Meritor Savings Bank V Johnson Case Summary

Analysis: The Civil Rights Act of 1964, Title VII, forbids “an employer to … discriminate against any individual with respect to his compensation, terms, conditions, or privileges of employment, because of such individual’s … sex.” Civil Rights Act, 1964. In Meritor Savings Bank v. Vinson, the court held that “a plaintiff may establish a violation of Title VII by proving that discrimination based on sex has created a hostile or abusive work environment.” Meritor Savings Bank v. Vinson (US 1986). A hostile work environment is created when the environment at work creates anxiety so severe as to result in an alteration of the terms and conditions of employment. Hailey Course Pack, p. 140. The burden to prove such an environment was created rests on the plaintiff. The plaintiff must prove that they belong to a protected class; were subject to unwelcomed harassment; the harassment is based on sex, meaning it is not happening to members of the opposite sex; and the harassment alters the conditions of employment. Hailey Course Pack, p. 140. In this case, the court will evaluate whether Black has sufficient evidence to prove her claim of a hostile work environment. Black must first prove that she belongs to a protected class under the Civil Rights Act. The protected classes include race, national origin, color, religion, and sex. Hailey Course Pack, p. 140. “Sex” has been
Black does not offer any evidence indicating the comments interfered with her ability to perform her job and never reported the comments for being offensive to her. She did not report the incident of the alleged touch of her buttocks until the day she quit her job. Considering the four factors altogether, Black cannot prove that the conduct affected the terms and conditions of employment. In comparison