Meritor Savings Bank v. Vinson
Encyclopedia
Meritor Savings Bank v. Vinson, 477 U.S. 57
(1986), marked the United States Supreme Court's recognition of certain forms of sexual harassment
as a violation of Civil Rights Act of 1964 Title VII
, and established the standards for analyzing whether conduct was unlawful and when an employer would be liable.
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: "Is a hostile work environment a form of unlawful discrimination under the Civil Rights Act of 1964, 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.
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.)
Case citation
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...
(1986), marked the United States Supreme Court's recognition of certain forms of sexual harassment
Sexual harassment
Sexual harassment, is intimidation, bullying or coercion of a sexual nature, or the unwelcome or inappropriate promise of rewards in exchange for sexual favors. In some contexts or circumstances, sexual harassment is illegal. It includes a range of behavior from seemingly mild transgressions and...
as a violation of Civil Rights Act of 1964 Title VII
Civil Rights Act of 1964
The Civil Rights Act of 1964 was a landmark piece of legislation in the United States that outlawed major forms of discrimination against African Americans and women, including racial segregation...
, and established the standards for analyzing whether conduct was unlawful and when an employer would be liable.
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. 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, 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
Catharine MacKinnon
Catharine Alice MacKinnon is an American feminist, scholar, lawyer, teacher and activist.- Biography :MacKinnon was born in Minnesota. Her mother is Elizabeth Valentine Davis; her father, George E. MacKinnon was a lawyer, congressman , and judge on the U.S. Court of Appeals for the D.C. Circuit...
, 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 harassmentHostile environment sexual harassmentIn employment law, hostile environment sexual harassment refers to a situation where employees in a workplace are subject to a pattern of exposure to unwanted sexual behavior from persons other than an employee's direct supervisor where supervisors or managers take no steps to discourage or...
- Hostile Advances: The Kerry Ellison StoryHostile Advances: The Kerry Ellison StoryHostile Advances: The Kerry Ellison Story is a 1996 television movie based on Ellison v. Brady, a landmark sexual harassment case. This lawsuit set the precedent for the "reasonable woman" standard in sexual harassment law which allows for cases to be analyzed from the perspective of the...
movie about Ellison v. Brady, which set the "reasonable woman" precedent in sexual harassment law. - Jenson v. Eveleth Taconite Co.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...
- Oncale v. Sundowner Offshore ServicesOncale v. Sundowner Offshore ServicesOncale v. Sundowner Offshore Services, , 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 co-workers with the acquiescence of his...
- Crawford v. NashvilleCrawford v. NashvilleCrawford v. Metropolitan Government of Nashville, 129 S.Ct. 846 , is a United States Supreme Court case in which the Court unanimously ruled that Title VII of the 1964 Civil Rights Act protects an employee who opposes unlawful sexual harassment, but does not report the harassment him or herself.-...