Meritor Savings Bank v. Vinson
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''Meritor Savings Bank v. Vinson'', 477 U.S. 57 (1986), is a
US labor law United States labor law sets the rights and duties for employees, labor unions, and employers in the United States. Labor law's basic aim is to remedy the "inequality of bargaining power" between employees and employers, especially employers "org ...
case, where the
United States Supreme Court The Supreme Court of the United States (SCOTUS) is the highest court in the federal judiciary of the United States. It has ultimate appellate jurisdiction over all U.S. federal court cases, and over state court cases that involve a point o ...
, in a 9–0 decision, recognized
sexual harassment Sexual harassment is a type of harassment involving the use of explicit or implicit sexual overtones, including the unwelcome and inappropriate promises of rewards in exchange for sexual favors. Sexual harassment includes a range of actions fro ...
as a violation of Title VII of the Civil Rights Act of 1964. The case was the first of its kind to reach the Supreme Court and would redefine sexual harassment in the workplace. It established the standards for analyzing whether conduct was unlawful and when an employer would be liable. The court, for the first time, made sexual harassment an illegal form of discrimination.


Background

In 1974, at the age of 19, Mechelle Vinson, a black woman, was hired as a teller-trainee at the northeast branch of Capitol City Federal Savings and Loan Association in Washington D.C. Vinson reported that by May 1975 her supervisor, Sidney L. Taylor, began what would be 3 years of recurring sexual harassment while in the workplace. In November 1978 Vinson was fired from her job at a
Meritor Savings Bank The Philadelphia Savings Fund Society (PSFS), originally called the Philadelphia Saving Fund Society, was a savings bank headquartered in Philadelphia, Pennsylvania, United States. PSFS was founded in December 1816, the first savings bank to organ ...
which Taylor explained as being due to Vinson's inordinate use of sick leave. The first initiation of Vinson's civil lawsuit against Sidney L. Taylor and Capital City Federal Savings and Loan Association, which would soon change its name to
Meritor Savings Bank The Philadelphia Savings Fund Society (PSFS), originally called the Philadelphia Saving Fund Society, was a savings bank headquartered in Philadelphia, Pennsylvania, United States. PSFS was founded in December 1816, the first savings bank to organ ...
, came in September 1978. Vinson charged that Taylor had coerced her to have sexual relations with him and made demands for sexual favors at work. Vinson stated that she had intercourse with Taylor 40 or 50 times. Additionally, she testified that Taylor had touched her in public, exposed himself to her, and forcibly raped her multiple times. She argued such harassment created a '"hostile working environment'" and a form of unlawful discrimination under Title VII of the Civil Rights Act of 1964. Vinson sought injunctive relief along with compensatory and punitive damages against Taylor and the bank. The primary question presented was whether a
hostile work environment In United States labor law, a hostile work environment exists when one's behavior within a workplace creates an environment that is difficult or uncomfortable for another person to work in, due to illegal discrimination. Common complaints in sexua ...
constituted a form of unlawful discrimination under the
Civil Rights Act of 1964 The Civil Rights Act of 1964 () is a landmark civil rights and United States labor law, labor law in the United States that outlaws discrimination based on Race (human categorization), race, Person of color, color, religion, sex, and nationa ...
, or if the Act was limited to tangible economic discrimination in the workplace.


Decision

The Court held that Title VII was "not limited to 'economic' or 'tangible' discrimination" and found that the intention of Congress was "'to strike at the entire spectrum of disparate treatment of men and women' in employment...." The Court pointed out that guidelines issued by the
EEOC The U.S. Equal Employment Opportunity Commission (EEOC) is a federal agency that was established via the Civil Rights Act of 1964 to administer and enforce civil rights laws against workplace discrimination. The EEOC investigates discrimination ...
specified that sexual harassment leading to noneconomic injury was a form of sex discrimination prohibited by Title VII of the Civil Rights Act of 1964. The Court recognized that the plaintiff, Mechelle Vinson, could establish violations of the Act "by proving that discrimination based on sex has created a hostile or abusive work environment." A Plaintiff with hostile environment-styled claims must prove that the challenged conduct was severe or pervasive, created a hostile or abusive working environment, was unwelcome, and was based on the plaintiff’s gender.
Catharine A. MacKinnon Catharine Alice MacKinnon (born October 7, 1946) is an American radical feminist legal scholar, activist, and author. She is the Elizabeth A. Long Professor of Law at the University of Michigan Law School, where she has been tenured since 1990, a ...
, author of ''Towards a Feminist Theory of the State'', was co-counsel for the respondent and wrote the respondent's brief.


Significance

The ruling of Mechelle Vinson’s Supreme Court case was the first instance of sexual harassment being recognized by the court as “actionable”. This ruling also qualified the hostile environment which sexual harassment in the workplace creates as sex discrimination under Title VII of the Civil Rights Act of 1964. Prior to the ruling on Vinson’s case, discrimination under Title VII was constituted as economic loss. This court case articulated that the creation of a hostile work environment is a form of discrimination and that economic loss is not required to be in violation of Title VII. Additionally, this case ruled that the sexual conduct between Taylor and Vinson could not be deemed voluntary due to the hierarchical relationship between supervisor and subordinates in the workplace. Following the ruling of Meritor Savings Bank v. Vinson, reported sexual harassment cases grew from 10 cases being registered by the EEOC per year before 1986 to 624 case being reported in the subsequent following year. This number of reported cases rose to 2,217 in 1990 and then 4,626 by 1995. A review revealed that the determination of what constitutes "severe or pervasive conduct" is invariably based on an examination of the totality of circumstances. Moreover, in gauging the totality of circumstances, lower courts typically focus on some or all of the following four factors: # the level of offensiveness of the unwelcome acts or words; # the frequency or pervasiveness of the offensive encounters; # the total length of time over which the encounters occurred; # the context in which the harassing conduct occurred. See for example '' Vance v. Southernbell Tel. & Tel. Co.'', 863 F.2d 1503 (11th Cir. 1989) (after the trial court granted a defense motion for judgment notwithstanding the verdict, on the ground that a noose hung over a black employee's desk on two different occasions was not enough, as a matter of law, to establish that the alleged racial harassment was a persistent, pervasive practice, the appellate court held that the determination of whether the defendant's conduct was sufficiently "severe and pervasive" did not turn solely on the number of incidents alleged by the plaintiff but was to be based on a consideration of all the circumstances, including the number and severity of individual incidents of harassment).


See also

*
US labor law United States labor law sets the rights and duties for employees, labor unions, and employers in the United States. Labor law's basic aim is to remedy the "inequality of bargaining power" between employees and employers, especially employers "org ...
* List of United States Supreme Court cases, volume 477 *
Hostile environment sexual harassment In United States labor law, a hostile work environment exists when one's behavior within a workplace creates an environment that is difficult or uncomfortable for another person to work in, due to illegal discrimination. Common complaints in sexual ...
*'' Hostile Advances: The Kerry Ellison Story'' movie about '' Ellison v. Brady'', which set the "reasonable woman" precedent in sexual harassment law. *'' Jenson v. Eveleth Taconite Co.'' *'' Oncale v. Sundowner Offshore Services'' *'' Crawford v. Nashville''


References


Sources

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External links

* {{caselaw source , case=''Meritor Savings Bank v. Vinson'', {{ussc, 477, 57, 1986, el=no , courtlistener =https://www.courtlistener.com/opinion/111712/meritor-savings-bank-fsb-v-vinson/ , findlaw=https://caselaw.findlaw.com/us-supreme-court/477/57.html , justia=https://supreme.justia.com/cases/federal/us/477/57/ , loc =http://cdn.loc.gov/service/ll/usrep/usrep477/usrep477057/usrep477057.pdf , oyez =https://www.oyez.org/cases/1985/84-1979 , other_source1 = WorldLII , other_url1 =http://www.worldlii.org/us/cases/federal/USSC/1986/139.html * Link to 1986 Washington Post Article on the Trial
Available here
United States Supreme Court cases United States Supreme Court cases of the Burger Court United States employment discrimination case law Business ethics cases Sexual harassment in the United States 1986 in United States case law United States gender discrimination case law United States labor case law Harassment case law