In 2005, Davis returned to the Banquet and Catering Division as a Catering Specialist, where she was responsible for supervising and providing leadership for kitchen assistants and substitutes. What Vance v. Ball State means for Future Employee Harassment Cases Ball State means for Future Employee Harassment Cases An employee at Ball State University came forward and claimed she was the victim of workplace harassment by someone she perceived as her supervisor. Additionally, Ball State believes that application of a new standard by the Supreme Court would be helpful for the lower courts that will have to apply the standard in the future. Workplace harassment based on race, color, national origin, religion or sex is prohibited by Title VII. If you would like to learn how Lexology can drive your content marketing strategy forward, please email enquiries@lexology.com. To anyone who has followed American labor law in the last fifteen years or so, the recent decision of the Supreme Court in Vance v. Ball State University is full of irony. Rather, the parties agree that one with the authority to oversee the work of others on a daily basis could count as a supervisor. In November 2005, Vance reported that McVicker had called her a “porch monkey,” and in December 2005 Vance complained that Davis glared at her and slammed pots and pans around her. VANCE v. BALL STATE UNIVERSITY ET AL. In its brief, Ball State goes on to argue that, even with a broader definition of supervisor under Title VII, Davis would not fall into that category. Although workplace harassment falls outside the scope of an employee’s work, the Supreme Court has held employers liable where the employee’s supervisory role enabled the harassment. The clinic will face Gregory Garre, a former U.S. solicitor general, who is representing Ball State University. National Partnership asserts that supervisor harassment derives from the overall employment environment, and that harassment will not end without employers making structural changes. Vance filed this lawsuit in the United States District Court for the Southern District of Indiana, claiming that she had been subjected to a racially hostile work environment in violation of Title VII, and arguing that Davis was her supervisor and that BSU was liable for Davis' creation of a racially hostile work environment. United States Court of Appeals for the Seventh Circuit, Ball State University Banquet and Catering Division. In May 2006, Vance alleged that Davis blocked her way at the elevator. Both Vance and Ball State assert that the Seventh Circuit definition of “supervisor” does not meet the realities of the workplace and is too restrictive; however, the parties disagree how supervisor should be defined and whether the new definition could include the facts of this case. In response to investigations into McVicker’s behavior, Ball State skipped a verbal warning and issued McVicker a written warning on November 11, 2005. What do … In Vance v. Ball State University, the Court narrowed the definition of “supervisor.” This is important because plaintiffs can win in Title VII cases only if they suffer discrimination from a supervisor, not from a peer in the workforce. Please contact customerservices@lexology.com. On June 24, 2013, the Supreme Court decided Vance v. Ball State University, No. She first worked as a substitute server, but she became a part-time catering assistant in 1991 and a full-time catering assistant in 2007. As a result, Ball State maintains that the Supreme Court, if it expands the definition, should simply apply this new standard to Davis rather than remand the case to a lower court. The traditional definition of what a Submitting a brief in favor of neither party, the Federal Government observes that the definition of supervisor should mirror the definition provided by the Equal Employment Opportunity Commission (“EEOC”). As the Supreme Court noted in Faragher v. City of Boca Raton, 524 U.S. 775, 806 (1998), the purpose of Title VII is not “to provide redress but to avoid harm.” Consequently, potential liability under Title VII increases employers’ incentives to monitor supervisors and create systems for which employees can file complaints. The Supreme Court’s Decisions in Ellerth and Faragher. 11–556. If Vance wins, the definition of supervisor under Title VII will expand to include more than just those who can hire, fire, demote, promote, or discipline an employee. 23 Justice Alito was joined by Chief Justice Roberts and Justices Scalia, Kennedy, and Thomas. Among other things, Title VII of the Civil Rights Act of 1964 makes it unlawful for an employer to engage in discriminatory practices based on its employees’ race. In August 2007, Vance reported that Davis taunted her by asking, “Are you scared?” and referenced the prior slapping incident. Faragher v. Boca Raton, 524 U.S. 775 (1998); Under standard conceptions of employer liability, an employer is liable for harms caused by an employee—the employer’s agent—provided the harm arose from the employee’s work for the employer. The United States notes that the EEOC definition of a supervisor focuses on the power an individual may have over another and whether or not the individual is in the “supervisory chain of command.” As a result, the United States asserts, the EEOC definition of a supervisor also includes control over daily work activities. She first worked as a substitute server, but she became a part-time catering assistant in 1991 and a full-time catering assistant in 2007. Additionally, the parties both point to guidelines generated by the EEOC. The conflict between Davis and Vance resumed on September 23, 2005 when Davis blocked Vance from exiting an elevator, saying, “I’ll do it again,” referencing the prior slapping incident. If Ball State wins, there will still be an increased focus on immediate supervisors; however, the definition of control over daily work assignments will be more restricted. Throughout this time, Vance was consigned to “entry level duties” and when both Vance and Davis were in the kitchen, Davis could assign Vance certain duties, but usually work assignments came from the chef. On June 24, 2013, the Supreme Court decided Vance v. Ball State University, No. Craig Oliver, vice-chair of the Bradley Arant Boult Cummings Labor and Employment Practice, was quoted by Law360 on the U.S. Supreme Court ruling in Vance v.Ball State University that found only employees with the authority to hire, fire or promote others should count as supervisors in Title VII harassment suits. Get Vance v. Ball State University, 133 S. Ct. 2434 (2013), United States Supreme Court, case facts, key issues, and holdings and reasonings online … Vance filed complaints with BSU and charges with the Equal Employment Opportunity Commission related to her interactions with a fellow BSU employee, Saundra Davis, who is white. Vance notified her employer about the incident, but she did not pursue a formal complaint because shortly thereafter Davis transferred to another department to accept a full-time position. Justice Alito delivered the opinion for the Court, in which Chief Justice Roberts and Justices Scalia, Kennedy, and Thomas joined. The Court held in Clinton v. Jones , 520 U.S. 681 (1997), that federal criminal subpoenas do not rise to the level of constitutionally forbidden impairment of the Executive’s ability to perform its constitutionally mandated functions, and here, it rejected the President’s argument that state criminal subpoenas pose a unique and greater threat. Ball State’s limits on what would make someone a supervisor is more restrictive; however, Ball State argues that the limiting principles narrow the focus to individuals actually exercising supervisory authority. In this case, the Supreme Court will resolve a circuit split on whether one must have the power to hire, fire, demote, promote, transfer, or discipline the victim of racial discrimination to qualify as a supervisor for purposes of employer liability under Title VII. The Seventh Circuit noted that, unlike other circuits, it did not consider the authority over an employee’s daily work sufficient to make one a supervisor. Justice Thomas filed a concurring opinion. Petitioner Maetta Vance is an African-American woman who worked as a catering assistant for Ball State University (BSU). Vance filed the action against Ball State in October 2006; however, the district court granted Ball State’s motion for summary judgment. Vance v Ball State University - Vance v Ball State University Issue Vance who is an African American woman Ball State University alleging that her Vance v Ball State University Issue: Vance, who is an African American woman, Ball State University alleging that her fellow employee Sandra Davis created a racially hostile work environment in violation of Title Vll. Understand your clients’ strategies and the most pressing issues they are facing. The district court found that Ball State could not be liable for Davis’s actions as a supervisor under Title VII because Davis did not have the power to hire, fire, demote, promote, transfer, or disciple Vance, and the periodic authority to direct the work of other employees did not make Davis a supervisor. Jan 31 2012 Reply of petitioner Maetta Vance filed. Prior to the Vance v. Ball State case, the law surrounding the definition of a “supervisor” was vague, but essentially relied on the traditional sense that the defense utilized in their argument. 11-556, holding that an employee is a "supervisor" for purposes of vicarious liability under Title VII of the Civil Rights Act of 1964 only if the person is empowered by the employer to take tangible employment actions against the victim of workplace harassment. From a policy perspective, National Partnershipasserts that Title VII is less effective if it only applies to high-level supervisors and not to supervisors who control workers’ daily activities. Conversely, Ball State advocates broadening the Seventh Circuit definition, but it argues that the definition should be based upon the workplace realities rather than titles. Details: Vance v. Ball State University Posted Mon, June 24th, 2013 11:34 am by Kevin Russell This is an important employment law case that has been eagerly anticipated since it was argued in late November. Overall, if Vance wins, there will likely be an increased focus on immediate supervisors because directing daily work assignments increases the potential for and impact of abuse. 11–556. Vance v. Ball State University, 570 U.S. 421 (2013), is a U.S. Supreme Court case regarding who is a "supervisor" for the purposes of harassment lawsuits. Argued November 26, 2012—Decided June 24, 2013 Under Title VII, an employer’s liability for i.e. In this case, the parties assert that a less restrictive reading of supervisor for the purposes of Title VII would be more consistent with those principles. 2011). Rather, according to the EEOC definition, a supervisor could also be one with the power to “direct the employee’s daily work activities.” The United States notes that the EEOC is the federal agency in charge of enforcing Title VII so the Court should give some weight to its interpretation of the statute. Automation law & tech construction - 5 ways of knowing the real scope of the work, Visa free visits to the Schengen countries - how to count 90 days within six months, 6 key questions to answer when analyzing project delays, Supreme Court decides Erica P. John Fund, inc. v. Halliburton co. et al, Illinois and New York state tax treatment of domestic partner health coverage, Supreme Court limits definition of “supervisor” under Title VII, A victory for employers: the Supreme Court narrows employer vicarious liability under Title VII, Supreme Court Narrows "Supervisor" Standard - and Employer's Liability - for Title VII Work Place Harassment Claims. Further, National Partnership argues that expanding employer liability to include direct supervisors will increase employer incentives to create better harassment policies, improve training, and improve monitoring. Because there was no evidence that BSU empowered Davis to take any tangible employment action against Vance, the Court affirmed the judgment against Vance's claims. After investigating Davis’s behavior, Ball State found no basis to take disciplinary action, but formally warned Davis for her August 2007 comments. Vance asserted that Davis was a supervisor although Ball State claimed Davis was not actually Vance’s supervisor. Factors germane to daily supervision include: actual control over daily work activities, the victim’s knowledge of control over their daily work activities, a lack of on-the-scene access to a higher ranking employee for the victim, and temporary control of daily work activities, which only creates liability if the harm occurs during the temporary period. Today the Supreme Court’s decision in Vance v. Ball State University reset the rule for when an employer may be held vicariously liable for an employee’s harassment. In the context of the Court's previous decisions in Ellerth and Faragher, however, the term was adopted to describe a class of employees whose misconduct may give rise to vicarious liability, and it described employees who "could bring the official power of the enterprise to bear on subordinates." Justice Ginsburg filed a dissenting opinion in which Justices Breyer, Sotomayor, and Kagan joined. In determining whether a given employee is a supervisor, the parties both stress that a court should look to the functioning work relationship. Both parties agree that this functional role may give rise to the very abuses that Title VII sought to combat. Vance v. Ball State University, No. The Court has concluded that Title VII incorporated principles of agency law in its allocation of liability to employers for their employees’ conduct. By contrast, Vance argues that the Supreme Court should simply reverse the Seventh Circuit’s decision and remand the case. Rebecca voluntarily goes for a motorcycle ride with Steve, who is obviously drunk. The District Court entered summary judgment in favor of BSU, finding that BSU could not be held vicariously liable for Davis' alleged racial harassment because Davis was not a supervisor. Learn vocabulary, terms, and more with flashcards, games, and other study tools. Party name: Maetta Vance v. Ball State University, et al. Keep a step ahead of your key competitors and benchmark against them. Title VII makes it unlawful for an employer to discriminate against any individual on the basis of race, including by creating a racially hostile work environment. In the decision below, the Seventh Circuit held that actionable harassment by a person whom the employer deemed a “supervisor” and who had the authority to direct and oversee the victim's daily work could not give rise to vicarious liability because the harasser did not also have the power to take formal employment actions against her. The District Court and Court of Appeals for the Seventh Circuit determined that Davis was not Vance’s supervisor because Davis did not have the power to direct the terms and conditions of Vance’s employment. Additionally, Ball State counseled Vance and Davis in an attempt to improve their working relationship. § 2000e–2(a)(1) Under Title VII, the employer may be liable for the improper actions of its employees; however, the standard that a court will apply to the employer depends on whether the employee was a supervisor of the victim or merely a co-worker. Tangible employment actions include hiring and firing an employee or changing an employee’s work assignments. The selection feature during registration helps in increasing the relevance of the content of the emails. The district court also held that Ball State had properly addressed every complaint filed by Vance and that the actions of the university were reasonable to prevent future harassment. As an alternative to this closed list, the Court may decide that the daily oversight of the victim’s work is enough to make one a supervisor under the statute. The next generation search tool for finding the right lawyer for you. Also in September 2005, Vance was told that co-worker Connie McVicker had bragged about McVicker’s family ties to the Ku Klux Klan and referred to Vance using a racial slur. Introducing PRO ComplianceThe essential resource for in-house professionals. Vance began working for the Ball State University Banquet and Catering Division of University Dining Services in 1989. VANCE v. BALL STATE UNIVERSITY ET AL. Title US Supreme Court Defines Supervisor Vance v Ball State University.pub Author gloverr Created Date 7/26/2014 11:42:04 AM Keywords () According to Vance, the Second Circuit definition is much broader, and it could cover all individuals given authority by the employer over the employee. Become your target audience’s go-to resource for today’s hottest topics. The term "supervisor," wrote the Court, has "varying meanings both in colloquial usage and in the law." Argued November … Kimes investigated each of these incidents and after the May 2006 incident, Kimes and other managers tried to separate Vance and Davis. I would recommend it to other attorneys.”, © Copyright 2006 - 2020 Law Business Research. Thus, National Partnership argues that a more expansive definition of supervisor will increase employer accountability and decrease harassment. Rejecting the open-ended approach advocated by the EEOC's Enforcement Guidance, which ties supervisor status to the ability to exercise significant discretion over another's daily work, the Court agreed with the Seventh Circuit and held that the employer must have empowered the employee with the ability to take tangible employment actions against the victim, such as hiring, firing, promoting, or disciplining. Questions? Both parties acknowledge that the power over an employee’s daily work could enable harassment. Ultimately, the Chamber of Commerce asserts that expanding employer liability too far creates a catch-22 between overly broad, yet ineffective, and narrow, yet effective, preventative measures. Around the same time, Vance overheard Davis refer to her with epithets like “Sambo” and “Buckwheat,” and she occasionally did so in the presence of other employees. Rae T. Vann Norris Tysse Lampley & Lakis LLP (202) 629-5600 1501 M Street, N.W., Suite 400 Washington, DC … The question presented is: Whether, as the Second, Fourth, and Ninth Circuits have held, the Faragher and Ellerth “supervisor” liability rule (i) applies to harassment by those whom the employer vests with authority to direct and oversee their victim's daily work, or whether, as the First, Seventh, and Eighth Circuits have held, the rule (ii) is limited to those harassers who have the power to “hire, fire, demote, promote, transfer, or discipline” their victims. university may not consider race unless held to strict scrutiny diversity shouldn't be the only reason for 11-556. Additionally, both courts found that Ball State had an adequate system in place for reporting and investigating claims of harassment under Title VII and thus the university could not be negligent. The Seventh Circuit ruled that, in this context, a “supervisor” is restricted to employees with the power to hire, fire, promote, transfer, or discipline other employees. The Seventh Circuit affirmed the district court ruling, holding that Davis was not Vance’s superior because she lacked the ability to hire, fire, demote, promote, transfer, or discipline Vance. If Ball State wins, the definition of supervisor under Title VII may expand; however, it would likely be limited to persons who actually control an employee’s daily activities. The Seventh Circuit concluded that Vance did not demonstrate that Davis had the requisite control over Vance to qualify as a supervisor, so the court therefore considered Davis as Vance’s co-worker. The theory behind this substitute liability for the employer is that a worker who is the victim of workplace bias is less likely to challenge a supervisor than a fellow employee, because of what the supervisor might do in response. Indeed, the Court’s new, narrow definition of “supervisor” does not simply limit the liability of companies in discrimination cases. Both parties highlight the possibility that the particularly close contact between employee and supervisor could provide the opportunity for greater abuse. Vance filed suit in October 2006, alleging hostile working environment and retaliation claims under Title VII. Title VII does not define “supervisor,” and there is no clear authority distinguishing between co-workers and supervisors. Feb 1 2012 DISTRIBUTED for Conference of February 17, 2012. According to Ball State, Davis did not have control over Vance’s daily work; further, Vance did not definitively consider Davis to be her supervisor. They’re easy to understand and I appreciate that they are only as long as necessary to cover the essentials. On June 24, 2013, the Supreme Court decided Vance v.Ball State University, No. Vance notes that this is the Supreme Court’s usual practice, and the Court should not deviate from it here. The case before the Court, Vance v. Ball State University , takes this question into consideration. (2013) No. Sometime before 2001, Vance and co-worker Saundra Davis engaged in an oral altercation that ended with Davis’s slapping Vance in the head. The Supreme Court upheld the Seventh Circuit's decision in a 5–4 opinion written by Samuel Alito, rejecting the Equal Employment Opportunity Commission's interpretation of who counts as a supervisor. The Seventh Circuit affirmed because its settled precedent requires a supervisor to have "the power to hire, fire, demote, promote, transfer, or discipline an employee.". Additionally, both parties argue that the Court should adopt the approach used by the Second Circuit in determining whether an employee is a supervisor, which turns on whether an employee’s authority over the victim gave rise to and facilitated the improper treatment. Brief of respondent Ball State University in opposition filed. Sometime before 2001, Vance and co-worker Saundra Davis engaged in an oral altercation that ended with Davis’s slapping Vance in the head. 11-556, holding that an employee is a "supervisor" for purposes of vicarious liability under Title VII of the Civil Rights Act of 1964 only if the person is empowered by the employer to take tangible employment actions against the victim of workplace harassment. The Supreme Court granted certiorari and affirmed. Vance began working for the Ball State University Banquet and Catering Divisionof University Dining Services in 1989. CERTIORARI TO THE UNITED STATES COURT OF APPEALS FOR THE SEVENTH CIRCUIT No. Petitioner Maetta Vance contends that Saundra Davis, a catering specialist, had made Vance’s life at work contentious through physical acts and racial harassment. Feb 21 2012 The Solicitor General is invited to file a To win a lawsuit for co-worker harassment under Title VII of the Civil Rights Act of 1964, it is necessary to show that the employer is negligent in responding to complaints about harassment; however, to win a lawsuit for harassment by a supervisor, the employer does not have to be negligent because Title VII imputes the supervisor’s acts to the employer. Finding an employer liable for unlawful harassment by supervisors is now more difficult. If Vance and Ball State agree and see the EEOC guidance as fitting within the Second Circuit’s restriction on liability to situations where the supervisory role enabled the improper treatment. If the harasser was the victim's co-employee, however, the employer is not liable absent proof of negligence. This meaning is both easy to administer and adapted to its purpose. The Chamber of Commerce argues employers’ resources will be stretched too thin without knowing where to focus training and monitoring. 11-556 Argued: November 26, 2012 Decided: June 24, 2013 Under Title VII, an employer's liability for workplace harassment may depend on the status of the harasser. Both Vance and Ball State assert that a “supervisor” under Title VII is not limited to those employees with the powers enumerated by the Seventh Circuit. As the Seventh Circuit noted, if a supervisor is responsible for creating an abusive workplace environment based upon harassment, then the employer is responsible for the supervisor’s acts under Title VII. Overall, it is very likely that this decision will expand the Seventh Circuit definition of “supervisor;” however, the Supreme Court will decide how broad the definition should be and whether or not there will be limiting principles that provide further guidance regarding how the definition may be limited. In 1998, the Supreme Court decided two cases, Faragher v. City of Boca Raton and Burlington Industries, Inc. v. Ellerth , that found when an employee is harassed by another employee, the employer's liability depends on the status of the harassing employee. According to Vance, the district court should engage in a new round of fact-finding in order to better apply any new standard that the Supreme Court announces. 42 U.S.C. The Court provided a definition and test for a supervisor that will fit in with the Faragher and Ellerth analysis in employment law matters. Power up your legal research with modern workflow tools, AI conceptual search and premium content sets that leverage Lexology's archive of 900,000+ articles contributed by the world's leading law firms. Vance v. Ball State Ball State An employee is a "supervisor" for purposes of vicarious liability under Title VII of the Civil Rights Act only if he is empowered by the employer to take tangible employment actions against the victim. In Vance v. Ball State University, decided June 24, 2013, a sharply divided (5-4) Supreme Court rejected the EEOC’s broad definition of “supervisor” in favor of a more restrictive definition. “I have found the articles in Lexology/Newsstand to be closely related to the topics I am interested in. In addressing the realities of the workplace and their relevance to the statute, the Court’s decision has the potential to expand employers’ liability for the unlawful conduct of their employees. 22 Vance v. Ball State Univ., 646 F.3d 461, 470 (7th Cir. Vance v. Ball State University case arose. Week 1 Case Analysis Read the information about the Supreme Court Decides Vance v. Ball State University case and answer the following questions: 1. Vance advocates expanding the definition of supervisor either by finding the Seventh Circuit definition to be too narrow or by explicitly adopting the definition used by the U.S. Second Circuit Court of Appeals. Vance notified her employer about the incident, but she did not pursue a formal complaint because shortly thereafter D… But if the hostile environment flows from an individual's "supervisor," an employer can be held vicariously liable for the supervisor's actions, making it easier for the individual to prove liability. Vance sued her employer, respondent Ball State University, for workplace harassment by a supervisor. The overall employment environment, and that harassment will not end without employers making structural changes drive content. 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