Jillian Ambrose
Overview
Jillian provides pragmatic advice and strategic support to employers navigating challenges big and small. Whether supporting clients in grappling with emerging issues like the evolving DEI landscape, investigating high-profile harassment allegations, or defending complex claims in federal court, Jillian brings a collaborate and practical approach to challenging situations.
Career & Education
- Smith College, B.A., cum laude, government, 2007
- University of Michigan Law School, J.D., cum laude, 2013
- District of Columbia
- Maryland
- U.S. Court of Appeals for the D.C. Circuit
- U.S. District Court for the Eastern District of Michigan
Jillian's Insights
Client Alert | 4 min read | 04.24.24
Muldrow Case Recalibrates Title VII “Significant Harm” Standard
On April 17, 2023, the Supreme Court handed down a unanimous decision in Muldrow v. City of St. Louis, Missouri, No. 22-193, holding that transferees alleging discrimination under Title VII of the Civil Rights Act of 1964 need only show that a transfer caused harm with respect to an identifiable term or condition of employment. The Court’s decision upends decades of lower court precedent applying a “significant harm” standard to Title VII discrimination cases. As a result, plaintiffs claiming discrimination under Title VII will likely more easily advance beyond motions to dismiss or motions for summary judgment. In the wake of the Court’s decisions in Students for Fair Admissions, Inc. v. President and Fellows of Harvard College (6-2), No. 20-1199, and Students for Fair Admissions, Inc. v. Univ. of North Carolina (6-3), No. 21-707 (June 29, 2023), Muldrow will also likely continue to reshape how employers conceive of, implement, and communicate workplace Diversity, Equity and Inclusion (“DEI”) efforts. The decision may be used by future plaintiffs in “reverse” discrimination actions to challenge DEI or affinity programs that provide non-economic benefits to some – but not all – employees. For example, DEI programs focused on mentoring or access to leadership open only to members of a certain protected class could be challenged under Muldrow by an employee positing that exclusion from such programs clears this new, lower standard of harm.
Client Alert | 1 min read | 04.11.24
U.S. Chamber Submits Comments on the FAR Council’s Proposed Rule Regarding Pay Transparency
Client Alert | 12 min read | 03.04.24
Insights
Jillian's Insights
Client Alert | 4 min read | 04.24.24
Muldrow Case Recalibrates Title VII “Significant Harm” Standard
On April 17, 2023, the Supreme Court handed down a unanimous decision in Muldrow v. City of St. Louis, Missouri, No. 22-193, holding that transferees alleging discrimination under Title VII of the Civil Rights Act of 1964 need only show that a transfer caused harm with respect to an identifiable term or condition of employment. The Court’s decision upends decades of lower court precedent applying a “significant harm” standard to Title VII discrimination cases. As a result, plaintiffs claiming discrimination under Title VII will likely more easily advance beyond motions to dismiss or motions for summary judgment. In the wake of the Court’s decisions in Students for Fair Admissions, Inc. v. President and Fellows of Harvard College (6-2), No. 20-1199, and Students for Fair Admissions, Inc. v. Univ. of North Carolina (6-3), No. 21-707 (June 29, 2023), Muldrow will also likely continue to reshape how employers conceive of, implement, and communicate workplace Diversity, Equity and Inclusion (“DEI”) efforts. The decision may be used by future plaintiffs in “reverse” discrimination actions to challenge DEI or affinity programs that provide non-economic benefits to some – but not all – employees. For example, DEI programs focused on mentoring or access to leadership open only to members of a certain protected class could be challenged under Muldrow by an employee positing that exclusion from such programs clears this new, lower standard of harm.
Client Alert | 1 min read | 04.11.24
U.S. Chamber Submits Comments on the FAR Council’s Proposed Rule Regarding Pay Transparency
Client Alert | 12 min read | 03.04.24
