Meritor Savings Bank v. Vinson
"Meritor Savings Bank v. Vinson" is a landmark Supreme Court case that addressed the issue of sexual harassment in the workplace and its classification as sex discrimination under Title VII of the Civil Rights Act. In this case, Mechelle Vinson, a former bank employee, alleged that her supervisor sexually harassed her, which prompted her to take legal action against both the supervisor and the bank itself. The Supreme Court, in a unanimous decision, affirmed that sexual harassment is indeed a form of sex discrimination actionable under federal law, thereby setting a significant precedent for future cases.
The Court endorsed the guidelines established by the Equal Employment Opportunity Commission, recognizing both quid pro quo harassment and hostile work environment claims. It clarified that a plaintiff does not need to prove tangible economic harm to succeed in such cases, highlighting the severe implications of harassment regardless of whether any sexual activity was initially consensual. Additionally, the ruling indicated that while employers are not automatically liable for the actions of their supervisors, each case must be evaluated based on its specific circumstances. This case played a crucial role in shaping the legal landscape surrounding workplace harassment and employer accountability.
Meritor Savings Bank v. Vinson
Date: June 19, 1986
Citation: 477 U.S. 57
Issues: Sexual harassment suits; sex discrimination
Significance: By deciding that sexual harassment is a form of gender discrimination, the Supreme Court cleared the way for employees, usually women, to sue employers for sexual harassment under Title VII of the Civil Rights Law of 1964.
Mechelle Vinson, a former employee of a bank, claimed that her supervisor, a vice president of the bank, had subjected her to constant sexual harassment and that this violated Title VII, as interpreted by guidelines of the Equal Employment Opportunity Commission. She brought legal action against both her former supervisor and the bank.
By unanimous vote, the Supreme Court held that sexual harassment constitutes sex discrimination and is actionable under the federal statute. Speaking for the Court, Chief Justice William H. Rehnquist accepted the commission’s guidelines, which recognized claims involving quid pro quo propositions and a broader hostile working environment. The plaintiff, in order to prevail, would not be required to demonstrate any tangible or economic harm. Sexual harassment may occur even when sexual activity is voluntary. Finally, a 5-4 majority of the Court held that employers are not automatically liable for sexual harassment by supervisors, but that the question of employer responsibility must be decided according to the circumstances of each separate case.