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Vance v. Ball State Univ.: Supreme Court Adopts Narrow Definition of "Supervisor" for Title VII Liability

June 27, 2013

By KENNETH W. GAGE & SEAN M. SMITH

The U.S. Supreme Court adopted a narrow definition for the term "supervisor" for purposes of an employer's vicarious liability for harassment under Title VII. In Vance v. Ball State University, the Court held that only an employee who "is empowered by the employer to take tangible employment actions against the victim" is a supervisor. The Court predicts that this will expedite resolution of many harassment cases at the summary judgment stage.

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Image: Kenneth W Gage
Kenneth W Gage
Partner, Employment Law Department