2012-09-27 18:12:47 by admin
Meritor Savings Bank v. Vinson: Facts of the Case
On further review, the Supreme Court, in an opinion by Justice Rehnquist, affirmed that allegations of sexual harassment under Title VII may include Hostile Work Environment claims and are not limited to economic benefits. The Court thus decided that a claim of “Hostile Work Environment” sex discrimination is actionable under Title VII. At the heart of its analysis, the Supreme Court noted that there are five elements in claims of sex discrimination based on the existence of a Hostile Work Environment, an offense that is ordinarily established by a series of incidents. The criteria can also apply in cases of quid pro quo harassment.
The Court noted that the first element in Hostile Work Environment sex discrimination claims is that plaintiffs must belong to a protected category. Insofar as most suits are filed by women, the Court indicated that this element is satisfied when women file claims. Second, the Court explained that plaintiffs must have been subjected to unwelcome sexual advances. The Court added that the correct inquiry into sexual harassment claims is not based on whether plaintiffs’ participation was voluntary but whether it was unwelcome. To this end, the justices were thus satisfied that the trial court had not erred in allowing evidence about Vinson’s sexually provocative dress and speech, because such evidence could prove useful in evaluating whether the sexual behaviors at the center of the dispute were welcome or unwelcome.
Third, the Supreme Court indicated that the harassment must have been based on sex. Fourth, the Court was of the opinion that the harassment must have affected a term, condition, or privilege of employment to such a degree that it created a Hostile Work Environment. In other words, the treatment must have been so pervasive as to alter working conditions to the point that, under the totality of the circumstances, it seriously affects plaintiffs’ psychological well-being. The fifth element that the Court identified was that employers knew or should have known of the harassment but failed to take prompt remedial action to resolve situations.
Even though the Supreme Court set the standards for evaluating whether Hostile Work Environment harassment occurred, it stopped short of definitely imposing liability on the bank. Insofar as it rejected the appellate panel’s disregard for the general principles of agency in imposing absolute liability on the bank for the acts of one of its supervisors, the Court remanded this part of the dispute for further consideration.