Meritor Savings Bank v. Vinson, decided in 1986, marked the first time the Supreme Court considered a sexual harassment case under Title VII. The case involved a female employee at a bank who alleged she was forced to have sex by her supervisor, fearing the loss of her job if she refused. The evidence showed the employee had repeatedly advanced through the bank by merit, that she had never filed a complaint about the supervisor’s behavior, and that she was terminated only because of lengthy sick leave absence. Yet the Supreme Court ruled that she had a case against her former employer on the basis of hostile environment sexual harassment.
For sexual harassment to be actionable, the court declared, it must be “sufficiently severe or pervasive to alter the conditions of [the victim’s] employment and create an abusive working environment.” In this case, the Court held, the facts were “plainly sufficient to state a claim for’hostile environment’ sexual harassment.” The Court also added that on the facts of the case, the plaintiff had a claim for quid pro quo sexual harassment as well.
The Meritor case was a landmark for sexual harassment rights in that it established the legal legitimacy of both quid pro quo and hostile environment sexual harassment claims before the Supreme Court. It also rejected the idea that there could be no sexual harassment just because the sexual relations between the plaintiff and the defendant were voluntary. The results opened a floodgate of sexual harassment litigation.