Kayla Loyd, a patrol officer with the Ruston Police Department in Ruston, Louisiana, alleged that the Police Chief denied her requests to transfer into the Criminal Investigation Division (CID) because of her gender, in violation of Title VII of the Civil Rights Act. At trial, a jury returned a verdict for the City, finding that the denial of a transfer was not an “adverse employment action,” which is a necessary component of that claim. Loyd appealed, challenging the sufficiency of the evidence.
The Fifth Circuit affirmed. The Court explained that denial of a transfer is an adverse employment action only if the sought position is “objectively better” than the employee’s current role. Relevant factors include pay, benefits, responsibilities, advancement opportunities, required qualifications, and prestige.
The City introduced evidence that the CID position was not objectively better than patrol. Testimony showed that CID officers received no pay increase and lost access to the substantial overtime opportunities available to patrol officers. Although CID officers were issued phones and a modest clothing allowance, the weights of benefits was offset by the burden of being on-call at all hours and by patrol officers’ broader access to uniforms and equipment. The evidence also suggested that CID officers worked under closer supervision, had less flexible schedules, and enjoyed no significant career or prestige advantages. Further, transfers to CID required no additional education or competitive application process, and the position carried no promotion in rank.
On this record, the Fifth Circuit concluded that ample evidence supported the jury’s finding that the CID post was not an objectively superior position, and that Loyd therefore did not suffer an adverse employment action. The judgment for the City was therefore affirmed.
Loyd v. City of Ruston, No. 24-30736, 2025 WL 2375237, (5th Cir. Aug. 15, 2025).