After she was fired from her job at Capital City Federal Savings and Loan (later Meritor Savings Bank), Mechelle Vinson sued the Washington, D.C., bank and its vice president Sidney Taylor. Vinson alleged that Taylor had coerced her into a sexual relationship with him and made demands for sexual favors at work.
Initially, Vinson said, she turned down Taylor’s advances but eventually agreed to the relationship because she feared for her job. She alleged that during her time at the bank Taylor coerced her to have sex dozens of times both during and after business hours. Additionally, she said Taylor fondled her and other women who worked there.
She argued such harassment created a ‘hostile working environment’, violating Title VII of the Civil Rights Act of 1964.
The bank denied all knowledge of Taylor’s alleged misbehavior, and the district court initially said Vinson hadn’t experienced discrimination because her relationship with Taylor had been voluntary.
Vinson had joined the bank as trainee-teller in 1974, with Taylor as her direct supervisor. She received several promotions, becoming an assistant branch manager. She was fired in 1978 over excessive leave. No one disputed the legitimacy of Vinson’s promotions. The question was whether or not the sexual relationship she had with Taylor during her employment at the bank had been consensual, and if not, whether the ‘hostile working environment’ it created constituted a violation of the Civil Rights Act.
The Supreme Court ruled that creation of a hostile or abusive work environment did constitute a violation of the act’s prohibition on sex-based discrimination in the workplace. The court also set the standard that, when considering sexual harassment claims, the important distinction lay not in whether a sexual relationship was voluntary, but whether such sexual advances were unwelcome.
The Supreme Court didn’t rule definitively on the employer’s liability. It did note that having a nondiscrimination policy and a grievance procedure – which Vinson had failed to use – didn’t protect Meritor from liability. The court criticized the bank’s nondiscrimination policy, which did not specifically address sexual harassment, and noted that the grievance procedures required employees to notify supervisors, which in this case would have been Taylor.
The Supreme Court sent the case back to the lower court to determine the precise nature of Vinson and Taylor’s relationship. Vinson later settled her case against Taylor and the bank out of court.