Recently, the influential U.S. Circuit Court of Appeals for the District of Columbia. Circuit ruled that denial of a lateral transfer request based on protected status is actionable under Title VII of the Civil Rights Act of 1964 without proving additional harm, such as a change in pay or benefits. Though circuit courts are split on this issue, employees will likely pursue the theory of liability across the country. Read on to learn about this developing area of the law and what you can do to prevent discrimination claims based on lateral transfers.