|
|
Harris v. Forklift Systems, Inc., 510 U.S. 17 (1993)
Contents:
Show Summary
Hide Summary
General SummaryThis case is from a collection containing the full text of over 16,000 Supreme Court cases from 1793 to the present. The body of Supreme Court decisions are, effectively, the final interpretation of the Constitution. Only an amendment to the Constitution can permanently overturn an interpretation and this has happened only four times in American history.
Harris v. Forklift Systems, Inc., 510 U.S. 17 (1993)
Harris v. Forklift Systems, Inc. No. 92-1168 Argued October 13, 1993 Decided November 9, 1993 510 U.S. 17
CERTIORARI TO THE UNITED STATES COURT OF APPEALS
FOR THE SIXTH CIRCUIT
Syllabus
Petitioner Harris sued her former employer, respondent Forklift Systems, Inc., claiming that the conduct of Forklift’s president toward her constituted "abusive work environment’’ harassment because of her gender in violation of Title VII of the Civil Rights Act of 1964. Declaring this to be "a close case,’’ the District Court found, among other things, that Forklift’s president often insulted Harris because of her gender and often made her the target of unwanted sexual innuendos. However, the court concluded that the comments in question did not create an abusive environment because they were not "so severe as to . . . seriously affect [Harris’] psychological wellbeing" or lead her to "suffe[r] injury." The Court of Appeals affirmed.
Held: To be actionable as "abusive work environment" harassment, conduct need not "seriously affect [an employee’s] psychological wellbeing" or lead the plaintiff to "suffe[r] injury." Pp. 21-23.
(a) The applicable standard, here reaffirmed, is stated in Meritor Savings Bank v. Vinson, 477 U.S. 57: Title VII is violated when the workplace is permeated with discriminatory behavior that is sufficiently severe or pervasive to create a discriminatorily hostile or abusive working environment, id., at 64, 67. This standard requires an objectively hostile or abusive environment -- one that a reasonable person would find hostile or abusive -- as well as the victim’s subjective perception that the environment is abusive. Pp. 21-22.
(b) Whether an environment is "hostile" or "abusive" can be determined only by looking at 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. The effect on the employee’s psychological wellbeing is relevant in determining whether the plaintiff actually found the environment abusive. But while psychological harm, like any other relevant factor, may be taken into account, no single factor is required. Pp. 22-23.
(c) Reversal and remand are required because the District Court’s erroneous application of the incorrect legal standard may well have influenced its ultimate conclusion that the work environment was not intimidating or abusive to Harris, especially given that the court found this to be a "close case." P. 23.
976 F. 2d 733, reversed and remanded.
O’CONNOR, J., delivered the opinion for a unanimous Court. SCALIA, J., post, p. 24, and GINSBURG, J., post, p. 25, filed concurring opinions.
Contents:
Chicago: U.S. Supreme Court, "Syllabus," Harris v. Forklift Systems, Inc., 510 U.S. 17 (1993) in 510 U.S. 17 510 U.S. 18. Original Sources, accessed November 22, 2024, http://originalsources.com/Document.aspx?DocID=FHI1TKDIEZSYG7P.
MLA: U.S. Supreme Court. "Syllabus." Harris v. Forklift Systems, Inc., 510 U.S. 17 (1993), in 510 U.S. 17, page 510 U.S. 18. Original Sources. 22 Nov. 2024. http://originalsources.com/Document.aspx?DocID=FHI1TKDIEZSYG7P.
Harvard: U.S. Supreme Court, 'Syllabus' in Harris v. Forklift Systems, Inc., 510 U.S. 17 (1993). cited in 1993, 510 U.S. 17, pp.510 U.S. 18. Original Sources, retrieved 22 November 2024, from http://originalsources.com/Document.aspx?DocID=FHI1TKDIEZSYG7P.
|