Harris v. Forklift Systems, Inc.: Difference between revisions

Harris v. Forklift Systems, Inc.
Harris v. Forklift Systems, Inc.
	Supreme Court of the United States
Argued October 13, 1993; Decided November 9, 1993
Full case name	Teresa Harris, Petitioner v. Forklift Systems, Inc.
Docket no.	92–1168
Citations	510 U.S. 17 (more) 114 S.Ct. 367, 126 L.Ed.2d 295
Argument	Oral argument
Case history
Prior	On writ of certiorari to the United States Court of Appeals for the Sixth Circuit
Court membership
	Chief Justice William Rehnquist Associate Justices Harry Blackmun · John P. Stevens; Sandra Day O'Connor · Antonin Scalia; Anthony Kennedy · David Souter; Clarence Thomas · Ruth Bader Ginsburg
Case opinions
Majority	O'Connor, joined by unanimous
Concurrence	Scalia
Concurrence	Ginsburg
Laws applied
	42 U.S.C. § 2000 et seq.

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Harris v. Forklift Systems, Inc., 510 US 17 (1993), is a US labor law case in which the United States of America Supreme Court 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]

Facts

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]

Teresa Harris claimed that the President of Forklift Systems, Inc, Charles Hardy, discriminated against her and subjected her to sexual innuendo at work on multiple occasions, including in front of other employees. She was a manager at the equipment rental company, between April 1985 and October 1987.^[1] Harris first complained directly to Hardy about his behavior in August 1987, 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 under Title VII of the Civil Rights Act of 1964.

Judgment

District Court of Tennessee

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. 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]

Sixth Circuit, Court of Appeals

The United States Court of Appeals, Sixth Circuit, affirmed the District Court's decision.^[2] It said a ‘hostile environment’ had to ‘seriously affect psychological well-being’ or mean the plaintiff ‘suffer injury’.

Supreme Court

The US Supreme Court, reversing the Court's below, held an abusive environment ‘that does not seriously affect employees’ psychological well-being can and often will detract from... job performance, discourage employees from staying on the job, or keep them from advancing in their careers.’ If the environment ‘would reasonably be perceived, and is perceived, as hostile or abusive’ this is enough. It remanded the case.^[3] This suit was later settled outside of Court, and the terms were not released.^[4]

Notes

^ ^a ^b ^c ^d "Legal Information Institute". Cornell University Law School. Retrieved October 4, 2016.
^ Harris v. Forklift Systems, Inc., 976 F.2d 733 (1992).
^ Harris v. Forklift Sys., Inc., 510 U.S. 17, 23 (1993).
^ "Harris v. Forklift Systems | law case". Encyclopædia Britannica. Retrieved 2016-10-06.

References

[:0-1] "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". Encyclopædia Britannica. Retrieved 2016-10-06.

[1]

[2]

[3]

[4]

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+<!-- Please use Maroonbook citation style -->
 {{Infobox SCOTUS case
   |Litigants=Harris v. Forklift Systems, Inc.
@@ Line 23: / Line 24: @@
   |LawsApplied=42 U.S.C. § 2000 et seq.
 }}
-'''Harris v. Forklift Systems, Inc.''', 510 U.S. 17 (1993), is a case in which the [[Supreme Court of the United States|United States of America Supreme Court]] 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 [[Associate Justice of the United States Supreme Court|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.<ref name=":0">{{Cite web|url=https://www.law.cornell.edu/supct/html/92-1168.ZO.html|title=Legal Information Institute|last=|first=|date=|website=Cornell University Law School|publisher=|access-date=October 4, 2016}}</ref>
+'''''Harris v. Forklift Systems, Inc.''''', [https://supreme.justia.com/cases/federal/us/510/17/ 510 US 17] (1993), is a [[US labor law]] case in which the [[Supreme Court of the United States|United States of America Supreme Court]] 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 [[Associate Justice of the United States Supreme Court|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.<ref name=":0">{{Cite web|url=https://www.law.cornell.edu/supct/html/92-1168.ZO.html|title=Legal Information Institute|last=|first=|date=|website=Cornell University Law School|publisher=|access-date=October 4, 2016}}</ref>
-==Background==
+==Facts==
-===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."<ref name=":0" />
+Teresa Harris claimed that the President of Forklift Systems, Inc, Charles Hardy, discriminated against her and subjected her to sexual innuendo at work on multiple occasions, including in front of other employees. She was a manager at the equipment rental company, between April 1985 and October 1987.<ref name=":0" /> Harris first complained directly to Hardy about his behavior in August 1987, 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 under Title VII of the [[Civil Rights Act of 1964]].
-===Harris' sexual harassment suit===
-Teresa Harris was a manager at an equipment rental company, Forklift Systems Inc., between April 1985 and October 1987.<ref name=":0" /> Harris alleged that the president of Forklift Systems, Charles Hardy, subjected her 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<ref name=":0" /> 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.<ref name=":0" />
+==Judgment==
-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.<ref name=":0" /> 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.<ref name=":0" /> The United States Court of Appeals affirmed the District Court's decision.<ref>''Harris v. Forklift Systems, Inc.'', 976 F.2d 733 (1992).</ref>
+===District Court of Tennessee===
+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. 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.<ref name=":0" />
-==Opinion of the Court==
+===Sixth Circuit, Court of Appeals===
-The United States Supreme Court decided to reverse the Sixth Circuit's decision and remanded the case.<ref>''Harris v. Forklift Sys., Inc.'', 510 U.S. 17, 23 (1993).</ref> This suit was later settled outside of Court, and the terms were not released.<ref>{{Cite news|url=https://www.britannica.com/topic/Harris-v-Forklift-Systems|title=Harris v. Forklift Systems {{!}} law case|newspaper=Encyclopædia Britannica|access-date=2016-10-06}}</ref>
+The United States Court of Appeals, Sixth Circuit, affirmed the District Court's decision.<ref>''Harris v. Forklift Systems, Inc.'', 976 F.2d 733 (1992).</ref> It said a ‘hostile environment’ had to ‘seriously affect psychological well-being’ or mean the plaintiff ‘suffer injury’.
+===Supreme Court===
+The US Supreme Court, reversing the Court's below, held an abusive environment ‘that does not seriously affect employees’ psychological well-being can and often will detract from... job performance, discourage employees from staying on the job, or keep them from advancing in their careers.’ If the environment ‘would reasonably be perceived, and is perceived, as hostile or abusive’ this is enough. It remanded the case.<ref>''Harris v. Forklift Sys., Inc.'', 510 U.S. 17, 23 (1993).</ref> This suit was later settled outside of Court, and the terms were not released.<ref>{{Cite news|url=https://www.britannica.com/topic/Harris-v-Forklift-Systems|title=Harris v. Forklift Systems {{!}} law case|newspaper=Encyclopædia Britannica|access-date=2016-10-06}}</ref>
 ==See also==
+{{Slist employment equality}}
+*[[US labor law]]
 * [[List of United States Supreme Court cases]]
 * [[Lists of United States Supreme Court cases by volume]]
 * [[List of United States Supreme Court cases by the Rehnquist Court]]
+==Notes==
+{{refs|2}}
 ==References==
+*
-{{Reflist}}
 [[Category:United States Supreme Court cases]]
@@ Line 51: / Line 60: @@
 [[Category:Sexual harassment in the United States]]
 [[Category:United States Supreme Court cases of the Rehnquist Court]]
+[[Category:United States labor case law]]

v t e Equal treatment
Equal Pay Act of 1963, 29 USC §206(d)
Corning Glass Works v Brennan 417 US 188 (1974)
Civil Rights Act of 1964, 42 USC §2000e-2
Age Discrimination in Employment Act of 1967, 29 USC §§621-634
Texas Department of Community Affairs v. Burdine 450 US 248 (1981)
St. Mary's Honor Center v. Hicks 509 US 502 (1993)
Federal Rules of Civil Procedure Rule 23
International Brotherhood of Teamsters v. US 431 US 324 (1977)
General Telephone Co. of Southwest v. Falcon 457 US 147 (1982)
Meritor Savings Bank v. Vinson 477 US 57 (1986)
Harris v. Forklift Systems, Inc. 510 US 17 (1993)
Faragher v. City of Boca Raton 524 US 775 (1998)
See United States labor law and Civil rights movement