Vance v. Ball State University, 570 U.S. 421 (2013)
Vance v. Ball State University is a landmark decision by the United States Supreme Court, which significantly delineated the definition of 'supervisor' under Title VII for purposes of vicarious liability in workplace harassment cases.
Who qualifies as a 'supervisor' in Title VII workplace harassment cases?
For Title VII purposes, a 'supervisor' is someone empowered by the employer to take tangible employment actions, meaning to effect a 'significant change in employment status,' against the victim.
The Supreme Court held that an employee is a 'supervisor' under Title VII only if he or she is empowered by the employer to take tangible employment actions against the victim.
The case is significant for law students and practitioners as it clarifies the scope of Title VII regarding supervisor liability. The decision restricts the category of employees whose actions can lead to automatic liability for an employer, potentially reducing the number of claims in which employers are automatically liable. Understanding this definition is crucial for evaluating potential harassment claims and advising clients on best practices for preventing harassment in the workplace.