2012-09-27 18:11:04 by admin
Meritor Savings Bank v. Vinson: The Court’s Ruling
Michelle Vinson began working for Meritor Savings Bank in 1974 as a teller-trainee. Her immediate supervisor, Sidney Taylor, was a vice president of the bank. Over the next four years, Vinson was promoted to teller, head teller, and then assistant branch manager. It was undisputed that her promotions were based on merit alone. In 1978, Vinson’s employment was terminated for excessive use of sick leave. Vinson then filed suit under Title VII against Taylor and the bank, alleging that she was subject to sexual harassment during her tenure in the job.
At trial, Vinson alleged that she had had sexual intercourse with Taylor on multiple occasions, out of fear of losing her job, and that he fondled her and made suggestive remarks to her any number of times. Taylor denied the allegations in their entirety and argued that Vinson’s accusations arose from a businessrelated dispute. The bank also denied Vinson’s allegations while specifically avowing that officials were unaware of Taylor’s behavior and that if he acted as Vinson alleged, he did so of his own volition.
The federal trial court for the District of Columbia held that Vinson was not the victim of sexual harassment, because the sexual relationship, if it existed, was voluntary. The District of Columbia Circuit reversed in favor of Vinson on the basis that if Taylor made Vinson’s toleration of sexual harassment a condition of her employment, the voluntary nature of the sexual relationship was irrelevant. The court also recognized that there were two categories of actionable sexual harassment under Title VII: harassment that conditions employment benefits on sexual favors (quid pro quo sexual harassment) and harassment that, while not affecting economic benefits, creates a hostile or offensive working environment (Hostile Work Environment harassment). Applying agency principles, the court decided that the bank was absolutely liable for sexual harassment arising from the actions of its supervisor, regardless of whether officials knew or should have known about the harassment.