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Questions and Answers
What was the main issue in the case of Meritor Savings Bank v. Vinson?
What does Title VII of the Civil Rights Act of 1964 prohibit?
Sex discrimination in employment.
In Harris v. Forklift Systems, what did Teresa Harris claim?
The court’s decision in Harris v. Forklift Systems focused solely on psychological harm.
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What two criteria must be met for a party to recover sexual harassment damages in Gebser v. Lago Vista School District?
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What was the basis for liability in Faragher v. City of Boca Raton?
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What does the anti-retaliation provision of Title VII protect?
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Study Notes
Meritor Savings Bank v. Vinson (1986)
- Mechelle Vinson sued Sidney Taylor, alleging sexual harassment during her employment at Meritor Savings Bank.
- Accusations of creating a "hostile working environment" fell under Title VII of the Civil Rights Act of 1964.
- Court ruled that Title VII encompasses both economic and non-economic discrimination.
- EEOC guidelines confirm that sexual harassment leading to non-economic injury is actionable under Title VII.
- Plaintiff must prove that conduct was severe, unwelcome, and based on gender to establish a hostile environment.
Harris v. Forklift Systems (1993)
- Teresa Harris claimed sexual harassment created an "abusive work environment" in violation of Title VII.
- The employer argued that the harassment lacked severity and did not psychologically impair her.
- The district court initially agreed, but the Sixth Circuit affirmed this decision.
- Justice Sandra Day O'Connor emphasized that focus should be on whether abuse was hostile rather than on psychological harm.
- Title VII's protections are not limited to conduct causing severe psychological effects; perception of hostility suffices.
Gebser v. Lago Vista School District (1998)
- Students cannot sue school districts for sexual harassment damages unless officials knew of the conduct and failed to act.
- Court ruled on necessity of two criteria: knowledge of abuse by an official and a deliberate failure to address it.
- The decision was narrow, emphasizing the need for accountability at the district level in cases of employee misconduct.
Faragher v. City of Boca Raton (1998)
- Beth Ann Faragher sued the City of Boca Raton, alleging her supervisors created a sexually hostile work environment.
- Court affirmed that employers are liable for discriminatory actions by supervisors under Title VII.
- A 7-2 decision clarified employer liability includes an affirmative defense based on reasonableness of employer response and victim's actions.
- Established the importance of employer responsibility in preventing and addressing harassment in the workplace.
Crawford v. Metropolitan Government of Nashville
- The Court held that Title VII's anti-retaliation provision protects individuals who speak out during an employer's internal investigation.
- Emphasis on employee cooperation with investigations as a protected activity under Section 704(a) of Title VII.
- Highlighted the broader scope of protections against retaliation beyond voluntary complaints.
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Description
Explore landmark cases related to sexual harassment under Title VII of the Civil Rights Act of 1964. This quiz delves into the details of Meritor Savings Bank v. Vinson and Harris v. Forklift Systems, highlighting key legal principles and court rulings. Test your knowledge on how the law defines hostile working environments and the implications for plaintiffs.