Reference no: EM133134956

Meritor Savings Bank, FSB v. Vinson 477 U.S. 57 (1986)

Case: Meritor Savings Bank, FSB v. Vinson 477 U.S. 57 (1986) Page 504

Parties:  Vinson is the plaintiff and Sidney Taylor, vice president of the bank is the defendant.

Facts: Mechelle Vinson filed a lawsuit against Sidney Taylor, the vice president of a Meritor Savings Bank, after she was fired. Vinson said that throughout her four years at the bank, Taylor had harassed her on a regular basis. Using Title VII of the Civil Rights Act of 1964, she claimed that such harassment constituted a "hostile working environment" that was protected by the law. Vinson sought injunctive and compensatory damages against Taylor and the bank, as well as punitive damages.

Issue: Did the Civil Rights Act prohibit the creation of a "hostile environment" or was it limited to tangible economic discrimination in the workplace?

Applicable Law(s): Civil Rights Act of 1964, Section VII. A claim of sexual harassment does not need proof of financial losses. The CRA of 1964 allows for legal recourse in this situation.

Holding: As the Supreme Court ruled, the meaning of Title VII was "not restricted to economic discrimination, but rather to the whole range of differential treatment of men and women" in the workplace... Sexual harassment that causes non-economic harm is a form of discrimination against women, according to EEOC rules, which the Court cited. To demonstrate a violation, plaintiffs must show that their treatment at work was made hostile or abusive because of their gender, according to the Supreme Court. On the issue of how much a firm might be held accountable for the actions of its workers, the Supreme Court refused to decide. The Court of Appeal overturned and remanded. Note that a violation of Title VII may be based on one of two forms of sexual harassment.

Reasoning: The District Court's judgment that no actionable harassment occurred may have been based on its prior finding that if Vinson and Taylor had participated in intimate or sexual contacts, that relationship was a choice one. It is not a defense to a Title VII sexual harassment complaint if the behavior in question was "voluntary" in the sense that the complainant was not coerced into participating. Unwelcome sexual approaches are the crux of every sexual harassment lawsuit. The District Court in this case focused incorrectly on the "voluntariness" of Vinson's participation in the alleged sexual episodes, even though determining whether or not certain conduct was indeed unwelcome presents difficult problems of proof and relies heavily on credibility determinations made by the trier of fact. The proper question is whether Vinson, by her actions, signaled that the claimed sexual approaches were unwanted, rather than whether she consented to sexual intercourse.

Vinson's "dress and personal desires" were permitted into evidence by the district court. Since Vinson's voluntary submission to Taylor's approaches was not relevant to her allegation of sexual harassment, the Court of Appeals ruled that evidence was unnecessary. There is no defense to such a claim in the sense of "voluntariness," but this does not mean that a complainant's sexually suggestive words or apparel are immaterial as a matter of law for deciding whether or not certain sexual approaches were acceptable. Such material, on the other hand, is clearly relevant to page 505. A key point in the EEOC's guidelines is that a fact-finder must consider "the record as a whole" and "the totality of circumstances" while determining whether or not sexual harassment happened.

Case Questions:

1. As a manager, what would you have done if Vinson had come to you with her story?
2. Under the circumstances, should it matter that Vinson "voluntarily" had sex with Taylor? That she received her regular promotions? Explain.
3. As a manager, how would you determine whom to believe?

Reference:

Rehnquist, W. H. & Supreme Court Of The United States. (1985) U.S. Reports: Meritor Savings Bank v. Vinson, 477 U.S. 57. [Periodical] Retrieved from the Library of Congress, https://www.loc.gov/item/usrep477057/

Fitzpatrick, Robert, March 2010, Hostile Work Environment - Single Incident of Harassment Retrieved from: https://casetext.com/analysis/hostile-work-environment-single-incident-ofharassment?sort=relevance&resultsNav=false&q=