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Shenika civil Rights Act of 1964 Sexual Discrimination in Employment
TITLE AND CITATION: Meritor Bank v. Vinson, 106 S. Ct. 2399 (1986)
TYPE OF ACTION: Review by the U.S. Supreme Court of a ruling made by the U.S. District Court for D.C. that sexual relations in the workplace were voluntary and not a part of a hostile environment. Meritor Bank sought to remove its responsibility for the actions taken by an employee. FACTS OF THE CASE:
Sometime in 1974 Mechelle Vinson met the vice president of Meritor Bank, Sidney Taylor, and inquired about a job. Mr. Taylor gave Ms. Vinson an application to apply for a position. She immediately filled it out and turned it in the next day. Later, on the same day, Vinson turned in her application. She received a call from Mr. Taylor stating that the position was hers and she would be under his supervision. She was initially hired as a teller-trainee and progressed into a position as a head branch manager. Her progression with the company happened over four years. There was no challenge made that she had received promotions due to the quality of work she produced. In September of 1978, Mechelle Vinson let her supervisor, Sidney Taylor know that she needed to take an extended leave of absence. Meritor Bank discharged Ms. Vinson on November 1, 1978, stating she had been using too much leave time. Vinson filed sexual harassment charges against Meritor Bank and Sidney Taylor with the District Court alleging that she had been sexually harassed by her boss during her employment. In her defense, she stated that Sidney Taylor originally came off as fatherly. He eventually started asking her out and making innuendos to engage in sexual activities. She admitted that she would tell him no at first but started fearing that she would lose her job. Ms. Vinson claimed that she and her former boss had sexual relations between 40 and 50 times over a few years. She additionally stated that he had fondled her in the presence of other employees and even raped her in the women’s bathroom several times. She states that she has witnesses who can attest to the events. The District Court did not allow witness testimony and decided since no there were no other allegations of sexual harassment that Vinson’s claims were unfounded and voluntary. Also, the bank was not held liable for Taylor’s alleged actions. Vinson’s appeal of the decision was denied.
CONTENTIONS OF THE PARTIES: Meritor Bank: Contends that the alleged sexual actions committed by Sidney Taylor are of no fault of the bank and did not present a hostile work environment. Mechelle Vinson: The sexual advances were offensive and unwelcomed. They caused a hostile work environment which was in clear violation of her Title VII Civil Rights. Respondent feared a loss of economic support if she did not participate. ISSUE: If a supervisor sexually harasses a lower-level employee and the employee fears the loss of their job if they do not allow the actions, is that a form of discrimination based on sex?
DECISION: Yes, it is a form of discrimination because the supervisor’s unwanted actions created a hostile environment.
REASONING: The court applied the reasoning that the actions of the supervisor were a violation of Title VII prohibiting sex discrimination in employment. Furthermore, the employer is responsible for the actions of its employees in matters of sexual harassment regardless of if the employer was or was not informed. RULE OF LAW: Employees may establish a violation of Title VII which prohibits sexual discrimination in employment if it’s proven that the sexual actions created a hostile or abusive work environment.
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