Harris v. Forklift Systems, Inc.

Harris v. Forklift Systems, Inc.

Argued October 13, 1993
Decided November 9, 1993
Full case name Teresa Harris, Petitioner v. Forklift Systems, Inc.
Docket nos. 92–1168
Citations

510 U.S. 17 (more)

114 S.Ct. 367, 126 L.Ed.2d 295
Argument Oral argument
Prior history On writ of certiorari to the United States Court of Appeals for the Sixth Circuit
Court membership
Case opinions
Majority O'Connor, joined by unanimous
Concurrence Scalia
Concurrence Ginsburg
Laws applied
42 U.S.C. § 2000 et seq.

Harris v. Forklift Systems, Inc., 510 U.S. 17 (1993), is a case in which the United States of America Supreme Court case that clarified the definition of a "hostile" or "abusive" work environment under Title VII of the Civil Rights Act of 1964. In a unanimous opinion written by Justice Sandra Day O'Connor, the Court held that a determination about whether a work environment is hostile or abusive requires a consideration of all relevant circumstances.[1]

Background

Title VII

Title VII of the Civil Rights Act of 1964 states that it is "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."[1]

Harris' sexual harassment suit

Teresa Harris was a manager at an equipment rental company, Forklift Systems Inc., between April 1985 and October 1987.[1] Harris alleged that the president of Forklift Systems subject to gender discrimination and undesired sexual innuendos while she was employed by the company. She claimed that these innuendoes included sexist remarks as well as sexual advance offers, and that these innuendos occurred on multiple occasions, and even in the presence of other employees[1] Harris first complained about Hardy's behavior in August 1987. She complained directly to Hardy, and he claimed that he was kidding and apologized to Harris. After Harris complained, Hardy said that he would stop that kind of behavior, so Harris stayed at the job. However, in September, Hardy started harassing her again in front of other employees. Harris got her paycheck and quit her job at Forklift Systems, Inc. on October 1. After quitting, Harris sued Forklift Systems, Inc. Harris claimed that Hardy's behavior made an abusive work environment for her based on her gender.[1]

Harris filed a lawsuit under Title VII of the Civil Rights Act of 1964. The United States District Court for the District of Tennessee stated that Hardy's behavior did not make a cruel work environment for Harris. The District claimed that Hardy's conduct would have made any "reasonable woman" uncomfortable but would not have affected their psychological well being and performance at work.[1] The District Court held that the evidence presented by Harris was not sufficient enough to show that Hardy's behavior actually affected the conditions of her employment; therefore, there was no Title VII violation.[1] The United States Court of Appeals affirmed the District Court's decision.[2]

Opinion of the Court

The United States Supreme Court decided to reverse the Sixth Circuit's decision and remanded the case.[3] This suit was later settled outside of Court, and the terms were not released.[4]

See also

References

  1. 1 2 3 4 5 6 7 "Legal Information Institute". Cornell University Law School. Retrieved October 4, 2016.
  2. Harris v. Forklift Systems, Inc., 976 F.2d 733 (1992).
  3. Harris v. Forklift Sys., Inc., 510 U.S. 17, 23 (1993).
  4. "Harris v. Forklift Systems | law case". Encyclopedia Britannica. Retrieved 2016-10-06.
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