Sexual_Harassment_Case

Meritor Savings Bank, FSB v. Vinson 477 U.S. 57 (1986) INTRODUCTION In 1974, 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'" Issue Instead of she doing the right thing at the beginning of the indecorous proposition, she accepted and not only that she started an affair with him for more than a year. Ruling Rule: Violation of Title VII when one of the following occur: 1. harassment that involves the conditioning of the employment benefits on sexual favors 2. harassment that, while not affecting economic benefits, creates a hostile or offensive working environment EEOC as Amici Curiae 26 “If the employer has an expressed policy against sexual harassment and has implemented a procedure specifically designed to resolve sexual harassment claims, and if the victim does not take advantage of that procedure, the employer should be shielded from liability absent actual knowledge of the sexually hostile environment.” The court determined that QUID PRO QUO was not the only type of sexual harassment. For the first time, the U.S. supreme court determined that this kind of situation constituted hostile environment sexual harassment. The Court of Appeals reversed and remanded. Noting that a violation of Title VII may be predicated on either of two types of sexual harassment - (1) harassment that involves the conditioning of employment benefits on sexual favors, and (2) harassment that, while not affecting economic benefits, creates a hostile or offensive working environment - the Court of Appeals held that since the grievance here was of the second type and the District Court had not considered whether a violation of this type had occurred, a remand was necessary. The court further held that the need for a remand was not obviated by the fact that the District Court had found that any sexual relationship between respondent and the supervisor was a voluntary one, a finding that might have been based on testimony about respondent's "dress and personal fantasies" that "had no place in the litigation." As to the bank's liability, the Court of Appeals held that an employer is absolutely liable for sexual harassment by supervisory personnel, whether or not the employer knew or should have known about it. Analysis Based on the theory of hostile work environment and one of the core federal statutes and according to title VII of the civil rights Act of 1964 where prohibits discrimination against color in addition to color, race, national origin, gender, sex or religion, and also based on age discrimination in Employment Act of 1967 and finally on the Americans with disabilities act of 1990, I believe also that it wasn’t any of the one’s mentioned before, specifying sexual harassment ; 1. Because the person who was or is the employee, didn’t ask the harasser to stop at any time. 2. She mentioned that she was afraid to lose her job and her good position at the company, but she never said no to that person to stop harassing her. 3. She sleep with him 40 to 50 times, so for me it sounds like a relationship or affair between them and she tried to get advantaged of the situation. I think somebody that is not comfortable with someone will not sleep that many times with that individual and at the beginning will try to avoid that person and will do something about it. 4. Also she tried to make it look worst like saying that she was raped on several occasions. 5. If this person (Vinson) would had psychological damage for those reasons, she wouldn’t started dating another male individual after several years of relationship with her boss. FACTS Facts: Plaintiff, Mechelle Vinson, claims that while she was employed at Meritor Savings bank, she was sexually harassed by her supervisor, Sidney Taylor. Vinson started out as a teller-trainee, but soon promoted to teller, head teller, and assistant branch manager. Shortly after being hired, Vinson claims to have been sexually harassed and repeatedly asked for sexual favors from Taylor. Vinson claims that out of fear for her job, she eventually agreed. The sexual harassment was never reported to the bank by the plaintiff. Taylor denied the allegations of sexual activity, along with denying all other claims of harassment. The bank denied the plaintiff’s allegations and claimed any sexual harassment was unknown and not reported to them. The District Court denied relief to Vinson, saying if a sexual relationship did occur; it was voluntary and did not affect Vinson’s employment at the bank. As for the bank’s liability, the District Court stated that the bank could not be held liable because it was not informed of any allegations. The Court of Appeals reversed and remanded, adding that an employer is liable for sexual harassment by a supervisory personnel, even if they were unaware of it. 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."