Constitutional Law
Vance v. Ball State University, 570 U.S. 421 (2013)
Study notes for Vance v. Ball State University: professor notes, cold call prep, exam angles, and memory aids.
An employee is a 'supervisor' under Title VII only if empowered by the employer to take tangible employment actions against the victim.
In Vance v. Ball State University, the Supreme Court addressed a pivotal issue regarding the definition of a 'supervisor' in the context of Title VII workplace harassment claims. The Court ruled that for an individual to qualify as a supervisor, they must have the authority to take 'tangible employment actions' against the plaintiff, such as hiring, firing, or making promotions, thereby establishing a clear limitation on the scope of employer liability for harassment. Professors often emphasize the importance of this case as it delineates the boundaries of employer responsibility under Title VII, highlighting the nuanced interpretation of employment relationships and responsibilities in the workplace.
Furthermore, the ruling emphasizes that mere oversight of an employee's work or the informal exercise of authority does not constitute supervisory status. This distinction is crucial for students to understand, as it impacts the strategic considerations for both plaintiffs and defendants in Title VII cases. In exams, a professor may encourage students to analyze the implications of this ruling on workplace dynamics and the role of management in preventing harassment.
Supervisor = Power to Fire (SPTF).
| Case | Distinction |
|---|---|
| Faragher v. Boca Raton | Faragher addressed employer liability for sexual harassment, but it focused on the concept of vicarious liability rather than defining a supervisor. |
| Burlington Industries, Inc. v. Ellerth | Ellerth involved the affirmative defense that employers could use in harassment cases, which relates to but is distinct from the supervisor definition established in Vance. |
| Jackson v. Birmingham Board of Education | Jackson dealt with retaliation against individuals for complaining of discrimination, not the definition of a supervisor in harassment claims. |
Limiting the definition of supervisor creates clear parameters for employer liability and encourages proper managerial training and oversight.
A narrow definition of supervisor might undermine protections for employees by allowing ongoing harassment to persist without employer accountability.
On exams, this case often appears in the context of Title VII discussions, specifically emphasizing the definition of 'supervisor' and its implications for employer liability.