Employment Litigation · Primary-source case analysis

Vance v. Ball State: Supervisor Status Depends on Tangible-Action Authority

By Aneeta Mishra and Timothy Chan

Published April 25, 2026

Vance draws the line between coworker and supervisor harassment by focusing on delegated power over significant employment decisions.

A catering employee alleged racial harassment

Maetta Vance alleged that another employee created a racially hostile environment. The liability framework depended on whether the alleged harasser was Vance’s supervisor or merely a coworker.

Supervisor status requires tangible-action power

For this doctrine, a supervisor must be empowered to hire, fire, demote, promote, transfer, discipline, or otherwise cause a significant change in employment status or benefits.

Task direction alone is not enough

An employee who directs daily work but lacks authority over tangible employment actions does not trigger the same vicarious-liability rule. The employer may still be liable for negligence in controlling workplace conditions.

Disposition

The Court affirmed summary judgment because the alleged harasser lacked the required authority and the employer was not shown negligent under the applicable record.

Key takeaways

• Map formal and practical authority over employment decisions.
• Separate daily task direction from tangible-action power.
• Analyze negligence even when the harasser is a coworker.
• Preserve delegation documents and actual decision practices.