Law // PRINCIPAL ANTI-DISCRIMINATION LAWS
Meritor Savings Bank v. Vinson
477 U.S. 57 (1986)
FACTS
Vinson alleged that during her four years working at the bank, she had been constantly subjected to sexual harassment by Taylor both during and after business hours, on and off the employer’s premises; she claimed that he forced her to have sexual intercourse with him on many occasions, fondled her in front of other employees, followed her into the women’s restroom and exposed himself to her, and even raped her on several occasions. According to her, due to fear of losing her job she submitted to his sexual demands and never reported his harassment to any of his supervisors and never attempted to use the bank’s complaint procedure. The supervisor and the employer denied all of her allegations. Taylor claimed they were fabricated in response to a business-related dispute, while the bank asserted that any sexual harassment by Taylor was unknown to them and they have no consent or approval to it.
The trial court denied relief in favor of Vinson and found that the sexual relationship between Vinson and Taylor was voluntary one and have nothing to do with her continued employment at the bank or her advancement. The Court of Appeals, however, reversed the decision of district court stating that a violation of Title VII may be predicated on two types of sexual harassment: (1) involves concrete employment benefits on sexual favors and (2) while not affecting the economic benefits, creates a hostile or offensive working environment, and remanded the case for further proceedings.
ISSUE
Whether or not there is a sexual harassment in this case as a violation of Title VII of the Civil Rights Act of 1964.
RULING
The Supreme Court affirmed the judgment of Court of Appeals reversing the judgment of the district court. It is held that “sexual harassment” as workplace conduct may be actionable under Title VII should have “(1) unwelcome sexual advances, requests for sexual favors, and other verbal or physical conduct of a sexual nature” and “(2) such conduct has the purpose or effect of unreasonably interfering with an individual’s work performance or creating an intimidating, hostile, or offensive working environment (U.S. Supreme Court, 1986)”
ANALYSIS
The decisions of the Supreme Court in relation to the case are as follows: (1) The right of the complainant to bring suit based on the 1964 Civil Rights Act is not limited to the charges wherein the Equal Employment Opportunity Commission has made a finding with reasonable cause and an error of the district court in holding in contrast was not undisruptive because the issues raised in relation to hostile environment theory. According to Title VII of the Civil Rights Act of 1964, the discrimination that is maintained by the law is not confined on “economic” or “tangible” discrimination, but it also extends beyond the economic aspects of employment for it also prohibits discrimination based on sex has created a hostile or abusive work environment.
In the case at bar, there was indeed apparent violation of the rights protected under Title VII of Civil Rights Act of 1964 on the grounds of sexual harassment. The court held that the gravamen of any sexual harassment claim is that the alleged sexual advances were ‘unwelcome’. As such the correct inquiry is whether Vinson, by her conduct, indicated that the alleged sexual advances were unwelcome, and not whether her actual participation in sexual intercourse was voluntary as decided by the district court. The EEOC Guidelines emphasize that the trier of fact must determine the existence of sexual harassment in light of the “record as a whole” and “the totality of circumstances, such as the nature of sexual advances and the context in which the alleged incidents occurred (U.S. Supreme Court, 1986).”
Reference
U.S. Supreme Court (1986). Meritor Savings Bank v. Vinson. Retrieved 30 May 2017 from Justia U.S. Law Database.
2017/5147
