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«Sexual Harassment »

Meritor Savings Bank v. Vinson 477 U.S. 57 (1986)

On March 25 1986, Mechelle Vinson filed a lawsuit against her former supervisor, Sidney Taylor. Mechelle Vinson was an employee at Meritor savings Bank, and Taylor was the Vice President of the bank. Vinson became an employee in 1974, after submitting her application to Mr. Taylor. She started as a teller trainee, but eventually graduated to a branch manager within her four years of employment at Meritor Saving Bank. There was no doubt that her gradual promotion was based on merit. In September 1978, Vinson informed Mr. Taylor that she was taking a sick leave for an indefinite period. Meritor Savings Bank discharged her for misuse of sick leave on November 1, 1978. This is when she brought litigation against Mr. Taylor for sexual harassment. The main issue in this case was, “whether a claim of ‘hostile environment’ sexual harassment was a form of sex discrimination that was actionable under Title VII of the Civil Rights Act of 1964” (Meritor Savings Bank v. Vinson 477 U.S. 57).

In her lawsuit, Vinson charged that Taylor had forced her to engage in a sexual relation with him, and that he had made several demands for sexual favors while at work. According to Vinson, she had more than 40 intercourses with Taylor. In addition, she stated that Taylor had attempted to touch her provocatively in public and had raped her several times. In her lawsuit, Vinson claimed that Taylor has violated the Civil Rights Act of 1964 – Title VII. She therefore sought an injunctive relief, compensation, and punitive damages against Meritor Savings Bank, and Taylor (Meritor Savings Bank v. Vinson 477 U.S. 57).

During the court hearings, the parties presented conflicting reports concerning existence of sexual relationship. Due to their conflicting testimonies, the District Court denied Vinson a relief, citing that the sexual relationship between her and Mr. Taylor was a voluntary one. Based on this, the District Court stated that Vinson was not a victim of sexual harassment, and that her continued employment at Meritor Savings Bank was not based on sexual relationship between her and the bank’s Vice President. The case was then put on hold. The District Court cited that since Meritor Savings Bank had not received any notice concerning the alleged sexual harassment by Taylor on Vinson, then it was not liable for his actions. However, the Court of Appeal reversed and remanded the ruling of the District Court.

During the court proceedings, the Court of Appeal stated that there are two types of sexual harassments that can be predicted as violations of Title VII of the Civil Right Act of 1964. These types of sexual harassment include harassment that involve demand for sexual favors in return for employment benefits and harassment that does not involve employment benefits but creates offensive or hostile working environment. Based on the plaintiff’s testimony, the Court of Appeals held that the grievance was under the second type of violation of Title VII. It therefore found it necessary to remand the case since the District Court had not previously established the type of violation that the grievance fell in. The Court of Appeals further held that employers are completely responsible for sexual harassment by their supervisory employees, regardless of whether they knew about the said harassment or not, since they ought to have known about it.

The majority ruling was based on the Court of Appeals final verdict concerning violation of Title VII of the Civil Rights Act of 1964. First, the Court of Appeals held that, “a claim of “hostile environment” sexual harassment is a form of sex discrimination that is actionable under title VII” (Meritor Savings Bank v. Vinson, 477 U.S 57). To interpret this, the court stated that violation of Title VII was not limited to “economic” or “tangible” harassment only. This explanation was based on the Employment Opportunity Commission Guidelines, which maintain that any form of sexual harassment leading to non-economic injury is a violation of Title VII. Therefore, based on the respondent’s testimony, the Court of Appeals found her accusations adequate to constitute a claim of ‘hostile environment’ sexual harassment. In addition, the Court of Appeals stated that the District Court did not have adequate findings to justify disposal of the respondent’s ‘hostile environment’ allegations. According to the Court of Appeals, it appeared that the District Court did not believe that sexual harassment in employment would occur without economic effects. Therefore, it had focused on the voluntariness of Ms. Vinson, instead of focusing on whether Ms. Vinson indicated to Mr. Taylor that his sexual advances were unwelcomed (Meritor Savings Bank v. Vinson, 477 U.S 57).

However, it was held that the Court of appeals had erroneously concluded that employers were responsible for sexual harassment actions committed by their supervisory employees. Instead, it was argued that while it may not be possible to transfer all principles of the law of agency to Title VII, Congress’s decision to include employment ‘agent’ in the definition of the term ‘employer,’ provides an objective way of preventing employers from being held responsible for all actions of their employees. During the court proceedings, the petitioner has claimed that failure of the respondent to follow a grievance procedure to report the allegation to the bank amounted to failure on her part. However, the Court of Appeals maintained that failure of the respondent to initiate a grievance procedure did not necessarily insulate the bank from the liability. Based on these rulings, the previous decision of the District Court was reversed, and the Court of Appeals remanded the case for more proceedings based on its opinion (Meritor Savings Bank v. Vinson, 477 U.S 57).

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In my opinion, the previous decision by the District Court to deny relief to the respondent was not justified. This is because the District Court had only relied on the testimony provided by the respondent and the petitioner to make its ruling. Furthermore, the District Court did not allow the respondent to bring witnesses, who the respondent alleged that the petitioner had sexually harassed them. In addition, the District Court only explored whether the respondent had voluntarily agreed to the alleged sexual demands from the petitioner, but failed to investigate whether the respondent had indicated to the petitioner that the alleged sexual advances were unwelcomed.

From my point of view, sexual advances or demands, which do not accompany economic or tangible benefits to an employee, are also forms of sexual harassment. This is because; such advances or demands create a hostile working environment to an employee. An employee may be unable to concentrate on his/her duties or responsibilities, due to the psychological effects that such demands or advances may have on him/her. In some instances, supervisors or other superior employees engage in sexual relations with subordinate employees of the opposite sex, even after the subordinate employees expresses to them that their sexual advances are not welcomed. Therefore, in lawsuits involving sexual harassment of subordinate employees by supervisors of the opposite sex, legal representatives should adequately explore the different circumstances surrounding such allegations. In addition, courts should not just base their judgments concerning sexual harassment on presence of economic or tangible benefits.

This case provides a clear connection to the aspects of competency. One of the aspects of competency is that organizations should provide their employees with organizational settings that respect their dignity, and that necessitate achievement of organizational goals. It is the duty and responsibility of supervisory personnel to provide such organizational setting to their subordinates. However, supervisors do have right to abuse their authority by imposing unwelcomed sexual advances on subordinate employees of the opposite sex. If a supervisor is found guilty of committing such an offense, there is no special rule even if the victim may fail to notify the employer since many grievance procedures start from the supervisors.



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