Case Brief
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Meritor Savings Bank, FSB v. Vinson 447 U.S. 57 (1986).
Facts: Plaintiff, Mechelle Vinson, claims that while she was employed at Meritor Savings bank, she was sexually harassed by her supervisor, Sidney Taylor. Vinson started out as a teller-trainee, but soon promoted to teller, head teller, and assistant branch manager. Shortly after being hired, Vinson claims to have been sexually harassed and repeatedly asked for sexual favors from Taylor. Vinson claims that out of fear for her job, she eventually agreed. The sexual harassment was never reported to the bank by the plaintiff. Taylor denied the allegations of sexual activity, along with denying all other claims of harassment. The bank denied the plaintiff’s allegations and claimed any sexual harassment was unknown and not reported to them. The District Court denied relief to Vinson, saying if a sexual relationship did occur; it was voluntary and did not affect Vinson’s employment at the bank. As for the bank’s liability, the District Court stated that the bank could not be held liable because it was not informed of any allegations. The Court of Appeals reversed and remanded, adding that an employer is liable for sexual harassment by a supervisory personnel, even if they were unaware of it.
Rule: Violation of Title VII when one of the following occur:
harassment that involves the conditioning of the employment benefits on sexual favors
harassment that, while not affecting economic benefits, creates a hostile or offensive working environment
EEOC as Amici Curiae 26
“If the employer has an expressed policy against sexual harassment and has implemented a procedure specifically designed to resolve sexual harassment claims, and if the victim does not take advantage of that procedure, the employer should be shielded from liability absent actual knowledge of the sexually hostile environment.”
Issue: Whether or not the plaintiff, Vinson, experienced sexual harassment by supervisor, Taylor, during her time of employment which requires a violation of Title VII.
Whether Meritor Savings Bank should be held liable for sexual harassment being present in their company, which requires a violation of EEOC as Amici Curiae 26 whether or not the employer knew or should have known about it.
Holding: No, defendant Sidney Taylor