Title VII Sexual Harassment Cases

Study Notes

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.

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.

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.

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.

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.