Vance v. Ball State University (2013) was a Supreme Court case that clarified the standard for determining who qualifies as a "supervisor" for purposes of employer liability under Title VII of the Civil Rights Act of 1964. The case involved Maetta Vance, an African American employee who worked as a catering assistant at Ball State University. Vance alleged that she had been subjected to racial and sexual harassment by her co-workers and that her supervisor, Saundra Davis, had not taken any action to stop the harassment. Vance filed a lawsuit against Ball State University, alleging that the university was liable for the harassment under Title VII.
The university argued that Davis was not Vance's supervisor, but rather a co-worker, and therefore the university could not be held liable for the harassment. The Supreme Court agreed with the university and held that an employee is a supervisor if they have the power to take tangible employment actions against the victim, such as hiring, firing, promoting, or demoting. The Court also held that an employee who only has the power to direct and oversee the victim's daily work is not a supervisor.
This case was important because it clarified the standard for determining who qualifies as a supervisor for purposes of employer liability under Title VII. The court established that employers can only be held liable for harassment committed by supervisors who have the power to take tangible employment actions against the victim. This decision is important because it could limit the number of cases in which an employer could be held liable for harassment by a co-worker. However, it also means that employers should be extra vigilant in identifying and training those employees who have such power, to prevent and correct any discriminatory harassment and discrimination.