On July 29, 1986 Emma Dade, an 83-year-old widow, visited Meritor Savings, a federally insured savings bank, to discuss changes she wished to make in an account she held jointly with her brother. At oral argument, his counsel appeared to advance a slightly different argument, suggesting that any embezzlement was of Mrs. Dade's property, not the bank's; thus, he could not have violated 18 U.S.C. Vinson charged that she had constantly been subjected to sexual harassment by Taylor over her four years at the bank. Alternatively, either by way of express or constructive trust, one might view Mrs. Dade and Taylor as holding the legal title as trustees in joint tenancy, with an equitable life estate in Mrs. Dade and an equitable remainder in her church. The Court held that Title VII was "not limited to 'economic' or 'tangible' discrimination" and found that the intention of Congress was "'to strike at the entire spectrum of disparate treatment of men and women' in employment....". Michelle Vinson began working for Meritor Savings Bank in 1974 as atelier-trainee. Sec. Moreover, in gauging the totality of circumstances, lower courts typically focus on some or all of the following four factors: Title VII of the Civil Rights Act of 1964, List of United States Supreme Court cases, volume 477, Hostile Advances: The Kerry Ellison Story, "She said her boss raped her in a bank vault. The District applies a presumption that "when a depositor creates a joint account for [herself] and another, without consideration, it is presumed to have been done for the convenience of the depositor." In November 1978 Vinson was fired from her job at a Meritor Savings Bankwhich Taylor explained as being due to Vinson's inordinate use of sick leave. In it, she claimed that during the four years she worked at the bank, the branch manager, Sidney L. Taylor, repeatedly sexually assaulted her - once forcing her to the floor in the bank vault. [4] The first initiation of Vinson's civil lawsuit against Sidney L. Taylor and Capital City Federal Savings and Loan Association, which would soon change its name to Meritor Savings Bank, came in September of 1978. See 3 Wharton's Criminal Law, at Sec. Within her four years at the bank, she was promoted from teller-trainee, to teller, head teller and then Assistant Manager. The Court pointed out that guidelines issued by the EEOC specified that sexual harassment leading to noneconomic injury was a form of sex discrimination prohibited by Title VII of the Civil Rights Act of 1964. Rehnquist, joined by Burger, White, Powell, Stevens, O'Connor, Marshall, joined by Brennan, Blackmun, Stevens, the level of offensiveness of the unwelcome acts or words, the frequency or pervasiveness of the offensive encounters, the total length of time over which the encounters occurred, the context in which the harassing conduct occurred. of Justice, with whom Jay B. Stephens, U.S. [1][2], It established the standards for analyzing whether conduct was unlawful and when an employer would be liable. Id. 412. Vinson had been fired from her job at Capital City Federal Savings Bank in Northeast Washington when she filed her lawsuit in 1978. Catharine A. MacKinnon, author of Towards a Feminist Theory of the State, was co-counsel for the respondent and wrote the respondent's brief. Taylor threatened to fire her if she refused his demands, she said. Atty., and Michael W. Farrell, Asst. Patrick M. Donahue, appointed by the Court, Annapolis, Md., for appellant. Meritor Savings Bank, FSB V. Vinson 1986 2 Meritor Savings Bank, FSB v. Vinson (1986) Meritor Saving Bank, FSB v. Vinson was the first case of sexual harassment to reach the US Supreme Court. Vinson had worked at the Capital City Federal Savings Bank in Washington for four years before being fired. In such instances the funds are delivered up to the agent solely for the purpose of performing a function within the apparent scope of his authority which would inure to the benefit of the drawer of the funds, if deposited in the Association as contemplated by fact and law. The primary question presented was whether a hostile work environment constituted a form of unlawful discrimination under the Civil Rights Act of 1964,[6] or if the Act was limited to tangible economic discrimination in the workplace. Link to 1986 Washington Post Article on the Trial: This page was last edited on 14 December 2020, at 13:26. Meritor Savings Bank v. Vinson 1986. Courts impose a constructive trust to redress the injustice that would otherwise occur when one person has fraudulently or wrongfully obtained the property of another. 1966) (permitting defendant to offer evidence of joint ownership under state law against charge of interstate transportation of stolen motor vehicle). If instead Mrs. Dade created a joint tenancy, we believe that Taylor's interest as joint tenant would be only the bare legal interest of a trustee, either by express or constructive trust. A review revealed that the determination of what constitutes "severe or pervasive conduct" is invariably based on an examination of the totality of circumstances. Taylor told her that his name appeared on the passbook because he was her administrator. After taking sick leave in 1978, the bank discharged her for excessive use of that leave. 419. In it, she claimed … Mrs. Dade signed the card without reading it and without any sort of explanation from Taylor. Vinson charged that Taylor had coerced her to have sexual relations with him and made demands for sexual favors at work. Although the statute does not define the offense of embezzlement, a standard definition is that a defendant commits it "when, being in lawful possession of the property of another, he fraudulently appropriates or converts such property to his own use with the intent permanently to deprive." The overwhelming evidence at trial indicated that Mrs. Dade did not intend to give Taylor any beneficial interest in the funds: she did not read the card, was not told of its contents, never intended to establish a joint tenancy account, and allowed Taylor's name to be placed on the passbook only so that he could function as her "administrator.". Her sexual harassment case would make legal history", "What About #UsToo? She claimed that for the next two and one-half years Mr. Taylor repeatedly demanded sex from her and otherwise harassed her physically and verbally. The case was the first of its kind to reach the Supreme Court and would redefine sexual harassment in the workplace. A jury found Sidney L. Taylor, formerly a branch manager of Meritor Savings Bank, guilty of embezzling, abstracting or purloining $22,400 from a customer's account, in violation of 18 U.S.C. Subscribe to Justia's Free Summaries US Court of Appeals for the District of Columbia Circuit. Id. Atty., Washington, D.C., were on the brief, for appellee. She approached Taylor, the branch manager, whom she knew only through her visits to the bank, and told him that she wanted to remove her brother's name from the account because he had recently entered a nursing home. In 1974, respondent Mechelle Vinson met Sidney Taylor, a vice president of what is now petitioner Meritor Savings Bank (bank) and manager of one of its branch offices. Circuit opinions. See, e.g., Webb v. United States, 369 F.2d 530, 535 (5th Cir. at 1209, 1211. 1 He is appealing his convictions on the ground that the prosecution failed to … The Court recognized that the plaintiff, Mechelle Vinson, could establish violations of the Act "by proving that discrimination based on sex has created a hostile or abusive work environment. Distilling the essence of that case and several others, the court wrote: [T]he opportunity to convert the funds arises by virtue of the defendant's position as the agent of a concern to which the public is invited to entrust its money, and it is in the integrity thereof which the public has confidence. Appeal from the United States District Court for the District of Columbia (Criminal Action No. Meritor Savings Bank v. Vinson, 477 U.S. 57 (1986), is a US labor law case, where the United States Supreme Court, in a 9-0 decision, recognized sexual harassment as a violation of Title VII of the Civil Rights Act of 1964. [4] Reported cases following this court ruling include the highly publicized case of the Anita Hill and Clarence Thomas hearings.[4]. Id. 110 Cong. [4] Vinson charged that Taylor had coerced her to have sexual relations with him and made demands for sexual favors at work. Vinson sought injunctive relief along with compensatory and punitive damages against Taylor and the bank. Her immediate supervisor, Sidney Taylor, was a vice president of the bank. In Groves v. United States, 343 F.2d 850 (8th Cir. In 1974, at the age of 19, Mechelle Vinson, a black woman,[3] was hired as a teller-trainee at the northeast branch of Capitol City Federal Savings and Loan Association in Washington D.C.[4] Vinson reported that by May of 1975 her supervisor, Sidney L. Taylor, began what would be 3 years of recurring sexual harassment while in the workplace. [7] This court case articulated that the creation of a hostile work environment is a form of discrimination and economic loss is not required in violating Title VII. The ruling of Mechelle Vinson’s Supreme Court case was the first instance of sexual harassment being recognized by the court as “actionable”. 2577-2584 (1964). He instead simply deposited the checks to accounts in his own name. The prohibition against discrimination based on sex was added to Title VII at the last minute on the floor of the House of Representatives. Memorandum of Points and Authorities in Support of Defendant's Motion for Judgment of Acquittal, Attachment 1. In 1974, at the age of 19, Mechelle Vinson, a black woman, was hired as a teller-trainee at the northeast branch of Capitol City Federal Savings and Loan Association in Washington D.C. Vinson reported that by May of 1975 her supervisor, Sidney L. Taylor, began what would be 3 years of recurring sexual harassment while in the workplace. U.S. Before SILBERMAN, WILLIAMS and SENTELLE, Circuit Judges. 2 * In 1974, respondent Mechelle Vinson met Sidney Taylor, a vice president of what is now petitioner Meritor Savings Bank (bank) and manager of one of its branch offices. Title VII of the Civil Rights Act of 1964 makes it "an unlawful employment practice for an employer . 657 (1982). A jury found Sidney L. Taylor, formerly a branch manager of Meritor Savings Bank, guilty of embezzling, abstracting or purloining $22,400 from a customer's account, in violation of 18 U.S.C. § 657 (1982).1  He is appealing his convictions on the ground that the prosecution failed to prove the necessary elements of embezzlement. Wherever they worked, women were sexually harassed by male workers, foremen and bosses. In his brief to this court, Taylor attacks his convictions on the ground that as a joint tenant, he had an ownership right in the money he appropriated; thus, the property taken was not the "property of another." of D.C. Testimony of Emma Dade, at 24. Rec. [5] Additionally, she testified that Taylor had touched her in public, exposed himself to her, and forcibly raped her multiple times. Trial Transcript, January 13, 1988, Testimony of Emma Dade, at 80. That year, she sued Taylor and the bank, which was later acquired by Meritor Savings. In 1974, respondent Mechelle Vinson met Sidney Taylor, a vice president of what is now petitioner Meritor Savings Bank (bank) and manager of one of its branch offices. Meritor Savings Bank v. Vinson, 477 U.S. 57 (1986), is a US labor law case, where the United States Supreme Court, in a 9-0 decision, recognized sexual harassment as a violation of Title VII of the Civil Rights Act of 1964. Sidney Taylor, Vice President of petitioner Meritor Savings Bank and Branch Manager hired Mechelle Vinson back in 1974. Within two hours after creating the new joint account, Taylor had withdrawn $3,500; he made two more withdrawals totaling $5,000 in the next two weeks. The daughter was made a joint tenant on the deed so that her mother could more easily obtain financing. A jury found Sidney L. Taylor, formerly a branch manager of Meritor Savings Bank, guilty of embezzling, abstracting or purloining $22,400 from a customer's account, in violation of 18 U.S.C. When respondent asked whether she might obtain employment at the bank, Taylor gave her an application, which she com- Vinson charged that Taylor had coerced her to have sexual relations with him and made demands for sexual favors at work. In it, she claimed … He had received checks, payable to the association, on the strength of his promises that he could make special arrangements by which the depositor would receive a higher than usual rate of return. The court rejected this characterization and affirmed the trial court's order imposing a constructive trust on the property for the benefit of the daughter, now the constructive trustee, and her eight siblings. The case was the first of its kind to reach the Supreme Court and would redefine sexual harassment in the workplace. [4] Vinson charged that Taylor had coerced her to have sexual relations with him and made demands for sexual favors at work. The first initiation of Vinson's civil lawsuit against Sidney L. Taylor and Capital City Federal Savings and Loan Association, which would soon change its name to Meritor Savings Bank, came in September of 1978. § 657 (1982). Vinson sought injunctive relief along with compensatory and punitive damages against Taylor and the bank. 2d 560, reh'g denied, 444 U.S. 890, 100 S. Ct. 195, 62 L. Ed. The nominal joint tenancy might be viewed simply as an attempted testamentary disposition. [7] Additionally, this case ruled that the sexual conduct between Taylor and Vinson could not be deemed voluntary due to the hierarchical relationship between supervisor and subordinates in the workplace. To relieve her anxiety, Taylor removed his name from the cover of her passbook with liquid paper. A mother and her daughter had purchased a home as joint tenants, using the proceeds of the mother's sale of a home evidently owned by her and her estranged husband. 42 U.S. C. § 2000e-2(a)(1). The manager argued that he had breached only his duty to the depositor. 1965), the branch manager of a federal savings and loan association made a claim similar to Taylor's. In 1974, respondent Mechelle Vinson met Sidney Taylor, a vice-president of what is now petitioner Meritor Savings Bank (bank) and manager of one of its branch offices. Thus there are several routes by which a jury could have rationally concluded that Taylor acquired no beneficial interest in the account. 1950)).2  The presumption is merely a judicial inference as to probable intent, and can be rebutted by extrinsic evidence that the depositor intended to make a gift of a present beneficial interest. [7], Following the ruling of Meritor Savings Bank v. Vinson, reported sexual harassment cases grew from 10 cases being registered by the EEOC per year before 1986 to 624 case being reported in the subsequent following year. The District cases cited above indicate that its courts would likely view the transaction as no more than a failed testamentary disposition. Id. 1980); see also Moore v. United States, 160 U.S. 268, 269, 16 S. Ct. 294, 295, 40 L. Ed. Moreover, and we think it critical here, Taylor's ability to make the withdrawals arose entirely from his position with the bank; it was that position that enabled him to prevail on Mrs. Dade to name him as joint holder of the account. In the case, the branch manager of Meritor Savings Bank, Sidney L. Taylor, was accused by 422 (1895) (defining the offense, in accordance with English common law, as "the fraudulent appropriation of property by a person to whom such property has been entrusted, or into whose hands it has lawfully come"). Her supervisor was a man named Sidney Taylor. The signature card for the new account, on which Taylor wrote both names, described the ownership arrangement as follows: As joint tenants with the right of survivorship and not as tenants in common and not as tenants by the entirety, the undersigned hereby apply for a savings account in MERITOR SAVINGS BANK, FSB.... [The savings bank is] hereby authorized to act without further inquiry in accordance with writings bearing [the accompanying] signatures; it being understood and agreed that any one of the undersigned may act in all matters related to this savings account. Clearly Taylor was not less guilty of embezzlement from the bank than Groves merely because he actually created an account bearing Mrs. Dade's name (as well as his own). Whoever, being an officer, agent or employee of ... any institution the accounts of which are insured by the Federal Savings and Loan Insurance Corporation ... embezzles, abstracts, purloins or willfully misapplies any moneys, funds, credits, securities or other things of value belonging to such institution, or pledged or otherwise intrusted to its care, shall be fined not more than $5,000 or imprisoned not more than five years, or both; but if the amount or value embezzled, abstracted, purloined or misapplied does not exceed $100, he shall be fined not more than $1,000 or imprisoned not more than one year, or both. The first initiation of … § 657, which prohibits only misappropriation from a specified class of financial transactions. 24 (3d ed.1967). Vinson charged that she had constantly been subjected to sexual … At oral argument, Taylor's counsel offered an alternative attack on the convictions, namely, that any funds embezzled did not belong to the bank. It was undisputed that her promotions were based on merit alone. [7] This ruling also qualified the hostile environment which sexual harassment in the workplace creates as sex discrimination under Title VII of the Civil Rights Act of 1964. In 1974, Meritor Savings Bank hired Vinson as a teller. The court rejected the claim, as the manager's opportunity to convert the funds arose from his position in the association. Even if Mrs. Dade's words and actions were not sufficient to create an express trust, a court could protect her interests (both in the property during her lifetime and in its disposition thereafter) by treating Taylor as a constructive trustee. The first initiation of Vinson's civil lawsuit against Sidney L. Taylor and Capital City Federal Savings and Loan Association, which would soon change its name to Meritor Savings Bank, came in September of 1978. Id. 2d 126 (1979), we find that any rational trier of fact could have found the essential elements of the crime beyond a reasonable doubt, id. : The Invisibility of Race in the #MeToo Movement", "Sexual Harassment and the Law: The Mechelle Vinson Case", https://en.wikipedia.org/w/index.php?title=Meritor_Savings_Bank_v._Vinson&oldid=994176784, United States Supreme Court cases of the Burger Court, United States employment discrimination case law, United States gender discrimination case law, Creative Commons Attribution-ShareAlike License. at 10. [4] This number of reported cases rose to 2,217 in 1990 and then 4,626 by 1995. . [4] In November 1978 Vinson was fired from her job at a Meritor Savings Bank which Taylor explained as being due to Vinson's inordinate use of sick leave. "[4] A Plaintiff with hostile environment-styled claims must prove that the challenged conduct was severe or pervasive, created a hostile or abusive working environment, was unwelcome, and was based on the plaintiff’s gender. Lawyers who handle such cases say there has been a flood of new claims since June 19, when the Supreme Court decided its first sexual harassment case, Meritor Savings Bank v. Vinson. During that time, she claimed that the branch manager, Sidney L. Taylor, repeatedly sexually assaulted her — once forcing her to the floor in the bank vault. Taylor asked Mrs. Dade if she wanted him to serve as "administrator" for such an arrangement. We do not reach the government's alternative argument that the conviction can be sustained because the evidence at trial showed that Taylor had "abstracted or purloined" the funds. Of course the actual cash that he removed belonged to the bank (offset by a debt to Mrs. Dade) until the moment of his wrongful withdrawals. 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