Another central issue in the Vinson case was the question of employer liability for the action of supervisors. Specifically, the issue has focused on the conditions under which an employer can be held liable for the harassing conduct of its individual supervisors (Meritor Savings Bank v. Vinson, 1986). At one extreme, the argument held that an employer is always liable for the actions of supervisors because the supervisor is acting as the agent of the employer. At the other extreme, the argument held that, unless the act of sexually harassing employees was part of the supervisor’s job, the employer should be liable only if the employer was negligent. Negligence in this context has come to be defined as “the employer knew or should have known