Vance v. Ball State University Case Brief Summary | Law Case Explained
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Vance v. Ball State University | 133 S. Ct. 2434 (2013)
Under Title Seven of the Civil Rights Act of 1964, employers can be vicariously liable for discrimination by supervisors. But who exactly is a supervisor? That was the question in Vance versus Ball State University.
Maetta Vance, an African American woman, worked in the catering division at Ball State University. Her job title was catering assistant. Saundra Davis, a white woman, worked in the same division as a catering specialist. Her job responsibilities included leading and directing kitchen staff.
Starting in 2005, Vance began filing complaints of racial harassment and discrimination with Ball State and the Equal Employment Opportunity Commission, or EEOC. She claimed that Davis was giving her a hard time at work. Davis reportedly glared at her, banged pots and pans, gave her weird looks, blocked her on an elevator, and smiled at her in what was suggested to be an intimidating manner. Ball State tried and failed to address the problem to Vance’s satisfaction.
In 2006, Vance sued Ball State in federal district court, claiming that she’d been subjected to a racially hostile work environment in violation of Title Seven. She alleged that Davis was her supervisor and Ball State was liable for Davis’s behavior. Vance argued that Davis had enough authority to qualify as a supervisor because she had some leadership responsibilities and she sometimes directed Vance and other employees in the kitchen.
The court found that Davis wasn’t Vance’s supervisor because she couldn’t hire, fire, demote, promote, transfer, or discipline Vance. Accordingly, Ball State couldn’t be held vicariously liable for Davis’s alleged racial harassment. Ball State could be liable only if Vance proved negligence, which the court held that she hadn’t done because Ball State had responded reasonably to the incidents Vance had complained of. The court granted Ball State summary judgment. The Seventh Circuit affirmed. The United States Supreme Court granted cert.
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