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forcibly raping her. In addition, after refusing him several times, she had

sexual intercourse with him, events that she did not describe as rape. Vin-

son did not report the harassment because she feared her supervisor and

would have had to make the report to him.

Before Meritor, only sexual harassment that included an economic

threat (quid pro quo), such as loss of employment or employment benefits,

had been recognized, but after Meritor, a hostile work environment became

the second classification under which action could be taken. Because hostile

work environment harassment is the more common type of harassment,

the Court’s decision provides working women with another avenue for liti-

gation. The decision also stated that compliance with sexual demands does

not necessarily mean that sexual harassment did not occur, but it did state

that the woman’s dress and speech could be admitted as evidence.

See also Civil Rights Act of 1964, Title VII; Employment Discrimination; Equal

Employment Opportunity Commission; Sexual Harassment

References Fallon, “Sexual Harassment” (1995); Hoff, Law, Gender, and Injustice

(1991); Meritor Savings Bank v. Vinson, 477 U.S. 57 (1986).

Meyers, Jan (b. 1928)

Republican Jan Meyers of Kansas served in the U.S. House of Representa-

tives from 3 January 1985 to 3 January 1997. President of the Shawnee

Mission League of Women Voters from 1961 to 1965, Meyers entered elec-

tive politics when she ran for the Overland Park City Council, beginning

Meyers, Jan 435

Representative Jan

Meyers (R-KS), chair of

the House Committee

on Small Business,

announced that she

would not seek a

seventh term in

Congress, 1995

(Associated Press AP)

her tenure in 1967 and serving as president from 1970 to 1972. She served

in the Kansas Senate from 1972 to 1984. As a member of Congress, Mey-

ers passed a bill to study improvements in firefighter safety and obtained

funding for a federal building and courthouse in Kansas City, Kansas. An

unsuccessful candidate in the 1978 Kansas Republican House primary

(she lost to Nancy Kassebaum), she won an open seat in the House in

1984. Meyers chaired the House Committee on Small Business in the

104th Congress (1995–1997). Her priorities included family planning,

health care, welfare reform, budget reform, drug abuse prevention, and

energy conservation. Meyers retired in 1997.

Born in Lincoln, Nebraska, Jan Meyers earned her associate of fine

arts degree from William Woods College in 1948 and her bachelor of arts

from the University of Nebraska in 1951.

See also Congress, Women in; State Legislatures, Women in

References Congressional Quarterly, Politics in America 1994 (1993).

Meyner, Helen Day Stevenson (1929–1997)

Democrat Helen Meyner of New Jersey served in the U.S. House of Rep-

resentatives from 3 January 1975 to 3 January 1979. When the Demo-

cratic candidate for Congress was disqualified in 1972, women leaders in

the Democratic Party recruited Meyner as a last-minute replacement. She

accepted the challenge but lost in a close race. She ran again in 1974 and

was successful. In Congress, Meyner was committed to peace issues and

proposed establishing a national academy of peace and conflict resolu-

tion. She was instrumental in keeping open the Army’s Picatinny Arsenal

in her district by having the Armament Research and Development Com-

mand transferred there. She also sought to reduce defense spending. She

worked for the Equal Rights Amendment and for appropriations for the

National Women’s Conference. Meyner was defeated in her attempt for a

third term.

Born in New York, New York, Helen Meyner earned her bachelor of

arts degree from Colorado College in 1950. An American Red Cross field-

worker in Korea from 1950 to 1952, she was a guide at the United Nations

from 1952 to 1953 and an airline consumer adviser from 1953 to 1956.

She was a special assistant to Adlai Stevenson during his 1956 presidential

campaign. In 1957, she married New Jersey governor Robert Meyner.

Helen Meyner wrote a twice-weekly newspaper column from 1957 to

1969, conducted a television interview program from 1965 to 1968, and

was an active volunteer in the community.

See also Congress, Women in; Equal Rights Amendment; National Women’s

Conference

436 Meyner, Helen Day Stevenson

References New York Times, 3 November 1997; Office of the Historian, U.S.

House of Representatives, Women in Congress, 1917–1990 (1991); Tomlinson,

“Making Their Way” (1996).

Mikulski, Barbara Ann (b. 1936)

Democrat Barbara Mikulski of Maryland served in the U.S. House of Rep-

resentatives from 3 January 1977 to 3 January 1987. She entered the U.S.

Senate on 6 January 1987. A social worker for a local Catholic charities or-

ganization and for the Baltimore City Welfare Department, Mikulski en-

tered politics at the grassroots level. A proposal for a highway that would

have gone through historic Fells Point of Baltimore, cutting through the

city’s first black home-ownership neighborhood, prompted Mikulski to

organize her neighbors to stop it. The network of community groups suc-

ceeded and at the same time provided Mikulski with a political base when

she ran for the city council. Mikulski served on the Baltimore City Coun-

cil from 1971 to 1977. During those years, she gained increasing visibility

and power within the Democratic Party, especially as chair of the Com-

mission on Delegate Selection and Party Organization in 1973.

As a member of the U.S. House and the Senate, Mikulski has been a

strong advocate for women’s issues, including the Equal Rights Amend-

ment and reproductive rights. She has worked for investigations of sexual

harassment, encouraged federal agencies to develop personnel policies on

discrimination and sexual harassment, promoted the implementation of

a comprehensive women’s health package, and argued for increased fund-

ing for breast and cervical cancer screening. She has fought domestic vio-

lence by supporting the Violence Against Women Act.

Mikulski, Barbara Ann 437

Two-term senator

Barbara Mikulski

(D-MD) was a

keynote speaker at

the Democratic

National Convention,

1996 (Corbis/Wally

McNam)

Mikulski has worked to maintain funding for NASA’s space station, a

source of thousands of jobs in Maryland, and has argued that medical re-

search with life-saving possibilities could be performed on the station. An

author of the 1984 Child Abuse Act and an advocate for unisex insurance

rates, Mikulski also focuses on education, aging, health insurance, the Na-

tional Service Program, the rights of working people, and job creation.

Noted for her sense of humor, Mikulski once described the chal-

lenges of being a political woman, saying: “If you’re married, you’re ne-

glecting him; if you’re single, you couldn’t get him; if you’re divorced, you

couldn’t keep him; and if you’re widowed, you killed him!” On another

occasion, she said: “Some women stare out the window waiting for Prince

Charming. I stare out the window waiting for more women Senators!” She

held the leadership positions of assistant Senate Democratic floor leader

in the 103rd Congress (1993–1995) and secretary of the Senate Demo-

cratic Conference in the 104th through 106th Congresses (1995–2001).

Born in Baltimore, Maryland, Barbara Mikulski received her bache-

lor of arts degree from Mount Saint Agnes College in 1958 and her mas-

ter’s degree in social work from the University of Maryland in 1965.

See also Abortion; Congress, Women in; Equal Rights Amendment; Sexual

Harassment; Violence Against Women Act of 1994; Women’s Health Equity Act

References Boxer, Strangers in the Senate (1994); Congressional Quarterly,

Politics in America 1994 (1993); H. W. Wilson, Current Biography Yearbook,

1985 (1985); www.senate.gov/~mikulski/bio.htm.

Military, Women in the

Women have fought in combat since the Revolutionary War, but it was

through their services as nurses that women began to be integrated into

the military. During the Civil War, Dorothea Dix recruited and trained

6,000 nurses to serve with the Union Army, but they were not a continu-

ing part of the military organization. The military appointed women to

serve as civilian nurses during the Spanish-American War, but they were

not uniformed members of the military. Congress created the Army Nurse

Corps in 1901 and the Navy Nurse Corps in 1908, but they had no mili-

tary rank, retirement, or veterans’ benefits.

Women’s roles expanded in 1917 during World War I, when the Navy

enrolled women in the Naval Coastal Defense Reserve with the rank of

yeoman to provide combat support as clerks, draftsmen, fingerprint ex-

perts, translators, and similar positions. The Marine Corps followed suit

in 1918. For the first time, women held full military rank and status, re-

ceived the same pay as men, wore uniforms, and had the other benefits

and obligations that their male counterparts had. The Army employed

women as civilians to perform comparable tasks, and the Army Nurse

438 Military, Women in the

Corps continued to have its auxiliary status. When the war ended, all

women in the armed forces were discharged except those in the nursing

auxiliaries.

With the advent of World War II and the personnel shortages that ac-

companied it, Congresswoman Edith Nourse Rogers (R-MA) passed leg-

islation creating the Women’s Army Auxiliary Corps (WAAC) in 1942.

The auxiliary structure did not provide women the same legal protection

men had, nor did they receive the same benefits as men if they were in-

jured, have military rank, or receive equal pay. In 1943, the Women’s Army

Corps (WAC) replaced the WAAC, and women gained full military status.

In 1942, Congress created the Navy Women’s Reserve (also known as

Women Accepted for Voluntary Emergency Service, or WAVES), the Ma-

rine Corps Women’s Reserve (Women Marines), and the U.S. Coast Guard

Women’s Reserve (SPARS, from the Coast Guard motto “Semper Para-

tus—Always Ready”). When the Air Force became a separate branch of

the military after World War II, it created Women in the Air Force (WAF).

Congress integrated women into the armed forces in 1948 but

banned them from combat planes and ships, limited them to no more

than 2 percent of personnel in any one service, and made lieutenant

colonel or Navy commander the highest rank they could hold. In addi-

tion, if they became pregnant, adopted children, or married someone with

children, they were automatically discharged.

Personnel shortages during the Korean War prompted the estab-

lishment of the Defense Advisory Committee on Women in the Services

(DACOWITS) in 1951. Initially a public relations group of fifty women,

DACOWITS has evolved into an advocacy group for women in the mili-

tary, playing a key role in passing the Women Officers Act of 1967. The act

permitted women to hold the ranks of general and admiral. The measure

also removed the 2 percent limit on women’s participation in the military,

but it gave each of the branches of the military the authority to establish

its own limit and effectively the limit remained.

In the 1970s, all of the services allowed pregnant women to stay in

the military, required the military academies to accept women, and per-

mitted women to serve on all noncombat Navy ships and to serve tempo-

rary duty on warships not on combat missions. In addition, the U.S.

Supreme Court decided in Frontiero v. Richardson (1973) that the de-

pendents of women in the military are eligible for the same benefits as the

dependents of men in the military.

Through the 1980s and 1990s, the military opened almost every job

to women except ground combat and service on submarines. Women,

however, cite their exclusion from combat as a barrier to gaining full

equality and respect. Retired Air Force major general Jeanne Holm wrote

Military, Women in the 439

that the bans on women’s participation in combat “automatically ex-

cluded [them] from participation in the primary mission of the armed

forces, and their second-class status was thus assured.” In 1993, Congress

repealed legislation that had prevented women from serving on combat

ships and the secretary of defense ordered the military services to allow

women aviators to compete for assignments as combat pilots. Both the

Navy and the Air Force had women pilots trained for combat at the time,

but the Army and the Marines did not have women pilots with compara-

ble training.

Sexual harassment has been recognized as a problem at least since

the 1970s, when DACOWITS members became aware of it. In 1980, a

naval officer was court-martialed for sexual harassment, but it was the

Tailhook scandal that brought national attention to the problem. In 1991,

during the Tailhook Association’s convention at a Las Vegas hotel, 117 of-

ficers were participants, observers, or aware of incidents of sexual assault,

indecent exposure, conduct unbecoming an officer, and failure to provide

proper leadership. A Pentagon report on the event said that 83 women

and 7 men had been subjected to assault during the convention. In 1996,

the Army revealed that a captain and two sergeants training auto me-

chanics at Aberdeen Proving Ground in Maryland had coerced young re-

cruits into having sex. One sergeant was convicted of rape and sent to

prison, and twelve others were relieved of their duties. U.S. senator

Olympia Snowe (R-ME) said that “women in the armed services today de-

serve to know right now that this problem is going to be taken care of”

and that sexual harassment in the military “is absolutely a failure of lead-

ership.” Scandals at other bases continued to be revealed as Congress and

the military sought to find ways to end sexual harassment.

See also Dix, Dorothea Lynde; Rogers, Edith Frances Nourse; Schroeder,

Patricia Nell Scott; Sexual Harassment; Snowe, Olympia Jean Bouchles

References Congressional Quarterly Almanac, 103rd Congress, 1st Session . . .

1993 (1994); Devilbiss, Women and Military Service: A History, Analysis, and

Overview of Key Issues (1990); Franke, Ground Zero: The Gender Wars in the

Military (1997); Freeman, “Women and Public Policy: An Overview” (1982);

Gruenwald, “Women in the Military: Mission in Progress” (1997).

Millender-McDonald, Juanita (b. 1938)

Democrat Juanita Millender-McDonald of California entered the U.S.

House of Representatives on 26 March 1996. She began her political career

as a member of the Carson City Council, where she served from 1990 to

1992, and she served in the California legislature from 1992 to 1996. She ran

for Congress after the incumbent was convicted of extortion and tax evasion

and resigned from office in December 1995. As an African American, Con-

440 Millender-McDonald, Juanita

gresswoman Millender-McDonald has introduced legislation to create a se-

lect congressional committee to investigate allegations that the Central In-

telligence Agency was involved in cocaine trafficking in inner-city neighbor-

hoods. She supports abortion rights, bilingual education, and job training.

Born in Birmingham, Alabama, Millender-McDonald earned her

bachelor of science degree from the University of Redlands in 1981 and

her master of arts degree from California State University and also at-

tended the University of Southern California.

See also Abortion; Congress, Women in; State Legislatures, Women in

References Congressional Quarterly, Politics in America 1998 (1997).

Millett, Katherine (Kate) Murray (b. 1934)

Author of Sexual Politics (1970), Kate Millett developed the first feminist

theories on the origins of the patriarchy. A pioneer in feminist criticism,

she linked literature to larger trends in society, politics, and culture. Mil-

lett became a national figure in 1970 with the publication of Sexual Poli-

tics, in which she used literature as the basis for her examination of gender

roles and patriarchy in society. Millett argued that gender is a function of

Millett, Katherine (Kate) Murray 441

Kate Millett, famous

for her book Sexual

Politics (1970),

which analyzed the

effects of the patri-

archy on women’s

status, 1971 (UPI/

Corbis)

social construction rather than biological differences and provided one of

the first feminist examinations of patriarchy. She described men’s power

over others as the last caste system and a remnant of feudalism, calling

chivalry a substitute for respect and equal rights for women. The celebrity

that accompanied the success of Sexual Politics led to a public confronta-

tion in which Millett, a married woman, was forced to declare herself a

lesbian. The event marked the first public confrontation between femi-

nism and lesbianism, and Time magazine made it a cover story. Ti-Grace

Atkinson, Gloria Steinem, Florynce Kennedy, and other feminists rallied

to Millett’s support and held a “Kate Is Great” press conference.

Born in St. Paul, Minnesota, Millett earned her bachelor of arts de-

gree from the University of Minnesota in 1956, studied at St. Hilda’s Col-

lege at Oxford University in England in 1958, and received her doctorate

from Columbia University in 1970. After studying in England, Millett held

a variety of jobs to support herself as she worked to develop her skills as

an artist. Her silkscreen prints and sculptures have been exhibited in gal-

leries on both the East and West Coasts and in Germany.

Millett’s other written works include The Prostitution Papers (1973),

Flying (1974), Going to Iran (1980), The Loony Bin Trip (1990), and A.D.

(1995).

See also Atkinson, Ti-Grace; Kennedy, Florynce Rae; Lesbian Rights; Steinem,

Gloria Marie

References H. W. Wilson, Current Biography Yearbook, 1995 (1995); Linden-

Ward and Green, American Women in the 1960s: Changing the Future (1993).

Mink, Patsy Matsu Takemoto (b. 1927)

Democrat Patsy Mink of Hawaii served in the U.S. House of Representa-

tives from 3 January 1965 to 3 January 1977 and returned to the House on

22 September 1990. In the 1960s and 1970s, she concentrated on educa-

tion, a bill to construct schools in the U.S. Pacific territories, a measure to

expand the federal student loan program, and another to help teachers

pursue advanced degrees or take refresher courses. She passed a measure

to create an economic development program and remove inequities

against Pacific Islanders in the Immigration and Nationality Act. After un-

successfully seeking the Democratic nomination for the U.S. Senate in

1976, she was assistant secretary of state for oceans and international en-

vironmental and scientific affairs from 1977 to 1978 and president of

Americans for Democratic Action from 1978 to 1981. She served on the

Honolulu City Council from 1983 to 1987.

When the incumbent member of Congress resigned in 1990, Mink

won his seat in a special election. In 1995 Mink described her experience

as an involuntary and unknowing subject in an experiment to determine

442 Mink, Patsy Matsu Takemoto

the effectiveness of diethylstilbestrol (DES) in preventing miscarriages.

While pregnant with her daughter in 1951, she had been given DES even

though she was not at risk for miscarriage. Because of the drug, her adult

daughter has dealt with repeated occurrences of a precancerous condi-

tion. In 1978, Mink and other women sued the manufacturer and won a

settlement. Their daughters also sued, but because they did not have can-

cer at the time, they did not receive an award. Congresswoman Mink’s

revelation of her experience with DES provides an example of ways that

women bring an additional perspective to policy debates.

Mink, Patsy Matsu Takemoto 443

Representative Patsy

Mink (D-HI) spoke

during a rally spon-

sored by the National

Organization for

Women to protest

welfare reform, 1995

(Associated Press AP)

Mink sponsored the Family Stability and Work Act in 1995 as an al-

ternative welfare reform bill. It emphasized combining monetary assis-

tance with job training, job search assistance, and child care. In presenting

the bill, Mink said: “Best of all it demeans no one because they are poor,

and it protects children and legal aliens by refusing to segregate their

rights and privileges because of status, and assures eligibility of Federal

support while allowing maximum flexibility to the States to provide for

jobs, job training, and child care.” She worked for the Family and Medical

Leave Act of 1993 and has worked for increased funding for ovarian can-

cer research, educational equity for girls and women, and the expansion

of Head Start.

Born in Paia, Hawaii, Patsy Mink attended Wilson College in 1946

and the University of Nebraska in 1948, earned her bachelor’s degree in

zoology and chemistry from the University of Hawaii in 1948, and re-

ceived her law degree from the University of Chicago in 1951.

She went into private law practice in Hawaii and lectured on business

law at the University of Hawaii from 1952 to 1956 and from 1959 to 1962.

She was attorney for the Hawaii House of Representatives in 1955. Mink

served in the Territory of Hawaii House of Representatives from 1956 to

1958, the Territorial Senate from 1958 to 1959, and the Hawaii Senate

from 1963 to 1964.

See also Congress, Women in; Family and Medical Leave Act of 1993; State

Legislatures, Women in

References Congressional Quarterly, Politics in America 1994 (1993); Congres-

sional Record, 24 March 1995; H. W. Wilson, Current Biography Yearbook, 1968

(1968); Office of the Historian, U.S. House of Representatives, Women

in Congress, 1917–1990 (1991).

Minor v. Happersett (1875)

In Minor v. Happersett, Virginia Minor attempted to gain suffrage rights

by arguing that the State of Missouri had violated her First, Thirteenth,

and Fourteenth Amendment rights when it prohibited her from register-

ing to vote in 1872. The U.S. Supreme Court found that the U.S. Consti-

tution does not grant the right of suffrage to anyone and the states’ deci-

sions to limit voting to men were not unconstitutional.

Minor contended that the First Amendment provided voting rights

as a form of free expression, that under the Thirteenth Amendment being

denied the vote was a form of involuntary servitude, and that the Four-

teenth Amendment made voting for federal officials a privilege of citizen-

ship. The U.S. Supreme Court refused to consider the first two arguments

and focused on the Fourteenth Amendment argument. Although agreeing

that women were citizens and that women were persons because they were

444 Minor v. Happersett