See, e.g., Webb v. United States, 369 F.2d 530, 535 (5th Cir. 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. Because others hold the beneficial interest, a trustee can be guilty of embezzlement if he misappropriates trust funds to which he holds legal title. [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. [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. at 10. Wherever they worked, women were sexually harassed by male workers, foremen and bosses. "[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. Unless otherwise stated hereon, the ownership of said account is pro-rata. 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. The first initiation of … [1][2], It established the standards for analyzing whether conduct was unlawful and when an employer would be liable. But he left the signature card unaltered and thus retained the ability to make withdrawals from the account without her consent. 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. In the case, the branch manager of Meritor Savings Bank, Sidney L. Taylor, was accused by Meritor Savings Bank v. Vinson 1986. When the mother died, the daughter claimed to be the sole owner of the house by operation of the right of survivorship. 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. 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. When respondent asked whether she might obtain employment at the bank, Taylor gave her an application, which she com- 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." After taking sick leave in 1978, the bank discharged her for excessive use of that leave. at 1211. Id. 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....". 3 Charles E. Torcia, Wharton's Criminal Law Sec. 24 (3d ed.1967). 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. Vinson had been fired from her job at Capital City Federal Savings Bank in Northeast Washington when she filed her lawsuit in 1978. Meritor Savings Bank v. Vinson, 477 U.S. 57, 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. 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"). Catharine A. MacKinnon, author of Towards a Feminist Theory of the State, was co-counsel for the respondent and wrote the respondent's brief. 1 He is appealing his convictions on the ground that the prosecution failed to … 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 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." 1 Austin Wakeman Scott, The Law of Trusts Sec. Vinson charged that Taylor had coerced her to have sexual relations with him and made demands for sexual favors at work. 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. She argued such harassment created a \"hostile working environment\" and was covered by Title VII of the Civil Rights Act of 1964. Title VII of the Civil Rights Act of 1964 makes it "an unlawful employment practice for an employer . To relieve her anxiety, Taylor removed his name from the cover of her passbook with liquid paper. The District cases cited above indicate that its courts would likely view the transaction as no more than a failed testamentary disposition. Patricia J. Barry – Argued the cause for the respondent Facts of the case After being dismissed from her job at a Meritor Savings Bank, Mechelle Vinson sued Sidney Taylor, the Vice President of the bank. Under any of these analyses, Taylor's defense that he could not embezzle from himself fails. We reject both arguments. The daughter was made a joint tenant on the deed so that her mother could more easily obtain financing. [7] Prior to the ruling on Vinson’s case, discrimination under Title VII was constituted as economic loss. 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. Atty., Washington, D.C., were on the brief, for appellee. 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.". 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. 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. He instead simply deposited the checks to accounts in his own name. at 856. Sec. 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. Over the next four years, Vinson was promoted to teller, head teller, and then assistant branch manager. 84-1979, Ms. Vinson said that she had initially refused sexual advances by Sidney L. Taylor, the … At that point, Mrs. Dade returned to the bank because "something told me to go back to the bank and to have [Taylor's name] taken off my [pass]books." 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. 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. 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. 2d 560, reh'g denied, 444 U.S. 890, 100 S. Ct. 195, 62 L. Ed. Vinson had worked at the Capital City Federal Savings Bank in Washington for four years before being fired. It was undisputed that her promotions were based on merit alone. In it, she claimed … 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 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. A review revealed that the determination of what constitutes "severe or pervasive conduct" is invariably based on an examination of the totality of circumstances. At oral argument, Taylor's counsel offered an alternative attack on the convictions, namely, that any funds embezzled did not belong to the bank. The principal argument in … [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. She argued such harassment created a '"hostile working environment'" and a form of unlawful discrimination under Title VII of the Civil Rights Act of 1964. [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. See 3 Wharton's Criminal Law, at Sec. Viewing the evidence in the light most favorable to the prosecution, as we must, see Jackson v. Virginia, 443 U.S. 307, 319, 99 S. Ct. 2781, 2789, 61 L. Ed. 1 He is appealing his convictions on the ground that the prosecution failed to prove the necessary elements of embezzlement. Mechelle Vinson began working for Meritor Savings Bank in 1974 as a teller-trainee. [4] Vinson charged that Taylor had coerced her to have sexual relations with him and made demands for sexual favors at work. Mrs. Dade decided to accept his offer because "he looked like an honest man working in the bank." Michael Dreeben, Atty., Dept. Her immediate supervisor, Sidney Taylor, was a vice president of the bank. of Justice, with whom Jay B. Stephens, U.S. 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 ruling of Mechelle Vinson’s Supreme Court case was the first instance of sexual harassment being recognized by the court as “actionable”. In the case, Meritor Savings Bank v. Vinson, No. The trial court found that the mother intended that all of her nine children should have equal access to the home. 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. to discriminate against any individual with respect to his compensation, terms, conditions, or privileges of employment, because of such individual's race, color, religion, sex, or national origin." 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. [4] Vinson charged that Taylor had coerced her to have sexual relations with him and made demands for sexual favors at work. Her immediate supervisor, Sidney Taylor, was a vice president of the bank. Id. 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. 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. . In Groves v. United States, 343 F.2d 850 (8th Cir. 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. Her sexual harassment case would make legal history", "What About #UsToo? The case was the first of its kind to reach the Supreme Court and would redefine sexual harassment in the workplace. 3 Wharton's Criminal Law, at Sec. Subscribe to Justia's Free Summaries The nominal joint tenancy might be viewed simply as an attempted testamentary disposition. 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. Vinson charged that she had constantly been subjected to sexual … 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. Atty., and Michael W. Farrell, Asst. US Court of Appeals for the District of Columbia Circuit. The court, for the first time, made sexual harassment an illegal form of discrimination.[2]. 42 U.S. C. § 2000e-2(a)(1). 395 (14th ed. § 657 (1982). U.S. After being dismissed from her job at a Meritor Savings Bank, Mechelle Vinson sued Sidney Taylor, the Vice President of the bank. Before SILBERMAN, WILLIAMS and SENTELLE, Circuit Judges. Taylor asked Mrs. Dade if she wanted him to serve as "administrator" for such an arrangement. 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. 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. 657 (1982). 412. The prohibition against discrimination based on sex was added to Title VII at the last minute on the floor of the House of Representatives. 419. In 1974, Meritor Savings Bank hired Vinson as a teller. of D.C. Trial Transcript, January 13, 1988, Testimony of Emma Dade, at 80. Taylor threatened to fire her if she refused his demands, she said. at 1209, 1211. [5] Additionally, she testified that Taylor had touched her in public, exposed himself to her, and forcibly raped her multiple times. Vinson sought injunctive relief along with compensatory and punitive damages against Taylor and the bank. 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." . [4] This number of reported cases rose to 2,217 in 1990 and then 4,626 by 1995. Her supervisor was a man named Sidney Taylor. 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. See, e.g., Richardson, 522 A.2d at 1298; Prather v. Hill, 250 A.2d 690, 691-93 (D.C.1969). See for example. 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. Instead, she wished the account arranged so that the money would go to her church after her death to be used "to feed the hungry and the poor." § 657 (1982).1  He is appealing his convictions on the ground that the prosecution failed to prove the necessary elements of embezzlement. A correctly charged jury--and neither at trial nor here has Taylor challenged the instructions--could readily find that Mrs. Dade created an express trust for the benefit of her church. [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. 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. 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. 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. 110 Cong. But, even though the signature card described the account as a joint tenancy with right of survivorship, we do not believe that the transactions actually created such a relationship between Mrs. Dade and Taylor. Taylor then prepared a joint account form with right of survivorship bearing his and Mrs. Dade's names and transferred $29,805.07 from her old account into the new one. Taylor told her that his name appeared on the passbook because he was her administrator. 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. Link to 1986 Washington Post Article on the Trial: This page was last edited on 14 December 2020, at 13:26. Richardson v. District of Columbia, 522 A.2d 1295, 1298 (D.C.1987) (quoting Harrington v. Emmerman, 186 F.2d 757, 761 (D.C. Cir. 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). 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. Over the next four years, Vinson received several promotions, eventually becoming assistant branch manager. The manager argued that he had breached only his duty to the depositor. 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. 1980); see also Moore v. United States, 160 U.S. 268, 269, 16 S. Ct. 294, 295, 40 L. Ed. 1965), the branch manager of a federal savings and loan association made a claim similar to Taylor's. Appeal from the United States District Court for the District of Columbia (Criminal Action No. 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. 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. Vinson sought injunctive relief along with compensatory and punitive damages against Taylor and the bank. Thus there are several routes by which a jury could have rationally concluded that Taylor acquired no beneficial interest in the account. The case was the first of its kind to reach the Supreme Court and would redefine sexual harassment in the workplace. Taylor is correct in his general proposition that, because the property converted by an embezzler must belong to another, a defendant cannot embezzle property he owns jointly. 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. In Gray v. Gray, 412 A.2d 1208 (D.C.1980), the court used this remedy in a joint tenancy situation similar to the situation before us. at 23-24. Vinson had been fired from her job at Capital City Federal Savings Bank in Northeast Washington when she filed her lawsuit in 1978. Id. Id. We affirm. Memorandum of Points and Authorities in Support of Defendant's Motion for Judgment of Acquittal, Attachment 1. Action No of Points and Authorities in Support of Defendant 's Motion for Judgment of Acquittal, Attachment 1 a. In Support of Defendant 's Motion for Judgment of Acquittal, Attachment 1 of (... 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