Amazon recently lost an attempt to dismiss a lawsuit filed by Keesha Anderson, a Black event producer, who alleges discriminatory treatment by the company. U.S. District Judge Arun Subramanian ruled against Amazon’s dismissal bid, marking one of the first applications of the April Supreme Court decision in Muldrow v. St. Louis. This ruling establishes that workers do not need to show concrete injuries such as pay cuts or demotions to pursue discrimination claims under federal law.
Case Background
Keesha Anderson worked as an event specialist for Amazon Music from 2019 to 2022. She claims that she was marginalized by her supervisors, placed on a performance improvement plan (PIP), and given limited job duties that hindered her career progression. According to Anderson, these actions were racially motivated and created a hostile work environment that ultimately forced her to resign and led to her filing a lawsuit against Amazon.
Court’s Ruling
Judge Subramanian’s decision referenced the Muldrow ruling, emphasizing that adverse actions for discrimination claims now include any employment action that negatively impacts working conditions. This broadened interpretation under Title VII of the Civil Rights Act of 1964 was applied to Anderson’s case under Section 1981 of the Civil Rights Act of 1866, as both laws use similar language and are generally interpreted in tandem.
Amazon argued that the actions Anderson described, including her placement on a PIP and the limitation of her job duties, did not constitute adverse actions. However, Judge Subramanian rejected this claim, stating that these actions could indeed form the basis of a discrimination claim in light of the Supreme Court’s recent decision.
Legal Precedents
Subramanian’s ruling did not address previous cases where courts had ruled that PIP’s could not form the basis of discrimination claims. Instead, he focused on the broader implications of the Muldrow decision, which expanded the definition of adverse actions under Title VII.
In his ruling, Subramanian noted that Anderson’s treatment adversely affected her employment conditions by assigning her more burdensome tasks, tarnishing her record, and limiting her career prospects. These factors collectively supported her claim under Section 1981.
Next Steps
The case will now proceed, with both parties preparing for further legal battles.
If you need assistance to further understand how this ruling potentially impacts your business, please contact us at info@mnklawyers.com.
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