## Facts

- Mechelle Vinson worked for Meritor Savings Bank from 1974 to 1978, rising from teller-trainee to assistant branch manager under supervisor Sidney Taylor.
- Vinson alleged that Taylor repeatedly demanded sexual favors and subjected her to ongoing sexual harassment during her employment, including sexual touching and coerced sexual acts.
- Vinson asserted she submitted out of fear of losing her job and did not complain to higher management because she feared retaliation.
- The bank denied knowledge of the alleged conduct and argued that any misconduct would have been outside the scope of employment.
- Vinson sued under Title VII, seeking relief based on a hostile work environment theory.

## Issues

1. Whether Title VII’s ban on discrimination “because of sex” includes hostile work environment sexual harassment absent tangible economic or job-benefit injury.
2. Whether an employer is automatically liable for sexual harassment committed by a supervisor, or whether liability depends on traditional agency principles.

## Decision

- The Supreme Court unanimously held that hostile work environment sexual harassment is actionable under Title VII even without economic or tangible job detriment.
- The Court rejected a rule of automatic employer liability for supervisor harassment and required courts to assess employer liability using traditional agency principles.
- The Court vacated the judgment and remanded for further proceedings under the proper standards.

## Legal Principles

- Title VII is not confined to economic or tangible employment actions; severe or pervasive sex-based harassment that alters the conditions of employment and creates an abusive environment can violate the statute.
- The central inquiry in sexual harassment is whether the conduct was unwelcome; “voluntariness” is not the controlling test.
- Employer liability for supervisor harassment is not governed by per se rules of immunity or automatic liability; agency principles guide the analysis, and lack of notice does not necessarily bar liability.
- A nondiscrimination policy and grievance procedure, and an employee’s failure to use them, do not by themselves resolve employer liability.

## Conclusion

The Court recognized hostile work environment sexual harassment as a form of sex discrimination under Title VII and required employer responsibility for supervisor harassment to be determined through agency-based, fact-specific analysis rather than automatic liability rules.


Meritor Savings Bank, FSB v. Vinson, 477 U.S. 57 (1986)