Title IX and Sexual Harassment
The Impact of Federal Education Law on the Nation's Schools
The U.S. Supreme Court first recognized a claim for sexual harassment in its decision in Meritor Savings Bank v. Vinson (1985), a case brought under Title VII of the Civil Rights Act of 1964, which prohibits discrimination in employment. In Meritor, the Court recognized two types of sexual harassment: "Harassment that involves the conditioning of concrete employment benefits on sexual favors," commonly referred to as quid pro quo sexual harassment, and "harassment that, while not affecting economic benefits, creates a hostile or offensive working environment," commonly known as hostile environment sexual harassment. In Title VII cases, the Court typically applies…
