MAETTA VANCE, Petitioner v. BALL STATE UNIVERSITY, 570 U.S. 421

Summary

The African-American employee was working for the employer as a full-time catering assistant when a white catering specialist allegedly harassed her. The catering specialist did not have the power to hire, fire, demote, promote, transfer, or discipline the employee. The employee alleged that the catering specialist was her supervisor. The Supreme Court determined that the employer was properly granted summary judgment as to the employee's Title VII racially hostile work environment claim because (1) an employee was a “supervisor” for purposes of vicarious liability under Title VII if he or she was empowered by the employer to take tangible employment actions against the victim, and (2) there was no evidence that the employer empowered the catering specialist to take any tangible employment actions against the employee. The Supreme Court rejected the nebulous definition of a “supervisor” advocated in the Equal Employment Opportunity Commission’s Enforcement Guidance. The way to ...