Wanza Cole v. Wake County Board of Education

Title VII of the Civil Rights Act of 1964 makes it unlawful for an employer “to fail or refuse to hire or to discharge any individual, or otherwise to discriminate against any individual” with respect to “compensation, terms, conditions, or privileges of employment” on the basis of race, religion, sex, or other protected status. 42 U.S.C. § 2000e-2(a)(1). The Fourth Circuit below— following binding circuit precedent limiting the reach of Title VII to discriminatory conduct that imposes “significant detrimental effect” on employees—held that certain discriminatory job transfers are not prohibited by Title VII. The question presented is: Does Title VII prohibit discrimination as to all “terms, conditions, or privileges of employment,” or is its reach limited to only discriminatory employer conduct that courts determine have significant detrimental effects on employees?