Meritor Savings Bank v. Mechelle Vinson
MERITOR SAVINGS BANK V. MECHELLE VINSON
MERITOR SAVINGS BANK V. MECHELLE VINSON, 477 U.S. 57 (1986), a Supreme Court decision that attempted for the first time to define what standard a court should use to determine sexual harassment under Title VII of the Civil Rights Act of 1964. The two main issues were whether a plaintiff's claim of sexual harassment could succeed if based on psychological aspects without tangible loss of an economic character, and whether employers are absolutely liable in cases of sexual harassment by supervisors.
Mechelle Vinson was an employee at Meritor Savings Bank under the supervision of the vice president and branch manager, Sidney Taylor, and Vinson had earned various promotions on the basis of merit. Vinson testified that Taylor invited her to dinner; repeatedly proposed sexual relations, leading to forty or fifty occasions of intercourse; fondled her in front of employees; followed her into the women's restroom; exposed himself to her; and raped her on several occasions. At first, Vinson resisted but ceased to do so out of fear of losing her job. She testified that she was afraid to report the incidents or use the bank's complaint procedure out of fear and because she would have to make the claim directly to her supervisor, Taylor. She said that Taylor stopped sexually harassing her when she began dating someone steadily. She was fired for taking an excessive leave of absence.
Subsequently, she filed a sexual harassment claim for violations of Title VII. Both the bank and Taylor denied Vinson's accusations and insisted that the claim arose from a business-related dispute. The bank asserted that if Vinson's claims were true, the supervisor's activities were unknown to the bank's executive managers and engaged in without its consent. The federal district court held that for a sexual harassment claim to prevail, the plaintiff had to demonstrate a tangible economic loss. The court also held that the bank was not liable for the misconduct of its supervisors. On both counts the circuit court reversed in favor of Vinson. The bank appealed to the Supreme Court, which in a unanimous decision decided for Vinson on the first point but held that employers were not automatically liable for sexual harassment by supervisors. Similarly, however, absence of notice to an employer did not insulate the business from liability for the acts of supervisors. In such cases the issue was one of fact, which required meeting a burden of proof. The case placed sexual harassment resulting in a hostile work environment on an equal footing with sexual harassment resulting in the loss of job or promotion. It put employers on notice that they must review supervisors' conduct because mere absence of notice of improper conduct is no longer a defense.
BIBLIOGRAPHY
Hartmann, Susan M. From Margin to Mainstream: American Women and Politics since 1960. Philadelphia: Temple University Press, 1989.
MacKinnon, Catharine A. Sexual Harassment of Working Women: A Case of Sex Discrimination. New Haven, Conn.: Yale University Press, 1979.
TonyFreyer/a. r.
See alsoDiscrimination: Sex ; Sexual Harassment .