to all plaintiffs.
- Judicial skepticism about the plausibility of discrimination against certain groups cannot justify imposing different prima facie requirements in Title VII cases.

## Conclusion

The Court rejected special prima facie burdens for “reverse discrimination” claims and required that Title VII disparate-treatment plaintiffs—whether in majority or minority groups—be assessed under the same evidentiary standard.


Ames v. Ohio Dep’t of Youth Servs., 605 U.S. ___ (2025)