Title, Style, and Citation
Meritor Sav. Bank, FSB v. Vinson – 477 U.S. 57, 106 S. Ct. 2399 (1986). Supreme Court of the United States, Web.
In this title of the case, the bank’s name comes first since it is the loser who went to a higher court. The lawsuit was initially filed by a bank employee, Mechelle Vinson, in the United States District Court for the District of Columbia.
Facts of the Case
Mechelle Vinson, a defendant and a former employee of the plaintiff bank, filed a lawsuit against the bank and its bank manager Sidney Taylor. She alleges that while working at the bank, she was sexually harassed by the manager in violation of Title VII of the Civil Rights Act of 1964.
In 1974, Meritor Savings Bank hired Mechelle Vinson, a black woman, as a cashier. Sidney Taylor was the vice president of the bank and the immediate manager of the new employee. Vinson claimed that Taylor coerced her into sexual relations with him and demanded sexual favors at work, including colleagues’ presence. For fear of losing her job, the cashier was forced to meet the needs of her boss. During her several years as a bank employee, Vinson estimates that she was sexually harassed by Taylor approximately 40 to 50 times, both during and after business hours (Meritor Sav. Bank, FSB v. Vinson, 1) In November 1978, Vinson was fired, the reason why, according to Taylor, was the excessive use of sick leave. Following her dismissal, Mechelle Vinson filed a lawsuit against Sidney Taylor, alleging that sexual harassment by her boss created a “hostile working environment” and was a form of illegal discrimination under Title VII of the Civil Rights Act of 1964. Moreover, the woman sought an injunction and compensation from Taylor and the bank.
Issue
Does the Civil Rights Act prohibit the creation of a “hostile environment,” or is it limited to perceived economic discrimination in the workplace, including dismissal and demotion?
Holdings
Yes, the Supreme Court ruled that creating a hostile or abusive work environment is indeed a violation of Title VII of the Civil Rights Act of 1964.
Reasoning and Analysis
The court ruled that sexual harassment in a “hostile environment” is a form of gender discrimination that is subject to legal action under Title VII. (Meritor Sav. Bank, FSB v. Vinson, 4)
The wording of Title VII is not limited to “economic” discrimination. Under the interpretation of Title VII, sexual harassment resulting in non-economic harm violates Title VII.
The Court has also established a standard that, when considering claims of sexual harassment, the critical distinction is not whether the sexual relationship was voluntary but whether such sexual harassment was unwelcome. (Meritor Sav. Bank, FSB v. Vinson, 4)
The court ruled that employers are not always automatically responsible for the sexual harassment of employees by their supervisors. In this case, however, the mere existence of a bank grievance procedure and the bank’s anti-discrimination policy, coupled with the defendant’s failure to do so, does not necessarily absolve the bank from liability. (Meritor Sav. Bank, FSB v. Vinson, 4)
The court cited the 11th Circuit judgment in Henson v. City of Dundee, 682 F.2d 897, 902 (11th Cir. 1982), in which gender-based harassment was compared to racial harassment. (Meritor Sav. Bank, FSB v. Vinson, 9)
The Mechelle Vinson decision in the Supreme Court was the first case of sexual harassment to be declared “actionable” by a court. Moreover, this case is also notable because it is doubtful whether sexual behavior between superior and subordinate can indeed be voluntary due to the dynamics of power and hierarchical relationships between them.
Work Cited
Meritor Sav. Bank, FSB v. Vinson – 477 U.S. 57, 106 S. Ct. 2399 (1986). Supreme Court of the United States, Web.