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Keywords

liabilitysummary judgmentharassmentvicarious liability
liabilitydiscriminationharassmentvicarious liability

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Vance v. Ball State Univ.

Facts

The African-American employee was working for the employer as a full-time catering assistant when a white catering specialist allegedly harassed her. The catering specialist did not have the power to hire, fire, demote, promote, transfer, or discipline the employee. The employee alleged that the catering specialist was her supervisor. The Supreme Court determined that the employer was properly granted summary judgment as to the employee's Title VII racially hostile work environment claim because (1) an employee was a 'supervisor' for purposes of vicarious liability under Title VII if he or she was empowered by the employer to take tangible employment actions against the victim, and (2) there was no evidence that the employer empowered the catering specialist to take any tangible employment actions against the employee.

Maetta Vance, an African-American woman, began working for Ball State University (BSU) in 1989 as a substitute server in the University Banquet and Catering division of Dining Services. In 1991, BSU promoted Vance to a part-time catering assistant position, and in 2007 she applied and was selected for a position as a full-time catering assistant. Over the course of her employment with BSU, Vance lodged numerous complaints of racial discrimination and retaliation, but most of those incidents are not at issue here. For present purposes, the only relevant incidents concern Vances interactions with a fellow BSU employee, Saundra Davis.

Issue

Who qualifies as a 'supervisor' in a case in which an employee asserts a Title VII claim for workplace harassment?

In this case, we decide a question left open in Burlington Industries, Inc. v. Ellerth, 524 U.S. 742, 118 S. Ct. 2257, 141 L. Ed. 2d 633 (1998), and Faragher v. Boca Raton, 524 U.S. 775, 118 S. Ct. 2275, 141 L. Ed. 2d 662 (1998), namely, who qualifies as a 'supervisor' in a case in which an employee asserts a Title VII claim for workplace harassment?

Rule

An employee is a 'supervisor' for purposes of vicarious liability under Title VII if he or she is empowered by the employer to take tangible employment actions against the victim.

We hold that an employee is a 'supervisor' for purposes of vicarious liability under Title VII if he or she is empowered by the employer to take tangible employment actions against the victim, and we therefore affirm the judgment of the Seventh Circuit.

Analysis

The court applied the rule by examining whether the catering specialist had the authority to take tangible employment actions against the employee. It found that the catering specialist lacked such authority, as she could not hire, fire, demote, promote, transfer, or discipline the employee. Therefore, the court concluded that the catering specialist was not a supervisor under Title VII, and the employer could not be held vicariously liable for her actions.

The court explained that BSU could not be held vicariously liable for Davis`alleged racial harassment because Davis could not 'hire, fire, demote, promote, transfer, or discipline' Vance and, as a result, was not Vances supervisor under the Seventh Circuits interpretation of that concept.

Conclusion

The Supreme Court affirmed the judgment of the Seventh Circuit, holding that the employer was not liable for the alleged harassment because the harasser was not a supervisor.

The Supreme Court affirmed the judgment of the Seventh Circuit, holding that the employer was not liable for the alleged harassment because the harasser was not a supervisor.

Who won?

Ball State University prevailed in the case because the court found that the catering specialist was not a supervisor and thus the employer could not be held vicariously liable for her actions.

Ball State University prevailed in the case because the court found that the catering specialist was not a supervisor and thus the employer could not be held vicariously liable for her actions.

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