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.