Meritor Savings Bank v. Vinson

Meritor Savings Bank v. Vinson
Meritor Savings Bank v. Vinson
Seal of the United States Supreme Court.svg
Supreme Court of the United States
Argued March 25, 1986
Decided June 19, 1986
Full case name Meritor Savings Bank, FSB v. Mechelle Vinson, et al.
Holding
A claim of "hostile environment" sexual harassment is a form of sex discrimination that is actionable under the Civil Rights Act of 1964[1] Title VII.
Court membership
Case opinions
Majority Rehnquist, joined by Burger, White, Powell, Stevens, O'Connor
Concurrence Marshall, joined by Brennan, Blackmun

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.

Contents

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

Further reading

External links

  • Text of Meritor Savings Bank v. Vinson, 477 U.S. 57 (1986) is available from: Justia · Findlaw · BC

Footnotes


Wikimedia Foundation. 2010.

Игры ⚽ Нужна курсовая?

Look at other dictionaries:

  • Catharine MacKinnon — Infobox Scientist image width = 150px name = Catharine MacKinnon box width = birth date = October 7, 1946 (age 61) birth place = Minneapolis, Minnesota death date = death place = residence = citizenship = nationality = ethnicity = field = Legal… …   Wikipedia

  • Civil Rights Act of 1964 — Full title An act to enforce the constitutional right to vote, to confer jurisdiction upon the district courts of the United States of America to provide relief against discrimination in public accommodations, to authorize the Attorney General to …   Wikipedia

  • William Rehnquist — 16th Chief Justice of the United States In office September 26, 1986 – September 3, 2005 Nominated by …   Wikipedia

  • Sexual harassment — is unwelcome attention of a sexual nature and is a form of legal and social harassment. It includes a range of behavior from seemingly mild transgressions and annoyances to actual sexual abuse or sexual assault. (Dziech et al 1990, Boland 2002)… …   Wikipedia

  • Oncale v. Sundowner Offshore Services — Oncale v. Sundowner Offshore Services, Inc. Supreme Court of the United States Argued December 8, 1997 …   Wikipedia

  • Harassment — refers to a wide spectrum of offensive behaviour. The term commonly refers to behaviour intended to disturb or upset, and, when the term is used in a legal sense, it refers to behaviours which are found threatening or disturbing. Sexual… …   Wikipedia

  • Hostile environment sexual harassment — In 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… …   Wikipedia

  • Crawford v. Nashville — Supreme Court of the United States Argued October 8, 2008 Decided January 26 …   Wikipedia

  • Hostigamiento — El texto que sigue es una traducción defectuosa o incompleta. Si quieres colaborar con Wikipedia, busca el artículo original y mejora o finaliza esta traducción. Puedes dar aviso al autor principal del artículo pegando el siguiente código en su… …   Wikipedia Español

  • List of United States Supreme Court cases, volume 477 — This is a list of all the United States Supreme Court cases from volume 477 of the United States Reports :* Wardair Canada Inc. v. Florida Dept. of Revenue , ussc|477|1|1986 * Schiavone v. Fortune , ussc|477|21|1986 * Bowen v. Public Agencies… …   Wikipedia

Share the article and excerpts

Direct link
Do a right-click on the link above
and select “Copy Link”