What employees must show to prove Title VII claims against federal employers

Claims filed under Title VII of the Civil Rights Act of 1964 require employees to demonstrate several specific elements to prove race discrimination, retaliation, hostile work environment, or constructive discharge by a federal employer. To be successful, they must show an adverse employment action, intolerable working conditions, or harassment affecting their terms, conditions, or privileges of employment, according to a recent ruling from the U.S. 8th Circuit Court of Appeals (which covers Missouri employers).

Facts

Monica Watson began working for the Kansas City Veterans Affairs Medical Center (VA) as a medical records technician coder in 2006. During her employment, the VA received new guidance on the maximum amount it could pay people in her position, and she made more than the maximum.

To avoid cutting salaries, the VA gave Watson and four other employees new roles as coding document improvement (CDI) program coders. In addition to some coding work, they were tasked with new responsibilities. Watson and two of the other individuals were black women.

Watson presented evidence indicating she and the other CDI coders felt they were being isolated, set up for failure, and targeted by their boss: