On Monday, the Supreme Court issued its decision in Vance v. Ball State University. The issue decided was which employees constitute "supervisors" for the purpose of applying Title VII anti-discrimination laws. I previously discussed the importance of this question.
In a 5-4 decision, the Court decided that an individual is a supervisor only if he or she is empowered by the employer to take tangible employment actions. The court defines "tangible employment action" as the ability "to effect a significant change in employment status, such as hiring, firing, failing to promote, reassignment with significantly different responsibilities or a decision cause a significant change in benefits." Individuals without such authority are not supervisors.
The Court provides a variety of reasons to support its determination, including its easy application and congruence with the reality of the workplace.
The Court's decision does not shift the legal framework present in the 8th Circuit as the definition adopted by the Supreme Court is the one that has historically been applied. This is good news for employers in Iowa.