Whether a hostile work environment claim under Title VII requires proof of 'severe or pervasive' harassment when Muldrow suggests only 'some injury' is necessary

Title VII of the Civil Rights Act of 1964 prohibits discrimination affecting the “terms, con ditions, or privileges of employment” because of an individual’s “race, color, religion, sex, or national origin.” 42 U.S.C. § 2000e -2(a)(1) . This Court recently held in Muldrow v. City of St. Louis, Missouri, et al. , 601 U.S. ___ (2024) , that, Title VII plaintiffs alleging discriminatory trans fer need only show “some injury” to their terms or conditions of employment rather than meeting a “significant harm” threshold. While Muldrow rejected judicially -created heightened harm requirements in the transfer context, courts continue to require that workplace harass ment be “severe or per vasive” to constitute an actionable hostile work environ ment claim under Title VII . The question pre sented is : Whether a hostile work environment claim under 42 U.S.C. § 2000e -2(a)(1) requires proof that harass ment was “severe or pervasive” —a standard not found in the text —when this court’s recent decision in Muldrow v. City of St. Louis holds that this provision requires only that discrimination cause “some injury” to the terms, conditions, or privileges of employment.