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L
ast month, a federal appellate court concluded that training delays, a denied vacation request, and a transfer to a different shift that interfered with the plaintiff’s childcare arrangements could all support a discrimination claim—even though the plaintiff never lost h
i
s job. It could be the new normal since the Supreme Court’s decision in Muldrow v. City of St. Louis
,
Missouri. In Muldrow, the Supreme Court concluded that a plaintiff claiming discrimination based on disparate treatment under Title VII “must show some harm respecting an identifiable term or condition of employment. What the [plaintiff] does not have to show, according to