Petitioner
Meritor Savings Bank
Respondent
Mechelle Vinson
Petitioner's Claim
That the Civil Rights Act of 1964 limits discrimination in the workplace to that which results in economic injury.
Chief Lawyer for Petitioner
F. Robert Troll, Jr.
Chief Lawyer for Respondent
Patricia J. Barry
Justices for the Court
Harry A. Blackmun, William J. Brennan, Jr., Warren E. Burger, Thurgood Marshall, Sandra Day O'Connor, Lewis F. Powell, Jr., William H. Rehnquist (writingfor the Court), John Paul Stevens, Byron R. White
Justices Dissenting
None
Place
Washington, D.C.
Date of Decision
19 June 1986
Decision
The decision of the court of appeals was affirmed and remanded.
Significance
The case of Meritor Savings Bank v. Vinson raised many important questions about the issues of sexual harassment in the workplace, as pertaining tothe Civil Rights Act of 1964, under Title VII.
Case Background
Meritor Savings Bank v. Vinson arose from allegations by Mechelle Vinson against Sidney Taylor and Meritor Savings Bank. These allegations stated that Vinson was repeatedly sexually harassed by Taylor, her supervisor. Taylorhired Vinson in September of 1974 as a teller trainee, who progressed to teller, then head teller, and finally to assistant branch manager, promotions that were based on merit. Vinson alleged that in May of 1975 Taylor began to have "sexual affairs" with Vinson, which Taylor denied. Vinson notified Taylorin September of 1978 that she would be taking sick leave indefinitely, and on1 November 1978 she was fired for "excessive use of that leave." Vinson thensued both Taylor and the bank, claiming that she had suffered through sexualharassment by Taylor during the four and a half years she was at the bank, and "sought injunctive relief, compensatory and punitive damages against Taylor and the bank, and attorney's fees."
At the trial, Vinson testified that Taylor made "repeated demands upon her for sexual favors, usually at the branch, both during and after business hours"and that she agreed only because she feared that she would lose her job. Taylor denied these claims, testifying that he "never fondled her, never made suggestive remarks to her, never engaged in sexual intercourse with her, and never asked her to do so," and he contended that Vinson "made her accusations in response to a business-related dispute." Vinson never reported the harassment to the bank and "never attempted to use the bank's complaint procedure." Because it was never reported, the bank "asserted that any sexual harassment by Taylor was unknown to the bank and engaged in without its consent or approval."
The district court found that 1) relief should be denied because the sexual relationship was voluntary and did not affect Vinson's employment at the bank,and 2) that because the alleged sexual harassment was never made known to the bank, it could not be held liable. The case went on to the court of appeals, which reversed and remanded the decision of the district court. The court of appeals believed that Vinson did have a claim under Title VII because the alleged sexual harassment created a "hostile or offensive working environment," which had not been considered by the district court. Furthermore, the courtof appeals decided that "an employer is absolutely liable for sexual harassment practiced by supervisory personnel, whether or not the employer knew or should have known about the misconduct." The U.S. Supreme Court granted certiorari and heard the case on 25 March 1986.
The Application of Title VII
This case examined the application of Title VII of the Civil Rights Act of 1964, which makes it unlawful for an employer "to discriminate against any individual with respect to his compensation, terms, conditions, or privileges ofemployment, because of such [an] individual's race, color, religion, sex, ornational origin." The court of appeals found that in this case the sexual harassment created "an offensive or hostile working environment" that was a violation of Title VII and that sexual harassment of a subordinate by a supervisor was considered sexual discrimination. The petitioner argued that the alleged sexual harassment did not result in an economic loss.
The Supreme Court disagreed with that argument, saying that the intent of Congress was to address a large range of mistreatment, not limited to economic loss only. Also, the Equal Employment Opportunity Commission (EEOC) had issuedguidelines in 1980 that defined sexual harassment as a type of sexual discrimination unacceptable in the workplace, in other words, a "hostile environment" (Rogers v. EEOC, [1972]). The Court felt that the respondent's claims were "plainly sufficient to state a claim for `hostile environment' sexualharassment." The Supreme Court went on to say that, apparently, the districtcourt's finding that the respondent did not suffer sexual harassment was "likely based on one or both of two erroneous views of the law." First, the district court did not consider this case to fall under the "`hostile environment' theory" as the court of appeals correctly did. Second, the district court believed that the sexual activity was voluntary, which the Supreme Court rejected as a sufficient defense against a Title VII complaint, noting that the sexual relationship was "unwelcome."
Another point in contention was that the court of appeals did not admit as evidence testimony about the respondent's dress or "sexually provocative speech," saying it was not relevant. However, the Supreme Court found that, following the EEOC guidelines, "such evidence is obviously relevant."
The Supreme Court then turned to the matter of whether the bank was liable for the actions of Taylor. Because the bank was never notified of Taylor's alleged misconduct towards Vinson, the district court found that it "could not beheld liable for Taylor's alleged actions." The court of appeals did not agree, "holding that an employer is strictly liable for a hostile environment created by a supervisor's sexual advances, even though the employer neither knewnor reasonably could have known of the alleged misconduct." The petitioner argued that because Vinson failed to report the misconduct using "its established procedure," the bank could not be held accountable for "Taylor's wrongdoing." The Supreme Court opted not to define the responsibilities of employer liability and held that "the Court of Appeals erred in concluding that employers are always automatically liable for sexual harassment by their supervisors" and "absence of notice to an employer does not necessarily insulate that employer from liability." Thus, the Supreme Court affirmed the decision of thecourt of appeals that reversed the district court decision, and remanded thecase "for further proceedings consistent with this opinion."
Impact
The difficult issues concerning sexual harassment in the workplace continue to be debated and contested in the courts, as evidenced by the large number ofcases citing Meritor Savings Bank v. Vinson: nine Supreme Court cases, and about 100 cases in the circuit courts. It is certain that sexual discrimination remains a serious problem for many Americans.
Related Cases
How Sexual Harassment is Determined
The Equal Employment Opportunity Commission (EEOC) was established under Title VII of the Civil Rights Act of 1964. The EEOC defined two types of harassment, and other factors governing sexual harassment suits.
The first type of sexual harassment, quid pro quo harassment occurs when economic benefit or other gain is explicitly or implicitly promised in return for sexual favors. In an employment setting, this may involve the promiseof pay increases, promotions, or other perks. In an academic setting, it might mean giving a student a higher grade than he or she deserved, or a place on a school team.
The other type of harassment is created when a "hostile environment" resultsbecause of one person's behavior toward another. This may occur when one party's sexual advances are rejected by the other, and the use of sexual innuendomay be used to punish the rejecting party. It can involve the use of insulting language, jokes in bad taste, or hanging lewd and potentially offensive pictures within one's work space.
Financial or psychological damage does not have to occur to justify a claim.The determination of whether the advances are "unwelcome" or not is also a factor.
Sources
Findlaw. http://www.findlaw.com/casecode/supreme.html.
Meritor Savings Bank
Respondent
Mechelle Vinson
Petitioner's Claim
That the Civil Rights Act of 1964 limits discrimination in the workplace to that which results in economic injury.
Chief Lawyer for Petitioner
F. Robert Troll, Jr.
Chief Lawyer for Respondent
Patricia J. Barry
Justices for the Court
Harry A. Blackmun, William J. Brennan, Jr., Warren E. Burger, Thurgood Marshall, Sandra Day O'Connor, Lewis F. Powell, Jr., William H. Rehnquist (writingfor the Court), John Paul Stevens, Byron R. White
Justices Dissenting
None
Place
Washington, D.C.
Date of Decision
19 June 1986
Decision
The decision of the court of appeals was affirmed and remanded.
Significance
The case of Meritor Savings Bank v. Vinson raised many important questions about the issues of sexual harassment in the workplace, as pertaining tothe Civil Rights Act of 1964, under Title VII.
Case Background
Meritor Savings Bank v. Vinson arose from allegations by Mechelle Vinson against Sidney Taylor and Meritor Savings Bank. These allegations stated that Vinson was repeatedly sexually harassed by Taylor, her supervisor. Taylorhired Vinson in September of 1974 as a teller trainee, who progressed to teller, then head teller, and finally to assistant branch manager, promotions that were based on merit. Vinson alleged that in May of 1975 Taylor began to have "sexual affairs" with Vinson, which Taylor denied. Vinson notified Taylorin September of 1978 that she would be taking sick leave indefinitely, and on1 November 1978 she was fired for "excessive use of that leave." Vinson thensued both Taylor and the bank, claiming that she had suffered through sexualharassment by Taylor during the four and a half years she was at the bank, and "sought injunctive relief, compensatory and punitive damages against Taylor and the bank, and attorney's fees."
At the trial, Vinson testified that Taylor made "repeated demands upon her for sexual favors, usually at the branch, both during and after business hours"and that she agreed only because she feared that she would lose her job. Taylor denied these claims, testifying that he "never fondled her, never made suggestive remarks to her, never engaged in sexual intercourse with her, and never asked her to do so," and he contended that Vinson "made her accusations in response to a business-related dispute." Vinson never reported the harassment to the bank and "never attempted to use the bank's complaint procedure." Because it was never reported, the bank "asserted that any sexual harassment by Taylor was unknown to the bank and engaged in without its consent or approval."
The district court found that 1) relief should be denied because the sexual relationship was voluntary and did not affect Vinson's employment at the bank,and 2) that because the alleged sexual harassment was never made known to the bank, it could not be held liable. The case went on to the court of appeals, which reversed and remanded the decision of the district court. The court of appeals believed that Vinson did have a claim under Title VII because the alleged sexual harassment created a "hostile or offensive working environment," which had not been considered by the district court. Furthermore, the courtof appeals decided that "an employer is absolutely liable for sexual harassment practiced by supervisory personnel, whether or not the employer knew or should have known about the misconduct." The U.S. Supreme Court granted certiorari and heard the case on 25 March 1986.
The Application of Title VII
This case examined the application of Title VII of the Civil Rights Act of 1964, which makes it unlawful for an employer "to discriminate against any individual with respect to his compensation, terms, conditions, or privileges ofemployment, because of such [an] individual's race, color, religion, sex, ornational origin." The court of appeals found that in this case the sexual harassment created "an offensive or hostile working environment" that was a violation of Title VII and that sexual harassment of a subordinate by a supervisor was considered sexual discrimination. The petitioner argued that the alleged sexual harassment did not result in an economic loss.
The Supreme Court disagreed with that argument, saying that the intent of Congress was to address a large range of mistreatment, not limited to economic loss only. Also, the Equal Employment Opportunity Commission (EEOC) had issuedguidelines in 1980 that defined sexual harassment as a type of sexual discrimination unacceptable in the workplace, in other words, a "hostile environment" (Rogers v. EEOC, [1972]). The Court felt that the respondent's claims were "plainly sufficient to state a claim for `hostile environment' sexualharassment." The Supreme Court went on to say that, apparently, the districtcourt's finding that the respondent did not suffer sexual harassment was "likely based on one or both of two erroneous views of the law." First, the district court did not consider this case to fall under the "`hostile environment' theory" as the court of appeals correctly did. Second, the district court believed that the sexual activity was voluntary, which the Supreme Court rejected as a sufficient defense against a Title VII complaint, noting that the sexual relationship was "unwelcome."
Another point in contention was that the court of appeals did not admit as evidence testimony about the respondent's dress or "sexually provocative speech," saying it was not relevant. However, the Supreme Court found that, following the EEOC guidelines, "such evidence is obviously relevant."
The Supreme Court then turned to the matter of whether the bank was liable for the actions of Taylor. Because the bank was never notified of Taylor's alleged misconduct towards Vinson, the district court found that it "could not beheld liable for Taylor's alleged actions." The court of appeals did not agree, "holding that an employer is strictly liable for a hostile environment created by a supervisor's sexual advances, even though the employer neither knewnor reasonably could have known of the alleged misconduct." The petitioner argued that because Vinson failed to report the misconduct using "its established procedure," the bank could not be held accountable for "Taylor's wrongdoing." The Supreme Court opted not to define the responsibilities of employer liability and held that "the Court of Appeals erred in concluding that employers are always automatically liable for sexual harassment by their supervisors" and "absence of notice to an employer does not necessarily insulate that employer from liability." Thus, the Supreme Court affirmed the decision of thecourt of appeals that reversed the district court decision, and remanded thecase "for further proceedings consistent with this opinion."
Impact
The difficult issues concerning sexual harassment in the workplace continue to be debated and contested in the courts, as evidenced by the large number ofcases citing Meritor Savings Bank v. Vinson: nine Supreme Court cases, and about 100 cases in the circuit courts. It is certain that sexual discrimination remains a serious problem for many Americans.
Related Cases
- Skidmore v. Swift & Co., 323 U.S. 134 (1944).
- Griggs v. Duke Power Co., 401 U.S. 424 (1971).
- Rogers v. EEOC, 406 U.S. 957 (1972).
- Albemarle Paper Co. v. Moody, 422 U.S. 405 (1975).
- Franks v. Bowman Transportation Co., 424 U.S. 747 (1976).
- General Electric Co. v. Gilbert, 429 U.S. 125 (1976).
- Banta v. United States, 434 U.S. 819 (1977).
- Los Angeles Dept. of Water and Power v. Manhart, 435 U.S. 702 (1979).
How Sexual Harassment is Determined
The Equal Employment Opportunity Commission (EEOC) was established under Title VII of the Civil Rights Act of 1964. The EEOC defined two types of harassment, and other factors governing sexual harassment suits.
The first type of sexual harassment, quid pro quo harassment occurs when economic benefit or other gain is explicitly or implicitly promised in return for sexual favors. In an employment setting, this may involve the promiseof pay increases, promotions, or other perks. In an academic setting, it might mean giving a student a higher grade than he or she deserved, or a place on a school team.
The other type of harassment is created when a "hostile environment" resultsbecause of one person's behavior toward another. This may occur when one party's sexual advances are rejected by the other, and the use of sexual innuendomay be used to punish the rejecting party. It can involve the use of insulting language, jokes in bad taste, or hanging lewd and potentially offensive pictures within one's work space.
Financial or psychological damage does not have to occur to justify a claim.The determination of whether the advances are "unwelcome" or not is also a factor.
Sources
Findlaw. http://www.findlaw.com/casecode/supreme.html.
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