[4] Vinson charged that Taylor had coerced her to have sexual relations with him and made demands for sexual favors at work. 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. Within her four years at the bank, she was promoted from teller-trainee, to teller, head teller and then Assistant Manager. 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. Vinson had been fired from her job at Capital City Federal Savings Bank in Northeast Washington when she filed her lawsuit in 1978. The prohibition against discrimination based on sex was added to Title VII at the last minute on the floor of the House of Representatives. In 1974, Meritor Savings Bank hired Vinson as a teller. 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 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. 24 (3d ed.1967). Vinson charged that she had constantly been subjected to sexual harassment by Taylor over her four years at the bank. 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. 395 (14th ed. of Justice, with whom Jay B. Stephens, U.S. See for example. Memorandum of Points and Authorities in Support of Defendant's Motion for Judgment of Acquittal, Attachment 1. § 657 (1982).1  He is appealing his convictions on the ground that the prosecution failed to prove the necessary elements of embezzlement. Patrick M. Donahue, appointed by the Court, Annapolis, Md., for appellant. It was undisputed that her promotions were based on merit alone. After taking sick leave in 1978, the bank discharged her for excessive use of that 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. 3 Charles E. Torcia, Wharton's Criminal Law Sec. 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. [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. 412. Vinson had been fired from her job at Capital City Federal Savings Bank in Northeast Washington when she filed her lawsuit in 1978. 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. 1980); see also Moore v. United States, 160 U.S. 268, 269, 16 S. Ct. 294, 295, 40 L. Ed. 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. The nominal joint tenancy might be viewed simply as an attempted testamentary disposition. at 23-24. [4] Reported cases following this court ruling include the highly publicized case of the Anita Hill and Clarence Thomas hearings.[4]. Because others hold the beneficial interest, a trustee can be guilty of embezzlement if he misappropriates trust funds to which he holds legal title. 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. The court, for the first time, made sexual harassment an illegal form of discrimination.[2]. 419. 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. Rec. . [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. 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. Taylor threatened to fire her if she refused his demands, she said. 3 Wharton's Criminal Law, at Sec. 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. Over the next four years, Vinson received several promotions, eventually becoming assistant branch manager. 1 He is appealing his convictions on the ground that the prosecution failed to prove the necessary elements of embezzlement. We affirm. Atty., and Michael W. Farrell, Asst. "[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. 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. 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. 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. 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. 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. 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. 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. She argued such harassment created a \"hostile working environment\" and was covered by Title VII of the Civil Rights Act of 1964. 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." The District cases cited above indicate that its courts would likely view the transaction as no more than a failed testamentary disposition. at 856. Taylor told her that his name appeared on the passbook because he was her administrator. 42 U.S. C. § 2000e-2(a)(1). Wherever they worked, women were sexually harassed by male workers, foremen and bosses. 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. Meritor Savings Bank v. Vinson 1986. Subscribe to Justia's Free Summaries Id. Michael Dreeben, Atty., Dept. The ruling of Mechelle Vinson’s Supreme Court case was the first instance of sexual harassment being recognized by the court as “actionable”. 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. 2577-2584 (1964). To relieve her anxiety, Taylor removed his name from the cover of her passbook with liquid paper. § 657, which prohibits only misappropriation from a specified class of financial transactions. 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. Sec. See, e.g., Webb v. United States, 369 F.2d 530, 535 (5th Cir. The case was the first of its kind to reach the Supreme Court and would redefine sexual harassment in the workplace. But he left the signature card unaltered and thus retained the ability to make withdrawals from the account without her consent. Appeal from the United States District Court for the District of Columbia (Criminal Action No. After being dismissed from her job at a Meritor Savings Bank, Mechelle Vinson sued Sidney Taylor, the Vice President of the bank. 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 3 Wharton's Criminal Law, at Sec. Although federal law defines the nature of this offense, federal courts look to state property laws in defining underlying concepts of ownership for the purpose of deciding whether a defendant violated a federal criminal statute aimed at protecting property. A review revealed that the determination of what constitutes "severe or pervasive conduct" is invariably based on an examination of the totality of circumstances. Her immediate supervisor, Sidney Taylor, was a vice president of the bank. Vinson sought injunctive relief along with compensatory and punitive damages against Taylor and the bank. In Groves v. United States, 343 F.2d 850 (8th Cir. 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." 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. 87-00435-01). 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). Vinson charged that she had constantly been subjected to sexual … Mrs. Dade signed the card without reading it and without any sort of explanation from Taylor. 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. Her sexual harassment case would make legal history", "What About #UsToo? 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 the mother died, the daughter claimed to be the sole owner of the house by operation of the right of survivorship. Sidney Taylor, Vice President of petitioner Meritor Savings Bank and Branch Manager hired Mechelle Vinson back in 1974. 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. Vinson sought injunctive relief along with compensatory and punitive damages against Taylor and the bank. 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. Michelle Vinson began working for Meritor Savings Bank in 1974 as atelier-trainee. In the case, the branch manager of Meritor Savings Bank, Sidney L. Taylor, was accused by In it, she claimed … See, e.g., Richardson, 522 A.2d at 1298; Prather v. Hill, 250 A.2d 690, 691-93 (D.C.1969). The first initiation of … Thus there are several routes by which a jury could have rationally concluded that Taylor acquired no beneficial interest in the account. US Court of Appeals for the District of Columbia Circuit. [1][2], It established the standards for analyzing whether conduct was unlawful and when an employer would be liable. 110 Cong. Id. The trial court found that the mother intended that all of her nine children should have equal access to the home. 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. He continued to do so, to cover overdrafts in his own checking account, until Meritor Savings officials discovered and stopped him. 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. Vinson charged that Taylor had coerced her to have sexual relations with him and made demands for sexual favors at work. 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." 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"). 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. [5] Additionally, she testified that Taylor had touched her in public, exposed himself to her, and forcibly raped her multiple times. 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. Her immediate supervisor, Sidney Taylor, was a vice president of the bank. Id. 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. 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. § 657 (1982). . 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.". 1 He is appealing his convictions on the ground that the prosecution failed to … The case was the first of its kind to reach the Supreme Court and would redefine sexual harassment in the workplace. The principal argument in … 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. 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. 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