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Law School Case Brief

Harris v. Forklift Sys. - 510 U.S. 17, 114 S. Ct. 367 (1993)

Rule:

Mere utterance of an epithet which engenders offensive feelings in an employee does not sufficiently affect the conditions of employment to implicate Title VII of the Civil Rights Act of 1964. Conduct that is not severe or pervasive enough to create an objectively hostile or abusive work environment—an environment that a reasonable person would find hostile or abusive—is beyond Title VII's purview. Likewise, if the victim does not subjectively perceive the environment to be abusive, the conduct has not actually altered the conditions of the victim's employment, and there is no Title VII violation. 

Facts:

Plaintiff Teresa Harris filed a lawsuit in federal district court against her former employer, defendant Forklift Systems, Inc., claiming that the conduct of Forklift's president toward her constituted "abusive work environment" harassment because of her gender in violation of Title VII of the Civil Rights Act of 1964. Declaring it to be "a close case," the district court found, among other things, that Forklift's president often insulted Harris because of her gender and often made her the target of unwanted sexual innuendos. However, the court concluded that the comments in question did not create an abusive environment because they were not so severe as to seriously affect Harris' psychological well-being or lead her to suffer injury. The court of appeals affirmed. Forklift filed a petition for a wit of certiorari.

Issue:

Did Harris' employer create an abusive environment?

Answer:

Yes.

Conclusion:

The Supreme Court of the United States reversed the lower court's judgment and remanded the action for further proceedings consistent with its opinion. It held that the district court erred when it relied on whether the president's conduct seriously affected Harris' psychological well being or led her to suffer injury. The Court held that while Title VII of the Civil Rights Act of 1964, 42 U.S.C.S. § 2000e-2(a)(1) barred conduct that would seriously affect a reasonable person's psychological well being, the statute was not limited to such conduct. The Court held that to be actionable as "abusive work environment" harassment, conduct need not "seriously affect an employee's psychological well-being" or lead the plaintiff to "suffer injury." As long as the environment would reasonably be perceived and was perceived as hostile or abusive, there was no need for it also to be psychologically injurious. The Court found that psychological harm could be taken into account, but was not required by the statute.

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