## Facts

- Teresa Harris worked as a manager at an equipment rental company from 1985 to 1987.
- The company’s president, Charles Hardy, repeatedly made gender-based insults and sexual comments toward Harris in the workplace.
- Hardy’s conduct included statements such as “You’re a woman, what do you know,” “We need a man as the rental manager,” and calling her “a dumb ass woman.”
- He also made sexual innuendos in front of others, including suggesting they “go to the Holiday Inn” to negotiate her raise and later insinuating she promised a customer sex.
- Harris complained in August 1987; Hardy apologized and promised to stop, but the conduct resumed.
- Harris quit on October 1, 1987, and filed suit under Title VII alleging a hostile or abusive work environment.

## Issues

1. Whether Title VII requires a plaintiff alleging hostile-environment sex harassment to prove that the conduct seriously harmed psychological well-being or caused concrete injury.
2. What standard governs whether workplace conduct is sufficiently hostile or abusive to violate Title VII.

## Decision

- The Supreme Court unanimously reversed and remanded.
- The Court held that Title VII does not require proof that harassment seriously affects psychological well-being or causes a specific injury.
- The Court reaffirmed that a hostile environment exists when discriminatory intimidation, ridicule, and insult are sufficiently severe or pervasive to alter employment conditions and create an abusive environment.
- The Court ruled that the lower courts applied an incorrect legal standard, which may have affected the outcome, particularly because the trial court characterized the matter as a close case.

## Legal Principles

- Hostile-environment harassment under Title VII is actionable when the workplace is permeated with discriminatory intimidation, ridicule, and insult that is sufficiently severe or pervasive to alter the conditions of employment and create an abusive environment.
- The environment must be both objectively hostile (a reasonable person would find it hostile or abusive) and subjectively hostile (the plaintiff perceived it as hostile or abusive).
- Courts evaluate hostility by considering the totality of the circumstances, including frequency, severity, whether the conduct is threatening or humiliating versus a mere offensive utterance, and whether it unreasonably interferes with work performance.
- Psychological harm may be considered as one factor, but it is not a required element and no single factor is dispositive.

## Conclusion

The Court rejected a psychological-injury requirement for Title VII hostile-environment claims and directed lower courts to apply an objective-and-subjective, totality-of-the-circumstances test focused on whether sex-based conduct is sufficiently severe or pervasive to create an abusive working environment.


Harris v. Forklift Sys., Inc., 510 U.S. 17 (1993)