Teresa Harris v. Forklift Systems, Inc.

social sciences


Teresa Harris v. Forklift Systems, Inc.

United States Supreme Court 510 U.S. 17 (1994)

Plaintiff Harris was a manager for Defendant Forklift Systems, Inc. During her tenure at Forklift Systems,

Plaintiff Harris was repeatedly insulted by defendant’s president and, because of her gender, subjected

to sexual innuendos. Numerous times, in front of others, the president told Harris, “You’re just a

woman, what do you know?” He sometimes asked Harris and other female employees to remove coins

from his pockets and made suggestive comments about their clothes. He suggested to Harris in front of

others that they negotiate her salary at the Holiday Inn. When Harris complained, he said he would stop,

but he did not; so she quit and filed an action against the defendant for creating an abusive work

environment based on her sex.

The district court found in favor of the defendant, holding that some of the comments were offensive to

the reasonable woman but were not so serious as to severely affect Harris’s psychological well-being or

to interfere with her work performance. The court of appeals affirmed. Plaintiff Harris appealed to the

U.S. Supreme Court.

Justice O’Connor

In this case we consider the definition of a discriminatorily “abusive work environment” (a “hostile work

environment”) under Title VII.

Title VII of the Civil Rights Act of 1964 makes it “an unlawful employment practice for an employer… to

discriminate against any individual with respect to his compensation, terms, conditions, or privileges of

employment, because of such individual’s race, color, religion, sex, or national origin.”… [T]his language

“is not limited to ‘economic’ or ‘tangible’ discrimination. The phrase ‘terms, conditions, or privileges of

employment’ evinces a congressional intent ‘to strike at the entire spectrum of disparate treatment of

men and women’ in employment,” which includes requiring people to work in a discriminatorily hostile

or abusive environment. When the workplace is permeated with “discriminatory intimidation, ridicule,

and insult,” that is “sufficiently severe or pervasive to alter the conditions of the victim’s employment

and create an abusive working environment.”

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