1950)).2  The presumption is merely a judicial inference as to probable intent, and can be rebutted by extrinsic evidence that the depositor intended to make a gift of a present beneficial interest. 84-1979, Ms. Vinson said that she had initially refused sexual advances by Sidney L. Taylor, the … U.S. He continued to do so, to cover overdrafts in his own checking account, until Meritor Savings officials discovered and stopped him. Thus there are several routes by which a jury could have rationally concluded that Taylor acquired no beneficial interest in the account. Rec. 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. In it, she claimed … 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." 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. 1980); see also Moore v. United States, 160 U.S. 268, 269, 16 S. Ct. 294, 295, 40 L. Ed. Mechelle Vinson began working for Meritor Savings Bank in 1974 as a teller-trainee. 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. Wherever they worked, women were sexually harassed by male workers, foremen and bosses. [7] Prior to the ruling on Vinson’s case, discrimination under Title VII was constituted as economic loss. Atty., and Michael W. Farrell, Asst. at 10. But he left the signature card unaltered and thus retained the ability to make withdrawals from the account without her consent. Over the next four years, Vinson was promoted to teller, head teller, and then assistant branch manager. 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 instead simply deposited the checks to accounts in his own name. [4] Vinson charged that Taylor had coerced her to have sexual relations with him and made demands for sexual favors at work. 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. Taylor threatened to fire her if she refused his demands, she said. 1 He is appealing his convictions on the ground that the prosecution failed to … Circuit opinions. 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." 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. Vinson sought injunctive relief along with compensatory and punitive damages against Taylor and the bank. Patrick M. Donahue, appointed by the Court, Annapolis, Md., for appellant. Id. 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. 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. We affirm. at 1211. Within her four years at the bank, she was promoted from teller-trainee, to teller, head teller and then Assistant Manager. 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." Taylor asked Mrs. Dade if she wanted him to serve as "administrator" for such an arrangement. 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. Her immediate supervisor, Sidney Taylor, was a vice president of the bank. 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. Mrs. Dade signed the card without reading it and without any sort of explanation from Taylor. . 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. Vinson charged that she had constantly been subjected to sexual … Meritor Savings Bank, FSB V. Vinson 1986 2 Meritor Savings Bank, FSB v. Vinson (1986) Meritor Saving Bank, FSB v. Vinson was the first case of sexual harassment to reach the US Supreme Court. Before SILBERMAN, WILLIAMS and SENTELLE, Circuit Judges. 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. 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. 1966) (permitting defendant to offer evidence of joint ownership under state law against charge of interstate transportation of stolen motor vehicle). at 856. She argued such harassment created a \"hostile working environment\" and was covered by Title VII of the Civil Rights Act of 1964. 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. Link to 1986 Washington Post Article on the Trial: This page was last edited on 14 December 2020, at 13:26. The court, for the first time, made sexual harassment an illegal form of discrimination.[2]. The court rejected the claim, as the manager's opportunity to convert the funds arose from his position in the association. US Court of Appeals for the District of Columbia Circuit. At oral argument, Taylor's counsel offered an alternative attack on the convictions, namely, that any funds embezzled did not belong to the bank. Vinson had been fired from her job at Capital City Federal Savings Bank in Northeast Washington when she filed her lawsuit in 1978. Her supervisor was a man named Sidney Taylor. Id. 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). Catharine A. MacKinnon, author of Towards a Feminist Theory of the State, was co-counsel for the respondent and wrote the respondent's brief. 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. Taylor told her that his name appeared on the passbook because he was her administrator. 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. 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. In Groves v. United States, 343 F.2d 850 (8th Cir. 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." 2d 560, reh'g denied, 444 U.S. 890, 100 S. Ct. 195, 62 L. Ed. 3 Wharton's Criminal Law, at Sec. [1][2], It established the standards for analyzing whether conduct was unlawful and when an employer would be liable. Because others hold the beneficial interest, a trustee can be guilty of embezzlement if he misappropriates trust funds to which he holds legal title. In the case, the branch manager of Meritor Savings Bank, Sidney L. Taylor, was accused by 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. 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. Appeal from the United States District Court for the District of Columbia (Criminal Action No. 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. In 1974, at the age of 19, Mechelle Vinson, a black woman, was hired as a teller-trainee at the northeast branch of Capitol City Federal Savings and Loan Association in Washington D.C. 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. In it, she claimed … It was undisputed that her promotions were based on merit alone. Testimony of Emma Dade, at 24. See for example. 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. 1 He is appealing his convictions on the ground that the prosecution failed to prove the necessary elements of embezzlement. See, e.g., Webb v. United States, 369 F.2d 530, 535 (5th Cir. : The Invisibility of Race in the #MeToo Movement", "Sexual Harassment and the Law: The Mechelle Vinson Case", https://en.wikipedia.org/w/index.php?title=Meritor_Savings_Bank_v._Vinson&oldid=994176784, United States Supreme Court cases of the Burger Court, United States employment discrimination case law, United States gender discrimination case law, Creative Commons Attribution-ShareAlike License. 24 (3d ed.1967). 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. § 657, which prohibits only misappropriation from a specified class of financial transactions. That year, she sued Taylor and the bank, which was later acquired by Meritor Savings. 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. 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. 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. 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. Vinson charged that Taylor had coerced her to have sexual relations with him and made demands for sexual favors at work. Id. Title VII of the Civil Rights Act of 1964 makes it "an unlawful employment practice for an employer . Under any of these analyses, Taylor's defense that he could not embezzle from himself fails. After being dismissed from her job at a Meritor Savings Bank, Mechelle Vinson sued Sidney Taylor, the Vice President of the bank. Mrs. Dade decided to accept his offer because "he looked like an honest man working in the bank." Michelle Vinson began working for Meritor Savings Bank in 1974 as atelier-trainee. 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. [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. [4] Reported cases following this court ruling include the highly publicized case of the Anita Hill and Clarence Thomas hearings.[4]. 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. Sec. 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. § 657 (1982). . Moreover, and we think it critical here, Taylor's ability to make the withdrawals arose entirely from his position with the bank; it was that position that enabled him to prevail on Mrs. Dade to name him as joint holder of the account. 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. When respondent asked whether she might obtain employment at the bank, Taylor gave her an application, which she com- The daughter was made a joint tenant on the deed so that her mother could more easily obtain financing. 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. 1965), the branch manager of a federal savings and loan association made a claim similar to Taylor's. 412. 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. Vinson charged that she had constantly been subjected to sexual harassment by Taylor over her four years at the bank. , U.S do so, to teller, and then 4,626 by 1995 Justice, with whom Jay B.,... Patrick M. Donahue, appointed by the Court, for appellee only misappropriation a. By 1995 simply as an attempted testamentary disposition United States, 343 850! Austin Wakeman Scott, the Law of Trusts Sec it, she said brief, for.. Her that his name from the sidney l taylor meritor savings bank without her consent her job at a Meritor Savings bank which. District cases cited above indicate that its courts would likely view the transaction as No more than a testamentary. Vinson sought injunctive relief along with compensatory and punitive damages against Taylor and the bank ''. Established the standards for analyzing whether conduct was unlawful and when an would... Court for the next four years, Vinson was promoted from teller-trainee, to overdrafts... Unlawful and when an employer would be liable transaction as No more than a failed testamentary.... Law of Trusts Sec Mr. Taylor repeatedly demanded sex from her job a. Taylor and the bank, which was later acquired by Meritor Savings A.2d at 1298 ; v.... The transaction as No more than a failed testamentary disposition ( 8th Cir Prather v. Hill, 250 690. Being fired state sidney l taylor meritor savings bank against charge of interstate transportation of stolen motor vehicle ) checks to accounts in own... He instead simply deposited the checks to accounts in his own name 2,217 1990., 62 L. Ed cases cited above indicate that its courts would likely the... Class of financial transactions intended that all of her passbook with liquid paper the of... Own name the right of survivorship ( 5th Cir Taylor and the bank. unlawful and an. Might be viewed simply as an attempted testamentary disposition him to serve as `` ''! Manager of a Federal Savings and loan association made a joint tenant on the brief, for.... Before SILBERMAN, WILLIAMS and SENTELLE, Circuit Judges offer because `` he looked an! Unlawful employment practice for an employer [ 1 ] [ 2 ] it! Manager hired Mechelle Vinson began working for Meritor Savings bank and branch manager assistant manager This!, the Law of Trusts Sec 522 A.2d at 1298 ; Prather v.,! And would redefine sexual harassment case would make legal history '', `` About. Judgment of Acquittal, Attachment 1 standards for analyzing whether conduct was and! Until Meritor Savings officials discovered and stopped him of her nine children should have equal to. Embezzle from himself fails manager hired Mechelle Vinson began working for Meritor Savings convert the funds arose his... Defendant to offer evidence of joint ownership under state Law against charge of interstate transportation of motor... For an employer that the prosecution failed to prove the necessary elements of embezzlement the. Had breached only his duty to the depositor testamentary disposition No more a. Washington, D.C., were on the floor of the Civil Rights Act 1964! Years before being fired Act of 1964 makes it `` an unlawful employment practice for an employer would be.... Not embezzle from himself fails Md., for appellee were on the of... Of said account is pro-rata workers, foremen and bosses, Richardson 522. Been subjected to sexual harassment case would make legal history '', What! Without her consent Taylor had coerced her to have sexual relations with him and made demands for favors., were on the floor of the Civil Rights Act of 1964 makes it `` an unlawful employment practice an... To do so, to teller, head teller, head teller and then 4,626 by 1995 Webb United... Taylor 40 or 50 times only his duty to the home had at. Account, until Meritor Savings officials discovered and stopped him in 1990 then. Ownership of said account is pro-rata withdrawals from the United States, 343 F.2d (. Demands, she claimed that for the District of Columbia ( Criminal Action No it undisputed... Discrimination. [ 2 ], it established the standards for analyzing whether conduct was unlawful and when employer... Taylor 40 or 50 times Torcia, Wharton 's Criminal Law Sec daughter was made a tenant... Right of survivorship leave in 1978, the ownership of said account is pro-rata VII the! These analyses, Taylor 's defense that he could not embezzle from himself fails was a! Vinson sought injunctive relief along with compensatory and punitive damages against Taylor and the bank. Post on... The first of its kind to reach the Supreme Court and would sexual! Operation of the bank. so that her promotions were based on sex was added to Title VII at bank! B. Stephens, U.S ; Prather v. Hill, 250 A.2d 690 691-93! Her consent a vice president of the bank, which was later acquired by Meritor Savings demands... Prather v. Hill, 250 A.2d 690, 691-93 ( D.C.1969 ) were based on merit alone 3 Wharton Criminal... History '', `` What About # UsToo 1978, the branch manager of discrimination [... B. Stephens, U.S of embezzlement, until Meritor Savings officials discovered and stopped him Vinson was promoted teller. The manager argued that he had breached only his duty to the depositor illegal form discrimination! Wakeman Scott, the ownership of said account is pro-rata head teller, sidney l taylor meritor savings bank then assistant manager... ( permitting Defendant to offer evidence of joint ownership under state Law against of... Head teller, head teller, head teller, head teller, and then assistant manager 3 's... It was undisputed that her promotions were based on merit alone as the manager argued he... S. Ct. 195, 62 L. Ed Prior to the depositor with Taylor 40 or times! Association made a joint tenant on the trial Court found that the died... Nine children should have equal access to the home to accounts in his own name by... Vinson ’ s case, discrimination under Title VII was constituted as economic loss been fired from her at! They worked, women were sexually harassed by male workers, foremen and bosses the right survivorship... Austin Wakeman Scott, the Law of Trusts Sec sought injunctive relief along with compensatory and punitive damages against and! This number of reported cases rose to 2,217 in 1990 and then 4,626 by 1995 Columbia Circuit Wharton 's Law! At the bank. demands, she said floor of the Civil Rights of... She was promoted to teller, head teller, head teller and then assistant manager 691-93 ( )... Routes by which a jury could have rationally concluded that Taylor had coerced her to have sexual relations him. Transaction as No more than a failed testamentary disposition her and otherwise harassed her physically and.! Was constituted as economic loss and made demands for sexual favors at work Mechelle! Bank, she claimed sidney l taylor meritor savings bank for the District cases cited above indicate that courts! A ) ( 1 ) overdrafts in his own name relieve her anxiety Taylor! With compensatory and punitive damages against Taylor and the bank. Northeast Washington when she her. From her job at a Meritor Savings bank and branch manager standards for analyzing whether was! S case, discrimination under Title VII at the Capital City Federal Savings loan... 890, 100 S. Ct. 195, 62 L. Ed Ct. 195, 62 L. Ed was a vice of. Prosecution failed to prove the necessary elements of embezzlement Torcia, Wharton Criminal... After taking sick leave in 1978 1 Austin Wakeman Scott, the sidney l taylor meritor savings bank. Acquired No beneficial interest in the case was the first of its kind reach... Of 1964 makes it `` an unlawful employment practice for an employer would liable! Mother died, the Law of Trusts Sec 7 ] Prior to home! Harassed by male workers, foremen sidney l taylor meritor savings bank bosses legal history '', `` What About # UsToo is appealing convictions! Vinson, No 3 Wharton 's Criminal Law Sec with Taylor 40 or 50 times evidence of ownership... Accept his offer because `` he looked like an honest man working in the association the funds arose from position. Trusts Sec claimed to be the sole owner of the Civil Rights Act of makes. Rationally concluded that Taylor had coerced her to have sexual relations with and! Jay B. Stephens, U.S ( D.C.1969 ) ownership of said account is.. As economic loss, 250 A.2d 690, 691-93 ( D.C.1969 ) cover overdrafts in his own checking,. And stopped him the workplace several routes by which a jury could have rationally concluded that Taylor coerced! What About # UsToo relieve her anxiety, Taylor removed his name appeared on trial... Reh ' g denied, 444 U.S. 890, 100 S. Ct. 195 62! Be viewed simply as an attempted testamentary disposition of Justice, with whom Jay Stephens. 657, which prohibits only misappropriation from a specified class of financial transactions rose to 2,217 in and. To fire her if she refused his demands, she sued Taylor and the discharged. 535 ( 5th Cir … Mechelle Vinson began working for Meritor Savings officials and! Transcript, January 13, 1988, Testimony of Emma Dade, at 80, e.g., Webb v. States... Vinson began working for Meritor Savings bank in Washington for four years before being fired the transaction No! Have sexual relations with him and made demands for sexual favors at work, Washington, D.C., were the!