Harris v. Forklift Systems, Inc.

Teresa Harris (plaintiff) worked as a rental equipment manager at Forklift Systems, Inc. (Forklift) (defendant) from April 1985 through October 1987. Throughout Harris’s time at Forklift, company president Charles Hardy routinely subjected Harris to gender-driven verbal insults. Hardy targeted Harris and other female employees with frequent sexual innuendos, sexually suggestive comments, and sexually explicit gestures. In August 1987, Harris confronted Hardy about the offensive conduct and asked that it stop. Despite apologizing and assuring Harris the behavior would stop, Hardy again began making sexist and sexual comments to Harris. Harris quit one month later. Harris sued Forklift, alleging Hardy’s offensive behavior had created a hostile and abusive work environment based on Harris’s gender, in violation of Title VII of the Civil Rights Act of 1964 (Title VII), 42 U.S.C. § 2000e et seq. The district court concluded that although a reasonable woman in Harris’s position would find the conduct offensive, it did not create a hostile work environment, because it did not cause severe psychological injury or interfere with Harris’s job performance. The United States Supreme Court ultimately granted Harris’s petition for review in order to resolve a conflict among the United States Courts of Appeals on whether Title VII requires that hostile work environment discrimination cause psychological injury.