Law School Case Brief
Meritor Sav. Bank, FSB v. Vinson - 477 U.S. 57, 106 S. Ct. 2399 (1986)
A plaintiff may establish a violation of Title VII of the Civil Rights Act of 1964 by proving that discrimination based on sex has created a hostile or abusive work environment without an economic effect on employment.
A female bank employee was allegedly subjected to sexual harassment by her male supervisor, including (1) public fondling, and (2) sexual demands, to which she allegedly submitted out of fear that she would otherwise lose her job. She filed suit against the supervisor and the bank in the United States District Court for the District of Columbia after she was terminated, claiming that the supervisor's conduct had violated her rights under Title VII of Civil Rights Act of 1964. The supervisor denied that he had had any sexual relationship with the employee. The district court rendered judgment in favor of the supervisor and the bank without resolving that factual issue, holding (1) that the employee had not made out a case of sexual discrimination because any relationship that might have existed had been voluntary and had never been made a condition of the employee's continued employment or advancement, and (2) that the bank could not be held liable for the supervisor's alleged actions because it had not received any notice about his supposed offensive conduct. The United States Court of Appeals for the District of Columbia Circuit reversed and remanded, holding that an infringement of Title VII was not necessarily dependent upon the victim's loss of employment or promotion, that the voluntariness of the alleged sexual relationship was immaterial, and that an employer is liable for sexual harassment of a subordinate by a supervisor regardless of whether the employer knew or should have known about the harassment.
Did the employee establish an actionable sex discrimination claim under Title VII based on a showing of "hostile environment"?
The United States Supreme Court affirmed the judgment and remanded the case for further proceedings. It was held that a plaintiff may establish a violation of Title VII by proving that discrimination based on sex has created a hostile or abusive work environment, without showing an economic effect on the plaintiff's employment. The fact that sex-related conduct is "voluntary," in the sense that a plaintiff was not forced to participate against her will, is not a defense to a sexual harassment suit under Title VII, as the correct inquiry in such cases is whether the plaintiff had indicated by her conduct that the alleged sexual advances were unwelcome. Lastly, the court held that employers are not always automatically liable for sexual harassment of employees by their supervisors. If the attentions of respondent's supervisor were unwelcome, then respondent had a claim for sexual harassment on the basis of a hostile work environment, even if any sexual acts were voluntary. Petitioner would be liable for the acts of its employee, if it could be found liable under general agency principles.
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