Where Muldrow Ends: Tenth Circuit Refuses to Extend Relaxed Harm Standard to Hostile Work Environment Claims

The Supreme Court of the United States lowered the bar for establishing a discrimination claim under Title VII of the Civil Rights Act of 1964 in its 2024 opinion, Muldrow v. City of St. Louis, holding that an employee need only show “some” harm—not a significant change—in working conditions. According to the U.S. Court of Appeals for the Tenth Circuit, however, Muldrow’s relaxed standard does not apply to hostile work environment harassment claims under Title VII.