Meritor Savings Bank v. Vinson, 477 U.S. 57 Case citation is the system used in many countries to identify the decisions in past court cases, either in special series of books called reporters or law reports, or in a 'neutral' form which will identify a decision wherever it was reported. Although case citations are formatted differently in different jurisdictions, they generally contain the (1986), marked the United States Supreme Court The Supreme Court of the United States is the highest judicial body in the United States, and leads the federal judiciary. It consists of the Chief Justice of the United States and eight Associate Justices, who are nominated by the President and confirmed with the "advice and consent" of the Senate. Once appointed, Justices effectively's recognition of certain forms of sexual harassment as a violation of Civil Rights Act of 1964 Title VII The Civil Rights Act of 1964 was a landmark piece of legislation in the United States that extended voting rights and outlawed racial segregation in schools, at the workplace and by facilities that served the general public ("public accommodations"), and established the standards for analyzing whether conduct was unlawful and when an employer would be liable.
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Case facts
After being fired from her job at a Meritor Savings Bank, Mechelle Vinson sued Sidney Taylor, the Vice President of the bank. Vinson charged that Taylor had coerced her to have sexual relations with him and made demands for sexual favors while 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[1]. Vinson sought injunctive relief along with compensatory and punitive damages against Taylor and the bank.
The primary question presented was: "Is a hostile work environment a form of unlawful discrimination under the Civil Rights Act of 1964[1], or is the Act limited to "tangible economic discrimination" in the workplace?"
The Court held that Title VII was "not limited to 'economic' or 'tangible' discrimination," finding 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 specified that sexual harassment leading to noneconomic injury was a form of sex discrimination prohibited by Title VII. The Court recognized that plaintiffs could establish violations of the Act "by proving that discrimination based on sex has created a hostile or abusive work environment."
Catharine MacKinnon, author of Towards a Feminist Theory of the State, was co-counsel for the respondent Mechelle Vinson, and wrote the respondent's brief.
Plaintiff's Burden of Proof
Plaintiffs 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
Post Meritor
A review of post Meritor reveals 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, the lower courts typically focus on some or all of the following four factors: 1) the level of offensiveness of the unwelcome acts or words; 2) the frequency or pervasiveness of the offensive encounters; 3) the total length of time over which the encounters occurred; and 4) the context in which the harassing conduct occurred. See e.g., 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
- List of United States Supreme Court cases, volume 477
- Hostile environment sexual harassment
- 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. Lois E. Jenson v. Eveleth Taconite Co. was the first class-action sexual harassment lawsuit in the United States, filed in 1988 on behalf of Lois Jenson and other female workers at the EVTAC mine in Eveleth, Minnesota on the state's northern Mesabi Range, which is part of the Iron Range. The case was documented in the 2002 book Class Action and a 2
- Oncale v. Sundowner Offshore Services Oncale v. Sundowner Offshore Services, 523 U.S. 75 , was a decision of the Supreme Court of the United States. The case arose out of a suit for sex discrimination by a male oil-rig worker, who claimed that he was repeatedly subjected to sexual harassment by his male coworkers with the acquiescence of his employer. The Court held that Title VII's
- Crawford v. Nashville
Further reading
- Anderson, Katherine S. (1987). "Employer Liability under Title VII for Sexual Harassment after Meritor Savings Bank v. Vinson". Columbia Law Review 87 (6): 1258–1279. doi A digital object identifier is a character string used to uniquely identify an electronic document or other entity. The DOI for a document remains fixed over the lifetime of the document, unlike URLs which can change when a publisher of online content changes its web server's file structure, and the DOI System provides a mechanism for locating an:10.2307/1122590.
- Dodier, Grace M. (1987). "Meritor Savings Bank v. Vinson: Sexual Harassment at Work". Harvard Women's Law Journal 10: 203. ISSN An International Standard Serial Number is a unique eight-digit number used to identify a print or electronic periodical publication. The ISSN system was adopted as international standard ISO 3297 in 1975[citation needed]. The ISO subcommittee TC 46/SC 9 is responsible for the standard 02701456.
- Vinciguerra, Marlisa (1989). "The Aftermath of Meritor: A Search for Standards in the Law of Sexual Harassment". Yale Law Journal 98 (8): 1717–1738. doi A digital object identifier is a character string used to uniquely identify an electronic document or other entity. The DOI for a document remains fixed over the lifetime of the document, unlike URLs which can change when a publisher of online content changes its web server's file structure, and the DOI System provides a mechanism for locating an:10.2307/796614.
External links
- Text of Meritor Savings Bank v. Vinson, 477 U.S. 57 (1986) is available from: · Enfacto · Findlaw · BC
Footnotes
Categories: United States Supreme Court cases Articles and categories related to cases argued before the Supreme Court of the United States | Business law Business law consists of many different areas typically taught in law school curricula, including: Contracts, the law of Corporations and other Business Organizations, Securities Law, Intellectual Property , Antitrust, Secured Transactions, Commercial Paper, Income Tax, Pensions & Benefits, Trusts & Estates, Immigration Law, Labor Law, | Business ethics cases | Discrimination in the United States Articles related to discrimination, perceived discrimination, and discrimination-related advocacy efforts in the United States | Sexual harassment in the United States | Labour relations Categories: Human resource management | Business ethics | Labor | Organizational studies and human resource management Categories: Organizations | Management | Social psychology | Sexism | United States labor case law | 1986 in United States case law
Connecticut Law Tribune
A company's responsibility goes beyond OSHA regulations. US Supreme Court decisions in 1986 ( Meritor Savings Bank v . Vinson ) and 1998 (Faragher v . ...
Ed Brayton
Mon, 28 Jul 2008 18:34:59 GM
the key precedent on this is . meritor savings bank v. . . vinson. , a 1986 case in which the supreme court unanimously ruled that sexual harassment creates a hostile work environment that amounts to unlawful discrimination on the basis of ...
