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An Analysis Of Vance V. Ball State University

1353 words - 5 pages

Supervisory responsibilities vary among the multitude of available jobs in the market; however, there are certain functions that exist in all jobs. Supervisors must decide when to hire, fire, promote, discipline, or transfer an employee. For example, it is fairly simple to identify a Chief Probation Officer with a defined title and responsibility; however, enthusiastic employees working toward professional development may be selected to handle progressively responsible tasks within an organization. Many business managers may choose to delegate tasks to those employees, thereby graying the structured lines of responsibility. As those lines diminish, organizations become vulnerable to violation of employee civil rights. In review of the Supreme Court case of Vance v. Ball State (2013), we examine Title VII of the Civil Rights Act of 1964 and whether employers may be vicariously liable for subordinate actions when the employer is not directly involved in the creation of a hostile work environment. We will review the case’s journey to the Supreme Court, analyze the Court’s rationale in deciding that Ball State University was not vicariously liable for Vance’s alleged hostile work environment, and discuss the impact of that decision on human resource managers.
In 2006, Maetta Vance filed a lawsuit against Ball State University in the United States District Court of the Southern District of Indiana. Ms. Vance, an African-American woman, claimed that Ball State University was responsible for a coworker’s creation of a hostile work environment. Ms. Vance worked for Ball State University as a catering assistant and served that department since 1989. She was promoted in 1991, from substitute server to part-time catering assistant, and again in 2007, from part-time to full time catering assistant. While serving the catering department, Ms. Vance filed several complaints of racial discrimination with the University. Ball State attempted to resolve those complaints, but Vance decided to sue on the basis of a racially hostile work environment that was created by coworker Saundra Davis, a white female employed by Ball State University as a catering assistant. Vance named Davis as her supervisor in the formal complaint and alleged that Ball State University was liable for Davis’ actions. The district court ruled in favor of Ball State stating that the university was not vicariously liable since Davis was not actually a supervisor and could take no employment action against Vance. Vance petitioned the United States Supreme Court and argued the case November 26, 2012. On June 24, 2013 the Court held that Ball State University was not vicariously liable for Vance’s workplace harassment under Title VII of the Civil Rights Act of 1964 (Vance v. Ball State University, 570 U.S. ___, 2013).
Next we will analyze the Supreme Court’s rationale for ruling in favor of Ball State University. There are several legal documents that are used to evaluate the circumstances in...

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