Harris v. Forklift Systems, Inc.

PETITIONER: Harris
RESPONDENT: Forklift Systems, Inc.
LOCATION: Forklift Systems Inc

DOCKET NO.: 92-1168
DECIDED BY: Rehnquist Court (1993-1994)
LOWER COURT: United States Court of Appeals for the Sixth Circuit

CITATION: 510 US 17 (1993)
ARGUED: Oct 13, 1993
DECIDED: Nov 09, 1993

ADVOCATES:
Ann Elizabeth Reesman - for the Equal Employment Advisory Council as amicus curiae urging affirmance
Douglas S. McDowell - for the Equal Employment Advisory Council as amicus curiae urging affirmance
Irwin Venick - on behalf of the Petitioner
Jeffrey P. Minear - on behalf of the United States, as amicus curiae, supporting Petitioner
Robert E. Williams - for the Equal Employment Advisory Council as amicus curiae urging affirmance
Stanley M. Chernau - on behalf of the Respondent

Facts of the case

Teresa Harris was sexually harassed by her employer. She filed suit in federal district court, claiming that the harassment created an "abusive work environment" in violation of Title VII of the Civil Rights Act of 1964. The employer countered that the harassment had not been severe enough to seriously affect her psychologically or impair her ability to work, and that it therefore did not create an abusive work environment under the meaning of Title VII. The district court agreed, stating that the decision was a "close case" but that the harassment had not been severe enough to create an abusive work environment in violation of the Act. A Sixth Circuit Court of Appeals panel affirmed the district court's decision.

Question

Must sexual harassment "seriously affect [an employee's] psychological well being" in order to create an "abusive work environment" that violates Title VII of the Civil Rights Act of 1964?

Media for Harris v. Forklift Systems, Inc.

Audio Transcription for Oral Argument - October 13, 1993 in Harris v. Forklift Systems, Inc.

Audio Transcription for Opinion Announcement - November 09, 1993 in Harris v. Forklift Systems, Inc.

Sandra Day O'Connor:

The second case is No. 92-1168, Teresa Harris against Forklift Systems.

And this case comes to us on certiorari to the United States Court of Appeals for the Sixth Circuit.

The petitioner, Teresa Harris, sued her former employer, the respondent, Forklift Systems, claiming that the harassment inflicted on her by Forklift's president created a gender-based abusive work environment in violation of Title VII.

Finding this was a closed case, the District Court concluded that Forklift's president often insulted Harris because of her gender and often made her the target of unwanted sexual innuendos.

However, the Court held that this conduct did not create an abusive environment because it was not so severe as to seriously affect Harris' psychological wellbeing or lead her to suffer injury.

The Court of Appeals affirmed.

In the opinion filed today, we reverse the judgment and remand.

We reaffirm Meritor Savings Bank against Vinson, which held that Title VII has is violated when a workplace is permeated with discriminatory behavior that is severe or pervasive enough to create a discriminatorily hostile or abusive work environment.

If the environment is both objectively and subjectively discriminatorily abusive, if a reasonable person would find it to be abusive, and the plaintiff actually found it to be abusive, a Title VII violation has taken place.

Whether an environment is hostile or abusive can be determined by considering all the circumstances, which may include the frequency of the discriminatory conduct, its severity, whether it is physically threatening or humiliating or a mere offensive utterance, and whether it unreasonably interferes with an employee's work performance.

A serious effect on the employee's psychological wellbeing is relevant to this inquiry but it is not required.

Justices Scalia and Ginsburg, who joined the opinion, have also filed concurring opinions.