Statute Annotations › Federal › 42 U.S.C. § 2000e-2

42 U.S.C. § 2000e-2

Unlawful employment practices: the cases that interpreted this section

Jurisdiction
Federal
Case notes
12,593
Cited in passing
5,373
Citing cases indexed
23,155
Case dates
1966–2026
Screened through
2026-01-28
Courts' treatment: live
No reviewed case has held this section invalid, preempted, superseded or repealed.
This reflects what the reviewed cases said, not legislative action: a later amendment or repeal by the legislature would not appear here unless a reviewed case discussed it.

17,966 citing cases reviewed of 23,155 in the citation index: 12,593 interpreted the section (annotated below), 5,373 cited it only in passing. Cases filed after 2026-01-28 may not have been reviewed yet.

Have a situation under 42 U.S.C. § 2000e-2?

These notes show how courts have ruled. Ask about your specific facts and see which of these rulings apply, with citations you can check.

Sex discrimination in compensation

Section 2000e-2(a)(1) allows a sex discrimination claim to proceed when factual disputes remain over whether similarly situated employees were treated more favorably and whether the employer’s reasons were pretextual.

Sayers-Russell v. Southwest Airlines Company · filed 2021-01-15(a)(1)

In sum, there are genuine disputes of material fact regarding whether other similarly ... situated employees were treated more favorably than Plaintiff, and whether Defendant’s ... proffered reasons for terminating Plaintiff are pretextual.
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Section 2000e-2 requires a sex discrimination complaint to allege facts supporting an inference that the plaintiff was treated unfavorably because of sex.

Vaughn v. State of Delaware Department of Insurance · filed 2021-02-11

Ms. Vaughn’s complaint fails to state a claim of either sex discrimination or sexual harassment under Title VII because she does not plead any factual matter to give rise to the inference that she was treated unfavorably on the basis of her sex.
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Section 2000e-2(a)(1) permits a sex-discrimination claim when the alleged facts plausibly show that menstruation and tampon use were a but-for cause of discharge.

Flores v. Virginia Department of Corrections · filed 2021-02-22(a)(1)

This leads the court to conclude, under the facts as alleged, that but for Flores’s menstruation and use of a tampon—conditions inextricable from her sex and her child-bearing capacity—she would not have been discharged.
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A sex discrimination complaint must allege facts making it plausible that the employer acted because of the plaintiff’s sex.

Amis v. Wolf · filed 2021-03-01(a)(1)

To state a claim for relief under Title VII, a plaintiff must “allege facts [sufficient] to satisfy the elements of a cause of action . . . in this case, that the [Department of Homeland Security] ‘fail[ed] or refus[ed] to hire [him] because of [his] . . . sex.’” McCleary-Evans v. Md. Dept. Of Transp., State Highway Admin., 780 F.3d 582, 585 (4th Cir. 2015) (emphasis in original) (quoting 42 U.S.C. § 2000e-2(a)(1)). ... Plaintiff has accordingly failed to state a plausible claim for relief under Title VII for sex discrimination.
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Section 2000e-2(a) requires a sex-discrimination plaintiff to plausibly allege adverse employment action and more favorable treatment of similarly situated employees outside her protected class.

Gomez v. City of Doral · filed 2021-03-05(a)

To make out a prima facie claim of sex discrimination, a plaintiff must show: (1) she is a member of a protected class; (2) she was qualified to do the job; (3) she was subjected to an adverse employment action; and (4) her employer treated similarly situated employees outside of her protected class more favorably. ... Here, the Court finds that Plaintiff has failed to allege enough facts to make out a prima facie claim of sex discrimination.
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A sex discrimination claim based on unequal compensation requires evidence that the employer treated a comparable employee outside the plaintiff’s protected class more favorably.

Keith v. Talladega City Board of Education · filed 2021-03-10(a)(1)

Title VII of the Civil Rights Act of 1964 prohibits employers from discriminating “against any individual with respect to his compensation, terms, conditions, or privileges of employment, because of such individual’s…sex.” 42 U.S.C. § 2000e-2(a)(1). ... As to Ms. Keith’s challenge to the Board’s $7,000 “offer” to Mr. Roller, then, she cannot show that the Board “treated [Mr. Roller]…more favorably” because it did not pay him any supplemental compensation to fill the role of athletic director and did not actually “offer” him $7,000 in supplemental compensation to fill that role—even assuming that an offer of compensation is actionable under Title VII.
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Section 2000e-2(a)(1) treats discriminatory loss of employment or reassignment with materially different duties as an adverse employment action sufficient to support a sex discrimination claim at the pleading stage.

Ingram v. Regano · filed 2021-03-31(a)(1)

According to her Complaint, she lost her employment as a result of Defendants’ discrimination. Loss of employment is an adverse employment action as is reassignment with material differences in job duties. At the pleading stage, these allegations are sufficient to support her Sex Discrimination claim.
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A sex-discrimination claim cannot survive summary judgment without evidence that the employee was fired under circumstances supporting an inference of discrimination.

JENKINS v. SEPTA · filed 2021-05-10(a)(1)

At this stage, Jenkins’ bare allegations do not support the conclusion that SEPTA terminated her under circumstances giving rise to an inference of discrimination. ... As Jenkins has not established her prima facie case, we will not reach whether a reasonable factfinder could find pretext. Accordingly, Jenkins’ claim that she was fired because of her gender does not survive summary judgment.
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Section 2000e-2(a) allows a sex discrimination claim based on unequal pay to reach a jury when the evidence could show that similarly situated employees were paid differently because of sex.

EGELKAMP v. ARCHDIOCESE OF PHILADELPHIA · filed 2021-05-18(a)

A reasonable jury, weighing the credibility of the relevant witnesses, could find that Egelkamp was paid less than Friedman because of her gender even though there was substantial similarity between their responsibilities and relevant experience.
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Section 2000e-2(a)(1) permits a sex discrimination claim based on lower pay than male employees performing equal work, even when they work in different departments.

Brightman v. Physician Affiliate Group of New York, P.C. · filed 2021-05-19(a)(1)

At the motion to dismiss stage, Brightman plausibly alleges Title VII and NYSHRL sex discrimination claims arising from pay discrimination. ... The standard is whether Brightman was paid “less than her male peers who performed equal work,” Lenzi, 944 F.3d at 110, and at the pleading stage, Brightman has plausibly alleged that she and her male colleagues performed equal work even though they were assigned to different departments.
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A sex discrimination claim under § 2000e-2 may proceed to service when the complaint plausibly alleges it.

Closser v. P.C.C.W. Teleservices (US) Inc. · filed 2021-06-14

Keeping in mind the liberal construction due pro se complaints, and the lesser pleading standard to which pro se litigants are held, the court finds that Plaintiff has alleged plausible claims for sex discrimination and retaliation under Title VII of the Civil Rights Act of 1964, 42 U.S.C. §§ 2000e-2 & 2000e-3, and the Nebraska Fair Employment Practice Act, Neb. Rev. Stat. §§ 48-1104 & 48-1114, and also for violations of the Equal Pay Act, 29 U.S.C. § 206(d), and the Nebraska Equal Pay Act, Neb. Rev. Stat. § 48-1221.
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Section 2000e-2(a) prohibits employment discrimination based on sex; a claim fails when the employer gives legitimate, nondiscriminatory reasons for termination and the employee cannot show they are pretextual.

Jones v. Grant County Hospital District 1 · filed 2021-06-15(a)

The Court finds that a reasonable jury would not conclude by a preponderance of the evidence that Mr. Jones’s sex was a motivating factor in Defendant’s decision to terminate him. As such, summary judgment on Plaintiffs’ Title VII claim is appropriate.
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A sex-discrimination claim under § 2000e-2 can support default judgment when the pleaded facts imply termination because of sex.

Murray v. Stengel · filed 2021-06-22(a)(1)

Under 42 U.S.C. § 2000e-2, “[i]t shall be an unlawful employment practice for an employer 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.” ... Taking the facts in Plaintiff’s Complaint as true, the foregoing is enough to satisfy Rule 8(a). ... As such, no material fact issue exists as to Plaintiff’s unlawful employment practices claim.
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Section 2000e-2 permits a sex discrimination claim to proceed when a jury could find that the employer’s stated reasons for an adverse action were pretext for discrimination.

Singer v. University of Tennessee Health Sciences Center · filed 2021-08-04

Because a reasonable fact-finder would have a factual basis to find that UTHSC’s proffered reasons for Singer’s non-renewal were merely pretext for Title VII discrimination, summary judgment is DENIED.
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A sex discrimination claim under § 2000e-2(a)(1) must allege facts showing different treatment or intentional discrimination because of sex.

Torres v. Pasco County Board of Commissioners · filed 2021-08-11(a)(1)

To the extent that Plaintiff alleges a sex discrimination claim, the Court finds that she has failed to meet her pleading burden. She has failed to allege that she was treated differently or intentionally discriminated against due to her sex.
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Section 2000e-2(a) prohibits discharge because of sex; a plaintiff must present evidence from which a reasonable factfinder could conclude that sex caused the discharge.

Henseler v. Cook Canton, LLC · filed 2021-08-17(a)

Whether assessed under the McDonnell Douglas burden-shifting approach or the holistic approach set forth in Ortiz, Plaintiff is unable to meet his burden at summary judgment to show a reasonable fact finder could conclude that Plaintiff’s sex caused his termination.
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Section 2000e-2(a)(1) prohibits national-origin discrimination in compensation, and evidence linking bias to a pay decision can support a discrimination claim.

Biliovschi Smith v. Pompeo · filed 2021-08-24(a)(1)

These statements, leading up to and during the process of establishing her pay level and rejecting her superior qualifications rate request, provide sufficient evidence from which a jury could conclude that Ms. Smith suffered unlawful discrimination on the basis of her national origin in violation of Title VII.
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Section 2000e-2(a)(1) requires a sex discrimination complaint to plausibly link an adverse employment action to the plaintiff’s sex.

Harris v. NYC Human Resources Administration · filed 2021-08-27(a)(1)

The Court rejects Harris’s Title VII claim because the Second Amended Complaint does not plead any facts suggesting that her demotion or transfer was linked to her sex.
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Section 2000e-2(a)(1) prohibits an employer from discriminating against or discharging an employee because of sex.

KROHMER v. AMERICAN AIRLINES, INC. · filed 2021-08-27(a)(1)

Count III alleges sex-based discrimination in violation of Title VII, 42 U.S.C. § 2000e–2(a)(1). Title VII makes it unlawful for an employer to discriminate against or discharge an employee “because of” the individual’s “sex.”
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Section 2000e-2(a)(1) prohibits sex discrimination in employment, including less favorable treatment than similarly situated employees of another sex.

Littleton v. Jackson State University · filed 2021-09-29(a)(1)

Plaintiff, at this juncture, has alleged sufficient facts to establish a claim for gender discrimination under Title VII.
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A reverse sex discrimination claim under § 2000e-2(a)(1) must plead enough facts to support a Title VII claim.

Schrader v. Emporia State University · filed 2021-09-21(a)(1)

the court concludes that although plaintiff has not pleaded a Title VII claim sufficiently, he has pleaded a Title IX claim sufficiently, for reasons explained below.
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Section 2000e-2(a)(1) prohibits sex discrimination in employment; a plaintiff must produce sufficient evidence for a reasonable jury to find intentional discrimination.

D'Andrea v. Paragon Systems, Inc. · filed 2021-09-30(a)(1)

D’Andrea has not produced sufficient evidence for a reasonable jury to find for her on her sex discrimination claim.
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Section 2000e-2(a)(1) prohibits discharge because of sex; a plaintiff relying on circumstantial evidence must show an inference of discrimination and, if the employer gives a legitimate reason, evidence of pretext.

Quayle v. Catholic Health Initiatives Colorado · filed 2021-09-30(a)(1)

Moreover, the circumstances surrounding that disagreement and the details leading to plaintiff’s PRIP further demonstrate that plaintiff cannot make out a prima facie case of discharge based on being a woman.
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Section 2000e-2(a)(1) prohibits sex discrimination, including discrimination based on sexual orientation and sex-based hostile work environments.

Schmidt v. H.H. Hall Restaurant of York, Inc. · filed 2021-10-13(a)(1)

Upon review of Plaintiff’s Amended Complaint, including its attachments, the court finds for purposes of 28 U.S.C. § 1915(e)(2) that Plaintiff has stated plausible claims for relief under Title VII for disparate treatment sex discrimination, sexual harassment (hostile work environment), and retaliation, and that the matter should proceed to service of process on such claims.
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Under § 2000e-2(a)(1), evidence disputing an employer’s reason for termination does not establish sex discrimination without evidence connecting the termination to the employee’s sex.

Maltby v. Alabama Municipal Insurance Corporation (CONSENT) · filed 2021-10-18(a)(1)

Because Maltby has failed to demonstrate a connection between her proffered evidence and her termination, that evidence does not establish AMIC’s reason for her termination is a pretext for discrimination or create a genuine issue of material fact as to whether her gender was a determinative factor in her termination.
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A Title VII sex-discrimination claim survives summary judgment only if the evidence would allow a reasonable juror to infer discrimination based on sex.

Burdett v. United Parcel Service, Inc. · filed 2021-11-03(a)(1)

On the record here, Burdett’s sex discrimination claim cannot survive summary judgment because she points to no reasonable inferences from the totality of the evidence which would lead a juror to conclude that UPS discriminated against Burdett on the basis of sex.
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Section 2000e-2(a)(1) prohibits discharge because of sex; alleging that only female employees were fired during a period, without more, does not state a plausible sex discrimination claim.

Dedrick v. Abilene Motor Express, Inc. · filed 2021-11-08(a)(1)

The fact that only female employees were terminated during this window of time, absent more, does not raise the claim of sex discrimination above mere speculation.
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Section 2000e-2(a)(1) prohibits employment discrimination because of sex; a complaint must allege facts supporting an inference that sex motivated the employer’s action.

Singleton III v. Astro Holdings Company, LLC. · filed 2021-11-08(a)(1)

Singleton’s complaint includes no facts that can support an inference that Singleton’s sex motivated Astro’s actions.
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Section 2000e-2(a)(1) requires facts plausibly showing that an employer discriminated against an employee because of sex.

Hunter v. Amazon.com Services, LLC · filed 2021-11-12(a)(1)

For these reasons, Plaintiff fails to plausibly allege any facts to show Defendant discriminated against her because of her sex, and that claim is dismissed.
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Section 2000e-2(a)(1) prohibits sex discrimination in employment; a claimant may survive summary judgment with evidence supporting a prima facie case and a finding of pretext.

Tuck v. McCarthy · filed 2021-11-15(a)(1)

Title VII prohibits employers from discriminating against individuals on the basis of sex. 42 U.S.C. § 2000e–2(a)(1). ... Viewing the evidence and drawing all reasonable inferences in the light most favorable to Plaintiff, the Court finds that a reasonable jury could determine that Defendant’s proffered reason was pretext for discrimination. Accordingly, Defendant’s motion for summary judgment will be denied.
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Section 2000e-2(a)(1) prohibits adverse employment actions because of sex; a sex discrimination claim fails when no reasonable jury could find that sex caused the actions.

JOHNSON v. FRANKLIN TOWNSHIP COMMUNITY SCHOOL CORPORATION · filed 2021-11-24(a)(1)

No reasonable jury could find that Johnson's removal from her administrative position, severance offer, non-renewal of her administrative contract, demotion to a teaching position, or placement on administrative leave was because of her sex.
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Section 2000e-2(a)(1) requires evidence that an adverse employment action was motivated by sex; a supervisor’s favorable attention to female employees alone does not establish discrimination.

Carvalho v. Santander Bank, N.A. · filed 2021-11-30(a)(1)

Ms. Lindstrom’s tendency to favor and give attention to Ms. Carvalho and other female employees does not, without more evidence, amount to gender discrimination against Ms, Carvalho.
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Section 2000e-2(a) allows a sex-based pay discrimination claim to proceed to trial when the evidence could permit a reasonable jury to find that sex caused the pay disparity.

Ahad v. Southern Illinois School of Medicine · filed 2021-12-27(a)

The Court finds that the submitted evidence—when reviewed as a whole, taken in the light most favorable to Dr. Ahad, and including the reasonable inferences drawn therefrom—could lead a reasonable jury to conclude that Defendants discriminated against Dr. Ahad by paying her less because of her sex.
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Section 2000e-2(a)(1) prohibits employment discrimination because of sex; a complaint must allege facts supporting an inference that the mistreatment was based on sex.

Vaughn v. Secretary of the Department Veteran Affairs · filed 2022-01-12(a)(1)

Although Plaintiff alleges in conclusory terms that he was mistreated, harassed, falsely written-up, and subjected to a hostile work environment that forced him to retire early from his employment, he has not alleged facts in his complaint supporting his conclusory allegations of mistreatment or giving rise to a plausible inference that any mistreatment he alleges was taken against him was based on or because of his sex (or any other characteristic protected by Title VII).
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Under § 2000e-2(a)(1), a sex discrimination plaintiff using the McDonnell Douglas framework must show that she met her employer’s legitimate expectations and that similarly situated male employees were treated more favorably.

Robinson v. Wawasee Community School Corporation · filed 2022-01-24(a)(1)

Ms. Robinson’s Title VII discrimination claim falters because no reasonable jury could find that she was meeting Wawasee’s legitimate expectations or that similarly situated male coaches were treated more favorably.
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Section 2000e-2(a)(1) does not make adverse action motivated by jealousy over an employee’s romantic relationship sex discrimination when the employee’s sex did not motivate the action.

WHETSTINE v. WOODS SERVICES · filed 2022-01-24(a)(1)

The motive behind the adverse employment actions was Plaintiff’s relationship with Mr. Whetstine, not any protected characteristic of any of them. ... Thus, Plaintiff has not plausibly stated a claim for sex discrimination and Defendant’s Motion to Dismiss as to Count I will be granted.
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Section 2000e-2(a)(1) allows a plaintiff to establish a prima facie case of sex discrimination through circumstances from which a reasonable factfinder could infer discrimination.

GATES v. ARAMARK CORPORATION · filed 2022-01-24(a)(1)

This constitutes sufficient evidence from which a reasonable factfinder could find a prima facie case of discrimination on the basis of sex.
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Section 2000e-2 permits a sex discrimination claim to proceed when an applicant alleges that an employer hired a less-qualified person of another sex for a position he sought.

Etheridge v. Hudson Group · filed 2022-02-08(a)(2)

Etheridge alleges that he applied for a position, and the company hired a less-qualified woman instead. That’s thin, but under controlling precedent, it is enough to state a claim.
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Section 2000e-2(a)(1) prohibits discharge because of sex; a claim cannot survive summary judgment without evidence that would permit a reasonable factfinder to find that sex caused the discharge.

Sims v. Whitley · filed 2022-03-08(a)(1)

All of the evidence, considered cumulatively, would not permit a reasonable factfinder to conclude that Plaintiff was terminated because of her sex.
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A plaintiff may prove sex discrimination under Title VII through direct or indirect evidence or the McDonnell Douglas burden-shifting framework.

NEW V. THERMO FISHER SCIENTIFIC, INC. · filed 2022-03-15(a)(1)

A plaintiff may prove discrimination under Title VII “either through direct and indirect evidence of [discriminatory] animus, or through the burden-shifting framework of McDonnell Douglas Corp. v. Green, 411 U.S. 792 (1973).”
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Section 2000e-2(a)(1) prohibits terminating an employee because of sex, and a claim may reach a jury when the evidence could show that changing the employee’s sex would have changed the employer’s decision.

Whitley v. SecTek, Inc. · filed 2022-03-23(a)(1)

And because nothing in Ms. Leahy’s report upon which Ms. Howard-Watts relied suggests that Plaintiff would have been terminated if he had not been found to have sexually harassed Ms. Sylver, there is sufficient evidence to suggest that removing the sexual harassment charge, and the implicit sex discrimination allegedly undergirding that charge, “would have yielded a different choice by the employer” such that a jury could find that “a statutory violation has occurred.” Bostock, 140 S. Ct. at 1741.
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Section 2000e-2(a)(1) permits a sex discrimination claim to proceed when allegations of more favorable treatment of a coworker of another sex support an inference of discrimination.

Clouser v. Hanover Foods Corporation · filed 2022-05-02(a)(1)

At the pleading stage, Clouser has met his burden to allege that Hanover treated a female coworker in his department more favorably, see Mandel, 706 F.3d at 170, and has raised “a reasonable expectation that discovery will reveal evidence of the necessary elements,” see Connelly, 809 F.3d at 788-89.
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A plaintiff relying on circumstantial evidence of sex discrimination must show pretext after the employer offers a legitimate, nondiscriminatory reason for its action.

Hemenway v. 16th Judicial Attorney's Office · filed 2022-05-24(a)(1)

Hemenway has not presented evidence from which a reasonable jury could find that JDAO’s rationale for terminating her employment is pretext for discrimination. Accordingly, JDAO is entitled to summary judgment on Hemenway’s Title VII claim.
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Section 2000e-2(a)(1) permits a sex discrimination claim to proceed when an employee alleges that her employer denied her a light duty assignment because of her sex.

Rodriguez v. Town of Cicero · filed 2022-06-01(a)(1)

Title VII’s antidiscrimination provision makes it “unlawful … for an employer … 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). ... Under that standard, the complaint’s allegation that Rodriguez sought light duty assignments and was denied, and that the denial was due to sex discrimination, Doc. 50 at ¶ 28, is sufficient to survive a motion to dismiss.
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Section 2000e-2(a)(1) requires evidence that sex caused an adverse employment action; coworkers whose misconduct was less serious are not valid comparators.

Nigro v. Indiana University Health Care · filed 2022-07-08(a)(1)

This difference matters and shows that CAA#1 and Dr. Green are not valid comparators.
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Section 2000e-2(a)(1) prohibits sex discrimination in termination; a complaint must plausibly link the termination to the employee’s sex.

Littlewood v. Novartis Pharmaceuticals Corp · filed 2022-08-03(a)(1)

Reviewing the facts in the light most favorable to Ms. Littlewood and drawing all inferences in her favor, the Court finds that Ms. Littlewood has not plausibly alleged that her termination was the result of her being “treated less favorably” on account of her sex.
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Section 2000e-2(a)(1) prohibits denying an employee spousal health insurance because the employee is married to someone of the same sex.

Doe v. Catholic Relief Services · filed 2022-08-03(a)(1)

There is no genuine dispute over the fact that CRS revoked Doe’s dependent health insurance because of his sex — in particular, that he was a man married to another man, which CRS does not cover under its medical insurance plan.
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Section 2000e-2(a)(1) prohibits sex discrimination in employment; a prima facie claim requires an adverse employment action under circumstances suggesting discrimination.

DENNISON v. INDIANA UNIVERSITY OF PENNSYLVANIA · filed 2022-08-09(a)(1)

A plaintiff can establish a prima facie gender discrimination case by showing: (1) she is a member of a protected class; (2) she was qualified for the position; (3) she suffered an adverse employment action; and (4) this occurred under circumstances that raise an inference of discriminatory action.
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Law changed since Muldrow v. City of St. Louis (2024) held that discriminatory work assignments can be actionable with some harm to an employment term or condition; a significant-harm threshold is no longer required.

More difficult work assignments generally do not constitute sex discrimination under § 2000e-2(a)(1).

LASTER v. GEORGIA DEPARTMENT OF CORRECTIONS · filed 2022-09-23(a)(1)

Indeed, even more difficult work assignments do not generally constitute discrimination in violation of Title VII.
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An employee relying on comparators to prove sex discrimination must identify employees similarly situated in all material respects who received more favorable treatment.

Baker v. Continental Aerospace Technologies, Inc. · filed 2022-09-29(a)(1)

Specifically, Plaintiff has failed to provide evidence of any purported comparators who were similarly situated in all material respects and who were treated more favorably than she was by Continental.
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Section 2000e-2(a) requires evidence that an adverse employment action was caused by the employee’s sex.

Inojosa v. Board of Trustees of the City Colleges of Chicago, Community College District 508 · filed 2022-09-30(a)

There is simply nothing in the record that would allow a reasonable jury to conclude that the events Inojosa complains of had anything to do with his sex.
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Section 2000e-2(a)(1) prohibits discrimination because of sex in compensation and other terms, conditions, or privileges of employment.

Dingman v. Fuji Japanese Steakhouse Sushi Inc. · filed 2022-09-30(a)(1)

For the reasons discussed below, the Court DENIES Defendants’ motion for summary judgment against Plaintiff’s discrimination claims under Title VII and NYSHRL, and GRANTS Defendants’ summary judgment motion against Plaintiff’s retaliation claims under Title VII and the NYSHRL, as well as the NYSHRL aiding and abetting claim against Defendant Chen. ... Under Title VII, it is unlawful for an employer to “discriminate against any individual with respect to his compensation, terms, conditions, or privileges of employment, because of such individual's . . . sex.” 42 U.S.C. § 2000e-2(a)(1).
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Section 2000e-2(a)(1) requires evidence that sex played a role in an adverse employment action to establish a sex discrimination claim.

Torres v. Pasco County Board of Commissioners · filed 2022-10-12(a)(1)

Perhaps more importantly, Plaintiff does not put forth any facts to demonstrate that Defendant treated similarly-situated employees outside of her class (here, men) more favorably, or that Plaintiff’s gender played any part in adverse employment actions.
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Section 2000e-2(a)(1) requires evidence that an employee’s sex caused an adverse employment action.

Perry v. Porter Hospital LLC · filed 2022-10-14(a)(1)

In this case there is simply no evidence to support a reasonable inference that plaintiff’s sex caused her to be offered a night-shift position, or that her sex was the reason for her termination. Accordingly, defendants are entitled to summary judgment on plaintiff’s Title VII claims.
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Section 2000e-2(a)(1) permits a sex discrimination claim to proceed when evidence could allow a jury to infer that an employer’s actions were discriminatory.

Wright v. Legacy Cabinets Inc · filed 2022-10-28(a)(1)

Wright has identified sufficient prima facie evidence from which a jury reasonably could infer that her termination and Legacy’s alleged failure to accommodate “were based on a discriminatory criterion.”
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Section 2000e-2(a)(1) prohibits termination because of sex; a male coworker’s dissimilar conduct did not establish discriminatory intent.

Kunkel v. Strawberry Park Resort Campground, Inc. · filed 2022-11-02(a)(1)

Kunkel herself was terminated after her third verbal argument, which also involved physical force. Accordingly, Mather’s one argument with campers cannot serve as the basis for establishing discriminatory intent.
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Section 2000e-2(a)(1) requires a plaintiff alleging sex discrimination to prove intentional discrimination because of sex.

Hammond-Beville v. Landis · filed 2022-11-15(a)(1)

To prevail on a Title VII claim, the plaintiff must ultimately prove that she suffered intentional sex-based discrimination.
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When a sex discrimination claim relies on a better-treated coworker, the complaint must allege facts showing that the coworker was similar in relevant respects.

MUNDY v. CITY OF PITTSBURGH · filed 2022-12-22(a)(1)

The Second Amended Complaint and the attached exhibits demonstrate that the identified male colleague presented different employment circumstances, which explain the difference in treatment. ... At this stage, even as a pro se plaintiff, Ms. Mundy has not pled sufficient facts regarding her Title VII Gender Discrimination claim.
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Section 2000e-2(a)(1) requires facts supporting a reasonable inference that an employee was fired because of sex.

Wasserman v. Office of Personnel Management · filed 2023-01-11(a)(1)

But there are no allegations in the complaint that support a reasonable inference that she was fired because of her sex.
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Section 2000e-2(a)(1) requires evidence from which a reasonable juror could infer intentional sex discrimination to sustain a disparate-treatment claim.

Hallman v. Thompson Tractor Company Inc · filed 2023-01-24(a)(1)

To succeed, Hallman must come forward with enough evidence for a reasonable juror to infer that Thompson Tractor intentionally discriminated against her because she is a woman. Lockheed, 644 F.3d at 1328. She has not done so.
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Section 2000e-2(a) requires a sex discrimination plaintiff to prove that sex caused the adverse employment action; the court describes this as but-for causation.

Karthauser v. Columbia 9-1-1 Communications District · filed 2023-01-24(a)

“Because of” means “by reason of” or “on account of.” This is sometimes referred to as “but-for causation.” This form of causation is shown whenever a particular outcome would not have happened “but for” the purported cause.
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Section 2000e-2(a)(1) requires facts plausibly showing that an employee was terminated because of her sex; an unsupported allegation that other pregnant employees received exemptions does not suffice.

D'Cunha v. Northwell Health Systems · filed 2023-02-28(a)(1)

D’Cunha does not plausibly allege that she was terminated “because of” her sex. § 2000e-2(a)(1) (emphasis added). The Complaint asserts, with no facts to support the charge, that “[u]pon information and belief, Northwell granted exemptions to several of its employees to accommodate their pregnancies.” Am. Compl. ¶ 45.
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A Title VII sex discrimination claim relying on a comparator must allege facts showing why that employee is similarly situated.

VEVERKA v. HUMAN SERVICES CENTER · filed 2023-03-14(a)(1)

Ms. Veverka’s Amended Complaint does not explain why the Court should consider the male CEO to be a similarly situated employee to Ms. Veverka.
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Section 2000e-2(a)(1) permits a sex discrimination claim to proceed when evidence of disparate treatment and pretext creates a genuine dispute about the reason for termination.

Logan v. Estes Environmental, Inc. · filed 2023-03-21(a)(1)

In sum, the totality of the evidence suggests that summary judgment on this claim is premature because the record casts doubt on the Estes’s proffered explanation for Logan’s termination and suggests that there is still a genuine dispute of material fact. Accordingly, Estes’s Motion for Summary Judgment on the gender discrimination claims under Title VII and Title 20 will be denied.
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Section 2000e-2(a) treats discrimination against women with young children as a form of sex discrimination, subject to the usual sex discrimination standards.

ZERFA v. ACOSTA, INC · filed 2023-03-30(a)

No special standards apply to sex-plus discrimination, which is just a form of sex discrimination.
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Section 2000e-2(a)(1) protects employees against discrimination based on their own sex; a benefit change applying equally to male and female employees does not support a sex discrimination claim.

Doe v. Avon Old Farms School, Inc · filed 2023-03-31(a)(1)

In contrast to Title IX, the sex-based protections of Title VII depend on the sex of the employee.
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Section 2000e-2(a)(1) prohibits sex-based discharge; a claim fails when the employer gives legitimate performance reasons and the employee cannot show they were a pretext for discrimination.

Pedraza-Melendez v. Ethicon Johnson & Johnson · filed 2023-03-31(a)(1)

There is no evidence that Ethicon’s decisions were driven by gender rather than by the legitimate business objectives.
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Section 2000e-2(a)(1) requires a plaintiff relying on coworkers as comparators to show they were similarly situated before their treatment can support an inference of sex discrimination.

VanHorn v. United States Postal Service · filed 2023-04-28(a)(1)

The defendant has it right. Plaintiff’s Title VII discrimination claim fails to “provide a basis for reliable comparison[.]” See id.
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Section 2000e-2(a)(1) allows a sex discrimination claim to reach a jury when evidence of pretext creates a genuine dispute about the employer’s stated reason for termination.

Six v. American Fidelity Corporation · filed 2023-04-28(a)(1)

Based on the evidence regarding American Fidelity’s investigation, discussed supra, and the additional evidence about Mr. A as a comparator, the Court finds Plaintiff has proffered sufficient evidence of pretext to warrant submission of this claim to a jury.
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Section 2000e-2(a)(1) requires a compensation discrimination claim to allege that a pay difference was due to race, color, religion, sex, or national origin.

Frazier-Barnes v. McDonough · filed 2023-05-02(a)(1)

While Frazier-Barnes alleged that she was paid less than other employees performing similar work, she did not allege that any compensation differences were due to her “race, color, religion, sex, or national origin,” as required to state a Title VII claim. See 42 U.S.C. § 2000e-2(a)(1).
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Section 2000e-2(a)(1) prohibits sex discrimination in employment; evidence of disparate treatment and inconsistent employer explanations can support a finding of pretext.

Wallace v. City of Jackson · filed 2023-05-18(a)(1)

Title VII prohibits employers from “discriminat[ing] against any individual with respect to his compensation, terms, conditions, or privileges of employment, because of such individual’s . . . sex.” 42 U.S.C. § 2000e-2(a)(1). ... But construing all reasonable inferences in the light most favorable to her, the Court finds sufficient evidence of disparate treatment—namely, in the seven-month difference between Wallace’s and Robinson’s demotion and the City’s inconsistent explanations in its reasons for firing her—and denies summary judgment on her sex-discrimination claims.
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Section 2000e-2(a)(1) prohibits sex discrimination in the terms, conditions, or privileges of employment.

Barton v. Warren County · filed 2023-06-13(a)(1)

Title VII prohibits discrimination with respect to the terms, conditions, or privileges of employment due to a person's sex. 42 U.S.C. § 2000e–2(a)(1).
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Section 2000e-2(a)(1) allows a sex discrimination claim to proceed when the alleged facts plausibly link an employee’s termination to sex, including an employer’s interviewing a female replacement before firing a male employee.

STARNES v. THREDUP INC · filed 2023-07-10(a)(1)

That ThredUP had interviewed a female candidate for Starnes’s position before terminating him (a fact the Court must accept as true) raises at least a plausible inference of sex-based discrimination at this stage of the litigation.
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Section 2000e-2(a)(1) bars sex discrimination in employment; when an employer gives a legitimate reason for its action, an employee relying on circumstantial evidence must show that reason was a pretext for discrimination.

Furr-Hoffman v. Precision Support Services · filed 2023-07-12(a)(1)

Because Plaintiff has “only created a weak issue of fact as to whether the defendant[s’] reason was untrue[,]” Gielda, 505 F. App’x at 556, she has not met her burden under McDonnell Douglas, and Defendants are thereby entitled to judgment on the claims of discrimination.
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Section 2000e-2(a)(1) permits a sex discrimination claim to proceed when different promotion standards for a woman and a male comparator plausibly support an inference of discrimination.

Raimondo v. Erie 2-Chautauqua-Cattaraugus BOCES · filed 2023-07-19(a)(1)

The contrast between Mr. Frazier’s promotion standard with hers plausibly states sex discrimination claim. This different evaluation raises an inference of discrimination to state sex discrimination claim.
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Section 2000e-2(a)(1) permits a sex-based compensation discrimination claim to proceed when alleged pay differences plausibly support an inference of discrimination.

Balchan v. City School District of New Rochelle · filed 2023-07-21(a)(1)

With respect to Plaintiff’s claim that she was underpaid as the District’s Medical Director because of her gender, the Court finds Plaintiff has pled sufficient facts to give rise to a plausible inference of discrimination based on gender.
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Section 2000e-2(a) requires a sex discrimination plaintiff to plausibly allege an adverse employment action taken because of sex.

Franovich v. Hanson · filed 2023-08-17(a)

To state a claim for sex discrimination under Title VII, a plaintiff must plausibly plead that her employer took an adverse action against her because of her sex. See 42 U.S.C. § 2000e- 2(a).
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Section 2000e-2(a)(1) allows a sex-discrimination claim to proceed when evidence of pretext creates a genuine factual dispute about the employer’s reason for an adverse action.

Esperance v. Vilsack · filed 2023-08-23(a)(1)

However, the Court also concludes that the inconsistent reasons given for removing Plaintiff from the Ranger position, the differing testimony about whether Mr. Ferebee had input into the reassignment, Plaintiff's assertion that she was not counseled about the performance issues listed in the January 31 letter, and Plaintiff's positive performance evaluations, are sufficient to create a genuine issue of fact whether Defendant’s reasons for reassigning Plaintiff are pretextual.
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More favorable treatment of a similarly situated male employee can support an inference of sex discrimination under § 2000e-2(a)(1).

Bussey v. Sun West Mortgage Company, Inc. · filed 2023-08-31(a)(1)

The Court finds that plaintiffs have presented evidence to support that their terminations took place under circumstances that give rise to an inference of discrimination because Fleege, a similarly situated employee, was treated more favorably than plaintiffs.
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Section 2000e-2(a)(1) requires evidence from which a reasonable factfinder could conclude that an employee’s sex caused the challenged discipline or termination.

Stump v. Franciscan Alliance, Inc · filed 2023-09-01(a)(1)

Considering the evidence as a whole, no reasonable fact-finder could find that defendant discriminated against plaintiff on the basis of his sex.
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A sex discrimination claim under Section 2000e-2(a)(1) fails when the employee provides no argument connecting her termination to sex.

Oliver v. Amazon.com Services LLC · filed 2023-09-13(a)(1)

In this case, while Oliver makes passing reference in her brief to her being terminated due to her sex (Docket # 65 at 17, 22), her brief contains no argument connecting her termination to her alleged sex discrimination.
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A sex discrimination claim under § 2000e-2(a)(1) fails when the employee offers no evidence that she was qualified for the job or that the employer’s stated reason for firing her was pretextual.

Spencer v. Kane County · filed 2023-09-28(a)(1)

Plaintiff has failed to show a genuine issue of material fact as to whether she was qualified for her employment position or that the employer’s proffered reason for terminating Plaintiff was pretextual. The Court will, accordingly, dismiss Plaintiffs discrimination claim.
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Section 2000e-2(a)(1) prohibits sex-based discharge; when an employer offers a legitimate nondiscriminatory reason, the employee must raise a genuine factual dispute that the reason is pretextual.

Jenkins v. CACI Inc - Federal · filed 2023-10-23(a)(1)

Upon review of the record, the court concludes that Myer has failed to proffer evidence sufficient to raise a genuine issue of material fact that CACI’s proffered legitimate nondiscriminatory reason for its termination decision is pretextual or unworthy of belief for gender discrimination. The court therefore concludes that CACI is entitled to summary judgment on Myer’s Title VII and OADA gender discrimination claims.
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A sex-discrimination claim fails when the evidence would not allow a reasonable jury to find that the employer acted because of the employee’s sex.

Schweyen v. University of Montana-Missoula · filed 2023-10-31(a)(1)

Based on the undisputed evidence in the record, a reasonable jury could not conclude by a preponderance of the evidence that the University terminated Schweyen’s employment because of her gender.
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Section 2000e-2(a)(1) prohibits sex discrimination in employment conditions, and a claim can proceed when the evidence raises a genuine dispute about discriminatory treatment.

Staton v. City and County of Butte-Silver Bow · filed 2023-11-09(a)(1)

A genuine issue of material fact exists as to whether BSB discriminated against Staton in the conditions and privileges of her employment based on her sex/gender. The Court will deny BSB’s motion for summary judgment on Count I of Staton’s Amended Complaint.
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Section 2000e-2(a)(1) requires evidence of discriminatory motive to establish a sex-based disparate-treatment claim; speculation does not suffice.

Merriweather v. Kijakazi · filed 2023-12-01(a)(1)

For these reasons, Ms. Merriweather fails to establish the discriminatory-motive element of a prima-facie disparate-treatment claim based on her gender, and the court grants the SSA’s motion for summary judgment on this count.
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Section 2000e-2(a)(1) requires a sex discrimination plaintiff to show that an adverse employment action was based on sex.

Dennison v. Indiana University of Pennsylvania · filed 2023-12-12(a)(1)

On these facts, no reasonable factfinder could find sex discrimination was the motivation for the employment actions about which Dennison complains. Thus, the District Court did not err in granting summary judgment on the Title VII and Title IX sex discrimination claims.
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Section 2000e-2(a)(1) requires facts plausibly connecting an adverse employment action to the employee’s sex.

Clark v. Sampson Regional Medical Center, Incorporated · filed 2023-12-14(a)(1)

Accepting for purposes of the instant analysis that these constitute adverse employment actions, plaintiff fails to allege sufficient facts to give rise to a plausible inference that defendant took these actions “because of her . . . sex.” 42 U.S.C. § 2000e–2(a)(1).
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Section 2000e-2(a) permits a sex discrimination claim to proceed when the complaint plausibly alleges that women received more difficult assignments and less favorable working conditions than men.

STEVENSON v. UNITED ANIMAL HEALTH, INC. · filed 2023-12-29(a)

The Court concludes that the Amended Complaint sufficiently pleads a sex discrimination claim against UAH and the motion to dismiss is denied as to the Title VII sex discrimination claim.
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Section 2000e-2(a)(1) requires plausible facts showing that an employer acted against an employee because of sex; replacement by a woman alone is insufficient.

Hill v. Meharry Medical College · filed 2024-01-02(a)(1)

Plaintiff’s assertion that sex discrimination occurred because his replacement was a woman is merely a “formulaic recitation” of the necessary elements and is no more than conclusory.
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A sex discrimination claim under § 2000e-2(a)(1) can survive summary judgment when evidence permits a jury to reject the employer’s stated reason for termination as pretextual.

Feldwisch v. Wormuth · filed 2024-01-29(a)(1)

But Plaintiff has produced sufficient evidence to allow a jury to reject the explanation as pretextual. As such, a reasonable jury could find that Plaintiff’s termination was improperly motivated by discriminatory animus.
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For a sex-discrimination claim based on indirect evidence, Section 2000e-2(a) requires proof that the employer’s stated reason was pretextual and that sex motivated the decision.

Colon-Gonzalez v. Commonwealth of Puerto Rico · filed 2024-02-22(a)

In sum, Plaintiff has failed to rebut Defendants’ proffered reason for the dismissal, that Plaintiff committed in ultra vires actions contrary to CEE’s regulations and did not establish that the actions against him were undertaken on the basis of sex. Therefore, Plaintiff’s claim under Title VII fails.
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Section 2000e-2(a)(1) requires evidence that an employee would have kept his job if his sex had been different and everything else had remained the same.

Moss v. Sage Bluff Health & Rehab Center, LLC · filed 2024-02-27(a)(1)

Thus, in Moss’ case the “sole question that matters” is whether a reasonable juror could conclude that Moss would have kept his job if he had a different sex, and everything else had remained the same.
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Section 2000e-2(a)(1) prohibits race discrimination in compensation; a pay cut can be an adverse employment action even if the employer later repays the lost wages.

Horace v. ARIA · filed 2024-03-19(a)(1)

To the extent the district court concluded Horace failed to allege an adverse employment action, both Title VII and the FCRA prohibit discrimination with respect to compensation. See 42 U.S.C. § 2000e-2(a)(1); Fla. Stat. § 760.10(1)(a). ... That Horace alleged that ARIA eventually repaid his lost wages after he resigned and hired a lawyer does not mean he did not suffer an adverse employment action.
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When an employer offers a legitimate nondiscriminatory reason for termination, a sex-discrimination plaintiff must provide evidence from which a factfinder could reasonably infer pretext.

Norris v. NLMK Pennsylvania LLC · filed 2024-03-21(a)(1)

Thus, the District Court did not err by granting summary judgment on the sex-discrimination claim because Norris failed to adduce evidence of pretext.
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Section 2000e-2 permits a cisgender employee to plead sex discrimination by alleging that an employer favored similarly situated transgender employees.

MCCREARY v. ADULT WORLD, INC. · filed 2024-04-04(a)(2)

Otherwise stated, allegations that an employer impermissibly favors transgender employees over both similarly situated cisgender males and similarly situated cisgender females satisfies the “inference of discrimination” requirement.
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Section 2000e-2(a) prohibits sex discrimination in compensation; a claim fails when the evidence does not support an inference of discrimination and the pay difference is explained by merit.

Vrabec v. Geisinger Clinic · filed 2024-04-04(a)

Whether viewed as a failure to show that the circumstances of her disparate compensation gives rise to an inference of discrimination or as Geisinger’s success in showing that the salary differences were based upon merit, Vrabec’s Title VII, ADEA, and PHRA discrimination claims relating to her compensation under the 2016 policy fail for the same reasons as her analogous EPA claims.
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Section 2000e-2(a) prohibits employers from discriminating in compensation or employment conditions because of sex.

Hawthorne v. Birdville Independent School District · filed 2024-04-12(a)

Title VII prohibits employers from discriminating “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).
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Section 2000e-2(a) allows a sex discrimination claim over a lower salary offer to reach a jury when evidence could show that sex motivated the offer.

United States v. State of Wisconsin, Department of Military Affairs · filed 2024-05-09(a)

Because plaintiff has presented evidence from which a reasonable jury could conclude that WDMA’s decision to offer Hartness a lower salary was motivated by her sex, the court must deny defendant’s motion.
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A sex discrimination claim requires facts suggesting that sex or gender was a factor in the adverse employment action.

Brice v. Bethany Retirement Living · filed 2024-05-09(a)(1)

Consequently, she has failed to assert a claim of sex discrimination for which relief may be granted.
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Section 2000e-2(a)(1) requires proof of intentional discrimination for a sex-based wage discrimination claim.

Hollis v. Morgan State University · filed 2024-05-10(a)(1)

To prevail on a sex-based wage discrimination claim under Title VII, a plaintiff must also prove intentional discrimination.
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Section 2000e-2 permits a sex discrimination claim to proceed to trial when evidence creates a genuine dispute about whether comparable male employees received more favorable treatment for similar misconduct.

Craig v. McFadden · filed 2024-05-15

The record in this case presents genuine disputes of material facts, particularly as it relates to whether male employees were treated differently than Plaintiff for similar misconduct.
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Section 2000e-2(a)(1) prohibits an employer from terminating an employee because of sex; a discrimination claim cannot proceed to trial without evidence from which a reasonable jury could find that sex caused the termination.

Anderson v. Mott Street · filed 2024-06-13(a)(1)

Viewing the evidence as a whole, no reasonable jury could find that Anderson’s termination was an act of sex discrimination.
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Section 2000e-2(a) prohibits covered employers from discriminating in compensation because of sex.

Gleason v. Filter Holdings, LLC · filed 2024-06-14(a)

Under Title VII, it is unlawful for a covered employer to discriminate against any individual based on sex.
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Section 2000e-2(a)(1) requires a claim of discriminatory adverse employment action to plausibly link the action to the employee’s sex.

Swank v. Regional University System of the Oklahoma Board of Regents · filed 2024-07-12(a)(1)

Thus, Plaintiff does not allege that her sex was a motivating factor in any adverse employment action.
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A sex discrimination claim requires facts supporting an inference of intentional discrimination; the employee’s and supervisors’ sexes alone do not suffice.

Ashbourne v. Hansberry · filed 2024-07-18(a)(1)

Because Ms. Ashbourne offers no other facts that could establish a viable sex discrimination clam, the court will dismiss any Title VII sex discrimination claim.
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Section 2000e-2(a)(1) prohibits an employer from discriminating against an employee because of sex.

Haner v. County of Niagara, New York · filed 2024-07-25(a)(1)

Title VII prohibits an employer from failing to hire or discharging “any individual, or otherwise . . . discriminat[ing] against any individual . . . because of such individual’s race, color, religion, sex, or national origin.” 42 U.S.C. § 2000e–2(a)(1).
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Section 2000e-2(a)(1) prohibits sex discrimination in employment, but a termination claim fails when the evidence cannot support a finding that gender motivated the decision.

Ontiveros v. Exxon Mobil Fuels and Lubricants Company · filed 2024-08-14(a)(1)

As such, no reasonable jury could conclude that Defendant terminated Plaintiff because of her gender.
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A Title VII sex discrimination claim may proceed when the alleged facts support an inference of gender bias.

Day v. Global Logistics Solutions, LLC · filed 2024-08-23(a)(1)

They are sufficient to raise an inference of discrimination based both upon gender and age. The defendant’s motion to dismiss the plaintiff's claim of age and gender discrimination will be denied.
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Section 2000e-2(a)(1) prohibits sex discrimination in employment; when an employer gives a legitimate reason for termination, the employee must show that reason is pretextual.

Peck v. United Parcel Service, Inc. · filed 2024-12-10(a)(1)

Even if Peck made out her prima facie case, she has not demonstrated that UPS’s explanation for her termination is pretextual.
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Section 2000e-2(a)(1) requires an employee using indirect proof of sex discrimination to show that the employer’s stated reason for termination was pretext for discrimination.

Jones v. Ohio State Univ. Wexner Med. Ctr. · filed 2025-01-29(a)(1)

Plaintiff did not meet her reciprocal burden of coming forward with evidence that Defendant’s proffered reasons for terminating her employment were pretextual, and that discrimination on the basis of age or sex was the real reason.
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A sex discrimination claim based on disparate treatment does not require severe or pervasive conduct interfering with the employee’s work.

Coleman v. Telles · filed 2025-02-05(a)(1)

None of these elements requires the plaintiffs to show severe and pervasive conduct interfering with their jobs.
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Section 2000e-2(a)(1) prohibits sex-based employment discrimination, not every conversation about sex at a work-related event.

Workman v. LHC Group, Inc. · filed 2025-02-12(a)(1)

Title VII does not prohibit all conversation about sex in work-related settings; it prohibits discrimination “because of . . . sex.”
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Section 2000e-2(a)(1) requires facts supporting a reasonable inference that an adverse employment action was motivated by sex discrimination.

Williams-Johnson v. Paris Foods Corporation · filed 2025-03-10(a)(1)

More generally, the Complaint offers no facts to support an inference that Plaintiff’s employment was terminated on account of her sex.
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A sex discrimination claim can survive summary judgment when a jury could find that the employer’s stated reason for firing the employee was a pretext for discrimination.

Kozak v. Office Depot, Inc. · filed 2025-03-25(a)(1)

And if the jury believes Kozak about what happened but discredits Bryan’s claims about the thoroughness of her investigation, it could reasonably conclude that Kozak was fired not because she falsely accused her supervisor but because she was a woman who accused her male boss of misconduct and sexual harassment.
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A Title VII sex-plus discrimination claim requires unfavorable treatment compared with an employee who shares the additional characteristic.

McKeown v. Paycom Payroll LLC · filed 2025-03-31(a)

Such a claim could be cognizable under Title VII but requires a showing of “unfavorable treatment relative to an employee who also shares the ‘plus-’ characteristic.”29 Plaintiff raised no allegations that Paycom treated similarly aged, unmarried, childfree men differently.
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Section 2000e-2(a) permits a sex discrimination claim to proceed when alleged adverse employment actions and more favorable treatment of male coworkers support an inference of discrimination.

Schouker v. Swarm Industries, Inc. dba Polyswarm · filed 2025-04-03(a)

From these allegations, it is reasonable to infer Plaintiff experienced the adverse employment actions described above because of her gender. ... So, the Court DENIES Defendants’ motion to dismiss Counts One and Two.
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Section 2000e-2(a)(1) requires evidence that an employee’s sex caused an adverse employment action; an employer’s stated reason is pretextual only if it conceals discrimination.

Napier v. Orchard School Foundation · filed 2025-05-16(a)(1)

At the end of that review, our con- clusion is that no reasonable factfinder could find that Napier lost his job based on his sex.
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A sex discrimination claim using comparators requires employees who are similarly situated in all material respects.

McCullers v. Koch Foods of Alabama LLC · filed 2025-05-19(a)(1)

Under Title VII, a comparator is only proper when he or she is “similarly situated in all material respects.” Lewis, 918 F.3d at 1219.
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Section 2000e-2(a) prohibits discharge because of sex; a claimant must show facts connecting sex to the discharge.

Waters v. J.B. Hunt Transport Services, Inc. · filed 2025-05-30(a)

Regarding his termination, Waters has failed to set out specific facts showing any connection between his gender and his termination.
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Section 2000e-2(a)(1) prohibits firing an employee because of sex; a discrimination claim requires evidence from which a reasonable jury could infer that sex caused the firing.

Mitchell v. Exxon Mobil Corporation · filed 2025-07-25(a)(1)

We agree with the district court that no reasonable jury could find that ExxonMobil subjected Mitchell to sex discrimination.
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Section 2000e-2(a) requires a plaintiff who bases a compensation discrimination claim on coworkers’ pay to allege facts showing that the coworkers are similarly situated in all material respects.

Gildyard v. Children's Network of Southwest Florida, L.L.C. · filed 2025-07-28(a)

But he added no factual allegations about whether Rossi and Kerr are similarly situated in all material respects. He still “alleges essentially nothing about his comparator’s job functions.” (Doc. 32 at 13–14). Because his compensation discrimination claim is based only on his inadequate comparator allegations, he fails to state a claim.
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A Title VII sex discrimination plaintiff relying on comparators must show they are similarly situated in all material respects, though they need not be identical.

Gallimore v. City of Opa-Locka, Florida · filed 2025-08-06(a)(1)

The comparators need not be “identical” to the plaintiff but for their gender, but they must be “similarly situated in all material respects.”
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A Title VII sex discrimination claim can survive dismissal when allegations about a supervisor’s questioning of an employee’s sexuality support an inference of discrimination, even without a similarly situated comparator.

Williams-Johnson v. Paris Foods Corporation · filed 2025-08-07(a)(1)

To the extent Plaintiff alleges sex discrimination based on her perceived sexual orientation, the Amended Complaint, read favorably, states facts showing unlawful discrimination based on the totality of the circumstances sufficient to overcome the need to demonstrate a similarly situated comparator.
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Section 2000e-2(a)(1) requires sex to be a cause of alleged sex-plus discrimination; discrimination based solely on an additional characteristic does not state a claim.

Fisher v. Valley Stream Central High School District · filed 2025-08-27(a)(1)

In other words, a plaintiff alleging discrimination solely on the basis of a “plus” characteristic, irrespective of that plaintiff’s sex, has not stated a claim for sex plus discrimination because such discrimination would not be on the basis of membership in a protected class enumerated in Title VII.
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A discharge claim under § 2000e-2(a) requires evidence that sex mattered to the employer’s decision.

Howard v. Cherokee Health Systems · filed 2025-09-02(a)

And Howard failed to produce any evidence suggesting that his (or Khatri’s) sex mattered to his termination.
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A sex discrimination claim under § 2000e-2(a)(1) fails when the alleged comparators were not treated more favorably in any relevant respect.

Davis v. Staples Contract and Commercial, Inc. · filed 2025-09-12(a)(1)

Assuming arguendo that these women are true comparators, Plaintiff’s prima facie case fails at the outset because he cannot show that they were treated differently in any relevant respect.
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Sex discrimination under Section 2000e-2(a)(1) may be proved through circumstantial evidence.

Casillas-Guardiola v. Bayer Puerto Rico, Inc. · filed 2025-09-30(a)(1)

Accordingly, sex discrimination may be proven through circumstantial evidence.
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A sex discrimination claim may proceed when a jury could find that a biased supervisor influenced the decision to fire an employee.

Perras · filed 2025-10-27(a)

Because a reasonable jury could conclude that McKinney influenced Perras’s termination, GCAD bears the burden to prove that it would have taken the same action regardless of McKinney’s recommendation. Given that GCAD promoted Perras twice in the same year that Perras had 21 tardies, one write-up, and two suspensions for tardiness and insubordination, a reasonable jury could conclude that Watson would not have fired Perras but for McKinney’s recommendation. Thus, GCAD has not shown that it is entitled to summary judgment on Perras’s Title VII sex discrimination claim.
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Section 2000e-2(a) prohibits sex discrimination regardless of whether an employee belongs to a disfavored group.

Reynolds · filed 2025-10-28(a)

Title VII does not limit its protections to disfavored groups or classes of people. ... Rather, it prohibits certain categories of discrimination, such as discrimination on the basis of race or sex.
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Section 2000e-2(a)(1) prohibits sex discrimination in promotion; evidence that an employer also promoted men can undercut a claim that it favors women.

PIROLLI · filed 2025-10-29(a)(1)

We infer the Authority promoted Barry Kavitsky, a man, into the director of finance position over Mr. McGuire at some unidentified time—undercutting Mr. Pirolli’s argument the Authority promotes less qualified women over more qualified men—and former Director Rodriguez believed the Authority should have promoted Mr. McGuire rather than a woman once Mr. Kavitsky left the position.
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Section 2000e-2(a)(1) requires facts supporting a plausible claim that an adverse employment action occurred because of sex.

Lykes · filed 2025-11-04(a)(1)

Broadly construing the complaint, the Court finds no allegations to support a plausible claim that Plaintiff was discriminated against because of her gender or age.
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For a discriminatory compensation claim, an employee must offer evidence that the employer’s stated nondiscriminatory reason for its salary decision was pretextual.

Steele v. Chopra · filed 2025-12-19(a)(1)

The Agency’s response to all three claims is the same: It determined Steele’s initial salary based on her prior work experience, not her race or sex. Because Steele has not shown that this explanation is pretextual or otherwise subject to reasonable dispute, the Agency is entitled to summary judgment on all three claims.
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A plaintiff alleging race discrimination in compensation must show that higher-paid comparators are similarly situated in all material respects; job titles, race, and pay alone do not establish that comparison.

Coleman v. Morris-Shea Bridge Company, Inc. · filed 2026-01-20(a)(1)

Without any evidence beyond formal job titles, race, and pay, Larry and Freddie failed to establish com- parators that were similarly situated in all material respects.
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Section 2000e-2(a)(1) prohibits discharge because of sex; a complaint survives dismissal when its allegations plausibly suggest sex discrimination motivated the termination.

Marshall · filed 2026-01-22(a)(1)

Because Plaintiff asserts that a clerical error was the sole reason for her termination, the Court finds it plausible that sex discrimination was the true reason for this adverse employment action.
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Section 2000e-2(a)(1) prohibits discrimination in compensation; allegations of lower pay than similarly situated coworkers can support a Title VII discrimination claim.

Shah · filed 2026-01-28(a)(1)

Discrimination “with respect to compensation” is, of course, prohibited by Title VII.
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State and local laws

Section 2000e-2(a)(2) bars sex-based restrictions on employees’ opportunities; a municipal ban on opposite-sex massages that requires such restrictions conflicts with Title VII.

Cianciolo v. Members of City Council, Knoxville, Tenn. · filed 1974-01-16(a)(2)

In summary, we hold that: (1) Sections 2 and 3 of Ordinance No. 5645 of the City of Knoxville, Tennessee, are in conflict with the equal employment opportunities provisions of the Civil Rights Act of 1964 and are, therefore, superceded by such federal provisions and, by virtue of the supremacy clause, are void and of no force and effect.
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Section 2000e-2 does not apply to bathhouse operators’ challenge to a city ordinance regulating massage operators.

Garaci v. City of Memphis · filed 1974-04-19(a)(2)

The Court does not consider that the intendment of the Title VII provision (42 U.S.C. § 2000e-2) was to apply to this type of situation, and it is not clear to the Court on its face that Memphis Charter provision 438.7(2) is invalid on the basis of this federal statute.
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Section 2000e-2(a) does not bar an ordinance prohibiting opposite-sex massages merely because the ordinance reduces employment opportunities for female massagists.

Wigginess Inc. v. Fruchtman · filed 1979-12-28(a)

Plaintiffs argue that because their clientele is almost exclusively male the ordinance will force them to “refuse to hire [and] to discharge” female massagists, in violation of section 703(a)(1). The ordinance, however, requires plaintiffs neither to discharge nor to refuse to hire anyone. It only makes it unlawful to operate certain establishments. The result of plaintiffs’ ceasing an unlawful operation may be to curtail employment opportunities for female massagists, but this surely does not preclude the city’s exercising its police power to prohibit practices it finds harmful to the public’s health, safety, welfare or morals.
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Job classifications and training programs

Section 2000e-2(d) prohibits race discrimination in access to training, retraining, and on-the-job training programs.

Thompson v. Town of Front Royal · filed 2000-10-03(d)

Also, the court finds it relevant to this matter that 42 U.S.C. § 2000e-2(d) makes it an unlawful employment practice to discriminate on the basis of race for entry into any training, retraining, or on-the-job training programs. Accordingly, the Magistrate’s recommendation with respect to this issue is accepted and the defendant’s motion for summary judgment on the Title VII claims based on the argument that the bases for the claims are not actionable, shall be demed.
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Section 2000e-2(a)(2) prohibits sex-based job classifications that limit an employee’s opportunities or maximum pay.

Martha ARMSTRONG, Appellant, v. INDEX JOURNAL COMPANY, Appellee · filed 1981-04-28(a)(2)

The Journal's segregation of jobs by sex adversely affected her status as an employee and deprived her of the opportunity to reach the maximum salary payable to salesmen.
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Section 2000e-2(d) prohibits discriminatory training; a prima facie claim requires different treatment and an employer’s knowledge of, and failure to remedy, the discrimination.

Gunvant D. SHAH, Appellant, v. MT. ZION HOSPITAL AND MEDICAL CENTER, a Non-Profit Corporation, Appellee · filed 1981-03-30(d)

To establish a prima facie case of discriminatory training, Shah was required to show that he was treated differently from other employees, and that Mt. Zion was aware of the discrimination and failed to remedy it.
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Section 2000e-2 permits a genuine training classification that is open to women and bases advancement on ability.

Cupples v. Transport Insurance Company · filed 1974-01-28(a)

Also Transport showed that the underwriter trainee was a valid classification not set up to discriminate against women and not having that effect. The employees hired as underwriter trainees were informed when hired that that was their position, the classification was set out in writing, the trainees were supervised and evaluated in their training, advancement depended solely on their ability to become effective underwriters and females have not been excluded from the program.
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Section 2000e-2(a)(2) prohibits sex-based employment classifications that tend to deprive employees of opportunities, including promotion opportunities.

Prescod v. Unemployment Insurance Appeals Board · filed 1976-04-05(a)(2)

Title VII also makes it unlawful to limit, segregate or classify employees in any way that would tend to deprive an employee of employment opportunities on the basis of sex (42 U.S.C. § 2000e-2(a)(2)). ... The fact that she was rehired in a position at the lower Grade 4 and consequently did not have the same promotional opportunities she had before her maternity leave at Grade 5, established a prima facie violation of the guidelines.
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Section 2000e-2(d) prohibits sex discrimination in the administration of employment training programs.

Batyko v. Pennsylvania Liquor Control Board · filed 1978-01-18(d)

Title VII of the Civil Rights Act expressly prohibits discrimination on the basis of sex in the administration of training programs. 42 U.S.C. § 2000e-2(d). ... In Westmoreland County, the defendant provided no training for males which was not provided for females.
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Section 2000e-2(a) prohibits restricting women to lower-paying jobs and applying unequal shift-transfer and seniority policies because of sex.

Jane MITCHELL, Plaintiff-Appellee, v. MID-CONTINENT SPRING COMPANY OF KENTUCKY, Defendant-Appellant · filed 1978-11-09(a)

The unlawful restriction of female applicants and employees to its lowest-paying positions, the Company’s differential shift-transfer policy and its consequent maintenance of separate seniority lists constitute violations of Title VII. These policies placed burdens on females that males were not required to suffer.
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Section 2000e-2(a)(2) permits separate employee classifications when women and similarly situated men are treated alike.

Brenda S. Griffin and Margaret Waimon v. Board of Regents of Regency Universities, a Public Corporation · filed 1986-06-18(a)(2)

We agree with the district court that the dual classification system at ISU is not illegal, however, when women are not treated differently from similarly situated men.
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Section 2000e-2(a)(1) bars an employer from denying job training because of an employee’s race or national origin.

Seo v. Anheuser-Busch, Inc. · filed 1990-08-15(a)(1)

Seo appears not to have received as much training as some employees, but given the fact of lay-offs, his low seniority, the fact that the company did not have a general training program and the feeling of some of the supervisors that Seo lacked the necessary skills and was accident prone, the Court finds that the plaintiff did not establish that failure to train him in the jobs which he desired to have or that he felt had greater status was caused by his race or national origin.
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An employee alleging sex discrimination in the denial of training must show she was entitled to the training benefit and that employees outside her protected class received it.

Keegan v. Dalton · filed 1995-09-21(a)(1)

Tailored to the context and procedural posture of this case, the prima facie ease requires a genuine issue of material fact that (1) Keegan is a member of a class protected by Title VII; (2) she was entitled to the desired benefit; (3) the Department denied her this benefit; and (4) unprotected employees were granted the benefit.
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Section 2000e-2(d) forbids discrimination in training programs; a program that awards applicants bonus points without providing education does not qualify as a training program.

Yeager v. General Motors Corp. · filed 1999-06-30(d)

It is true that discrimination with respect to training programs is forbidden under Title VII, 42 U.S.C. § 2000e-2(d) (1994). Thus, if there is an exclusion from available seats in a training program, that would establish standing under Bakke. Two factors lead this Court to reject applying Bakke to the instant case. First, PATP is not a training program.
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Notes 3151–3300 of 12,593, oldest cases first.

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