Meritor Savings Bank v. Vinson

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. Taylor hired 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 Taylor in September of 1978 that she would be taking sick leave indefinitely, and on 1 November 1978 she was fired for "excessive use of that leave." Vinson then sued both Taylor and the bank, claiming that she had suffered through sexual harassment 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 court of 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.