Case Brief Meritor Sav
Meritor Sav. Bank v. Vinson, 477 US 57 (1986)
Facts:
After being terminated a female bank employee filed an action under Title VII of the Civil Rights Act of 1964, 42 U.S.C.S. §2000e et seq., claiming that she had been sexually harassed by her male supervisor. The US Supreme Court ruled that if the actions of the supervisor were unwelcome, than the respondent had a claim for sexual harassment on the basis of a hostile work environment, even if the sexual acts were voluntary.
Issues:
(1) Whether a corporate employer is automatically liable under Title VII if they have no prior knowledge of the alleged discrimination.
(2) Whether a hostile work environment based on sexual harassment can be established ….
Holding:
In a 9/0 decision, the United States Supreme Court declared that A claim of "hostile environment" sexual harassment is a form of sex discrimination that is actionable under Title VII. Pp. 477 U. S. 63-69.
Rationale:
(a) The language of Title VII is not limited to "economic" or "tangible" discrimination. Equal Employment Opportunity Commission Guidelines fully support the view that sexual harassment leading to non-economic injury can violate Title VII. Here, respondent's allegations were sufficient to state a claim for "hostile environment" sexual harassment. Pp. 477 U. S. 63-67.
(b) The District Court's findings were insufficient to dispose of respondent's "hostile environment" claim. The District Court apparently erroneously believed that a sexual harassment claim will not lie absent an economic effect on the complainant's employment, and erroneously focused on the "voluntariness" of respondent's participation in the claimed sexual episodes. The correct inquiry is whether respondent by her conduct indicated that the alleged sexual advances were unwelcome, not whether her participation in them was voluntary. Pp. 477 U. S. 67-68.
(c) The District Court did not err in admitting evidence of respondent's sexually provocative speech and dress. While
Facts:
After being terminated a female bank employee filed an action under Title VII of the Civil Rights Act of 1964, 42 U.S.C.S. §2000e et seq., claiming that she had been sexually harassed by her male supervisor. The US Supreme Court ruled that if the actions of the supervisor were unwelcome, than the respondent had a claim for sexual harassment on the basis of a hostile work environment, even if the sexual acts were voluntary.
Issues:
(1) Whether a corporate employer is automatically liable under Title VII if they have no prior knowledge of the alleged discrimination.
(2) Whether a hostile work environment based on sexual harassment can be established ….
Holding:
In a 9/0 decision, the United States Supreme Court declared that A claim of "hostile environment" sexual harassment is a form of sex discrimination that is actionable under Title VII. Pp. 477 U. S. 63-69.
Rationale:
(a) The language of Title VII is not limited to "economic" or "tangible" discrimination. Equal Employment Opportunity Commission Guidelines fully support the view that sexual harassment leading to non-economic injury can violate Title VII. Here, respondent's allegations were sufficient to state a claim for "hostile environment" sexual harassment. Pp. 477 U. S. 63-67.
(b) The District Court's findings were insufficient to dispose of respondent's "hostile environment" claim. The District Court apparently erroneously believed that a sexual harassment claim will not lie absent an economic effect on the complainant's employment, and erroneously focused on the "voluntariness" of respondent's participation in the claimed sexual episodes. The correct inquiry is whether respondent by her conduct indicated that the alleged sexual advances were unwelcome, not whether her participation in them was voluntary. Pp. 477 U. S. 67-68.
(c) The District Court did not err in admitting evidence of respondent's sexually provocative speech and dress. While