Harris v. Forklift Systems Inc.
Harris v. Forklift Systems Inc.
Supreme Court of the United States, 1993
510 U.S. 17
FACTS: Plaintiff Teresa Harris was employed as a rental manager with Forklift Systems Inc. She filed a complaint regarding the sexual harassment behavior committed by the company’s President, Charles Hardy. In her complaint, she alleged that Hardy's misconduct made her undergo PTSD-like symptoms. She further alleged in her complaint that she was willing to resign from her job on the condition that Hardy makes a formal apology for his misconduct. For failure to heed to her request and knowing that the sexual harassment behavior will persist, she resigned from Forklift and filed her complaint with the Equal Employment Opportunity Commission (EEOC). The district court ruled that Hardy was not guilty of sexual harassment despite his crude and vulgar attitude. It was further held that Harris represented a continuing pattern of sex-based derogatory conduct that was offensive to any reasonable person. In addition, the lower court held that the plaintiff did not suffer serious psychological injury so the hostile work environment was not established in order to justify the judgment against Hardy for sexual harassment. The lower court dismissed the case. Complainant Harris filed an appeal to the Sixth Circuit which affirmed the decision of the district court. Hence, this appeal was filed before the Supreme Court for certiorari.
ISSUE: Whether or not in a sexual harassment case, plaintiff has the burden to prove the conduct causing complaint that would have reasonably offended the victim, and to show that victim suffered from serious psychological injury
RULING: The Supreme Court held mere offensive conduct is not a violation of Title VII. Title VII will take place prior to the harassing conduct that is usually leading to a nervous breakdown, or a pervasive and severe discriminatory conduct. Further, it was ruled that even if there are no tangible effects that are produced, it is considered a violation of Title VII's expanded rule of workplace equality.
Hence, the plaintiff who alleges sexual harassment does not necessarily require a demonstration of any concrete psychological harm. The offensive conduct or behavior must be sufficient to create a hostile or abusive working environment, which signifies an environment that any reasonable person will consider as hostile or abusive.
REASON: The Supreme Court ruled that there was no need for the environment to be psychologically injurious. In order to demonstrate hostile environment, the victim need not show direct economic injury, but only that the employer had actual knowledge of the harassment and failed to make reasonable efforts to correct the situation. Further, the Supreme Court ruled that violation of Title VII can be determined by considering several factors that includes the impact on the conduct, whether the conduct was physically threatening or whether it only represents a simple offensive utterance and how it has affected the work performance of the employee (Kuersten, 2003, p. 184).
Thus, the Supreme Court decision in favor of Harris has settled that Title VII prohibits the conduct that has an effect of seriously injuring the psychological well-being of any reasonable person. However, the law is not strictly confined to such conduct provided that the environment is reasonably perceived as hostile or abusive and no direct economic injury has to be proven by sufficient evidence (Kuersten, 2003, p.184).
References
Cleveland, J., Stockdale, M. S. and Murphy, K. R. (2000). Women and Men in Organizations.
New York. Routledge.
Harris v. Forklift Systems, Inc. 510 U.S. 17
Kuersten, A. (2003). Women and the law: leaders, cases, and documents. California:
