Mrs. Dade signed the card without reading it and without any sort of explanation from Taylor. 2577-2584 (1964). Id. 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. 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. 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. Before SILBERMAN, WILLIAMS and SENTELLE, Circuit Judges. In it, she claimed … 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. Unless otherwise stated hereon, the ownership of said account is pro-rata. . To relieve her anxiety, Taylor removed his name from the cover of her passbook with liquid paper. The nominal joint tenancy might be viewed simply as an attempted testamentary disposition. Rec. The court, for the first time, made sexual harassment an illegal form of discrimination.[2]. Over the next four years, Vinson was promoted to teller, head teller, and then assistant branch manager. [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. Under any of these analyses, Taylor's defense that he could not embezzle from himself fails. Atty., and Michael W. Farrell, Asst. 110 Cong. Mechelle Vinson began working for Meritor Savings Bank in 1974 as a teller-trainee. But he left the signature card unaltered and thus retained the ability to make withdrawals from the account without her consent. 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. 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. 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. The court rejected the claim, as the manager's opportunity to convert the funds arose from his position in the association. Vinson charged that she had constantly been subjected to sexual … When the mother died, the daughter claimed to be the sole owner of the house by operation of the right of survivorship. In the case, Meritor Savings Bank v. Vinson, No. 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. at 1209, 1211. 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. [5] Additionally, she testified that Taylor had touched her in public, exposed himself to her, and forcibly raped her multiple times. Her sexual harassment case would make legal history", "What About #UsToo? 87-00435-01). Link to 1986 Washington Post Article on the Trial: This page was last edited on 14 December 2020, at 13:26. 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. [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. Vinson had been fired from her job at Capital City Federal Savings Bank in Northeast Washington when she filed her lawsuit in 1978. [4] Reported cases following this court ruling include the highly publicized case of the Anita Hill and Clarence Thomas hearings.[4]. at 1211. 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. Of course the actual cash that he removed belonged to the bank (offset by a debt to Mrs. Dade) until the moment of his wrongful withdrawals. Within her four years at the bank, she was promoted from teller-trainee, to teller, head teller and then Assistant Manager. [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. 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. Id. Her supervisor was a man named Sidney Taylor. Appeal from the United States District Court for the District of Columbia (Criminal Action No. See, e.g., Webb v. United States, 369 F.2d 530, 535 (5th Cir. Circuit opinions. Id. If instead Mrs. Dade created a joint tenancy, we believe that Taylor's interest as joint tenant would be only the bare legal interest of a trustee, either by express or constructive trust. 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. 1980); see also Moore v. United States, 160 U.S. 268, 269, 16 S. Ct. 294, 295, 40 L. Ed. The trial court found that the mother intended that all of her nine children should have equal access to the home. The first initiation of … 657 (1982). A claim of "hostile environment" sexual harassment is a form of sex discrimination that is actionable under the Civil Rights Act of 1964. In 1974, Meritor Savings Bank hired Vinson as a teller. Thus there are several routes by which a jury could have rationally concluded that Taylor acquired no beneficial interest in the account. 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). Testimony of Emma Dade, at 24. 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. Taylor threatened to fire her if she refused his demands, she said. In the case, the branch manager of Meritor Savings Bank, Sidney L. Taylor, was accused by No special words are required to create an express trust--the settlor need only manifest an "intention to impose upon [herself] or upon a transferee of the property equitable duties to deal with the property for the benefit of another person." Michelle Vinson began working for Meritor Savings Bank in 1974 as atelier-trainee. 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." Wherever they worked, women were sexually harassed by male workers, foremen and bosses. 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. See, e.g., Richardson, 522 A.2d at 1298; Prather v. Hill, 250 A.2d 690, 691-93 (D.C.1969). 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. 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 Groves v. United States, 343 F.2d 850 (8th Cir. See for example. 24 (3d ed.1967). When respondent asked whether she might obtain employment at the bank, Taylor gave her an application, which she com- 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. Vinson charged that Taylor had coerced her to have sexual relations with him and made demands for sexual favors at work. at 856. The principal argument in … That year, she sued Taylor and the bank, which was later acquired by Meritor Savings. 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. 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. Vinson charged that Taylor had coerced her to have sexual relations with him and made demands for sexual favors at work. 3 Charles E. Torcia, Wharton's Criminal Law Sec. 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. 84-1979, Ms. Vinson said that she had initially refused sexual advances by Sidney L. Taylor, the … 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." 42 U.S. C. § 2000e-2(a)(1). 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. 419. 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. § 657 (1982).1 He is appealing his convictions on the ground that the prosecution failed to prove the necessary elements of embezzlement. [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. Trial Transcript, January 13, 1988, Testimony of Emma Dade, at 80. She argued such harassment created a \"hostile working environment\" and was covered by Title VII of the Civil Rights Act of 1964. 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. 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. 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. . [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. 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. Subscribe to Justia's Free Summaries 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. 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. 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. Vinson testified that Taylor subsequently invited her out to dinner and, during the course of the meal, suggested that they go to a motel to have sex. We affirm. 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. 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.". 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." 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. 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. 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. 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 case was the first of its kind to reach the Supreme Court and would redefine sexual harassment in the workplace. 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. at 23-24. 2d 560, reh'g denied, 444 U.S. 890, 100 S. Ct. 195, 62 L. Ed. 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. 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. of D.C. 1 Austin Wakeman Scott, The Law of Trusts Sec. 1965), the branch manager of a federal savings and loan association made a claim similar to Taylor's. Vinson had been fired from her job at Capital City Federal Savings Bank in Northeast Washington when she filed her lawsuit in 1978. § 657, which prohibits only misappropriation from a specified class of financial transactions. The case was the first of its kind to reach the Supreme Court and would redefine sexual harassment in the workplace. [7] Prior to the ruling on Vinson’s case, discrimination under Title VII was constituted as economic loss. 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." § 657 (1982). Sec. 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." 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. Patrick M. Donahue, appointed by the Court, Annapolis, Md., for appellant. Catharine A. MacKinnon, author of Towards a Feminist Theory of the State, was co-counsel for the respondent and wrote the respondent's brief. at 10. Vinson had worked at the Capital City Federal Savings Bank in Washington for four years before being fired. The Court pointed out that guidelines issued by the EEOC specified that sexual harassment leading to noneconomic injury was a form of sex discrimination prohibited by Title VII of the Civil Rights Act of 1964. Atty., Washington, D.C., were on the brief, for appellee. Sidney Taylor, who is still working at the same bank at the same job, has steadfastly denied every allegation, almost every word of Vinson's testimony. 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