Harris v. Forklift Systems Supreme Court case took place in 1993. This case is remarkable because in it, the Supreme Court, for the first time, gave a precise definition of the concept of an abusive work environment. More precisely, the Court ruled that for a work environment to be characterized as abusive, it is enough even to slightly affect the mental and physical well-being of an employee (510 U.S. 17, 114 S.Ct. 367). In addition to this, the environment could be regarded as hostile even if a victim subjectively finds it malicious and abusive (510 U.S. 17, 114 S.Ct. 367). The present essay examines this Harris v. Forklift Systems Supreme Court case, describes the final decision, and provides the author’s opinion on it.
Facts of the Case
The rental manager at Forklift Systems, Inc. and the injured party, Teresa Harris, claimed that she was discriminated against on a gender basis. Additionally, she, as well as her colleagues, were the subjects of Charles Hardy’s, the president of Forklift Systems, Inc, sexual innuendo. Teresa Harris was experiencing such behavior from her boss for almost two years. When the incident happened for the first time, Charles Hardy apologized to Harris and promised to alter his behavior. However, Hardy’s comments that Harris characterized as sexually offensive were repeated (Farrell & Saleh, 2021). The company president’s harassment forced Harris to quit her job and sue the former employer for the abusive work environment and gender bias.
The victim’s testimony reveals that the defendant had violated the Title VII of the Civil Rights Act of 1964. Title VII prohibits humiliating, insult and discriminating employees because of their personal characteristics such as gender, age, race, religion, and nationality. This is an equal opportunity law that protects the rights of employees and applicants at the workplace. This way, Teresa Harris’s advocates wanted the Forklift Systems to be punished for establishing an abusive working environment.
The Main Issue Before the Court
From the previously described facts, it could be inferred that the main issue was to prove that Forklift Systems indeed created an abusive working environment. The plaintiff was not raped, demoted, or fired because she is a woman. Without a doubt, Charles Hardy’s behavior was offensive and biased. For example, he suggested Teresa Harris “go to the Holiday Inn to negotiate [Harris’] raise” and called her “a dumb ass woman” (510 U.S. 17, 114 S.Ct. 367, p. 5). Besides, “he threw objects on the ground in front of Harris and other women and asked them to pick the objects up” (510 U.S. 17, 114 S.Ct. 367, p. 5). In spite of these facts, it is still possible to argue that these actions did not make the working environment at Forklift Systems hostile. Thus, the court had to decide whether Charles Hardy’s actions could be considered from the perspective of violation of the Title VII of the Civil Rights Act of 1964. In a more general sense, the task of the court was to answer the question of whether sexual harassment actually affects the psychological well-being of employees and, hence, creates a hostile work environment.
The Decision of the Court and the Reasons for the Decision
In the preceding section of the paper, it was noted that the court had to examine the case of Forklift Systems to reveal whether the offensive behavior of its president created an abusive working atmosphere there. The judges of the federal district court made a decision in favor of Forklift Systems. This decision means that the court found that Hardy’s outrageous actions significantly harmed the plaintiff’s psychological state. Harris appealed against this decision; however, the Sixth Circuit Court of Appeals supported the federal district court ruling. Afterward, the litigation between Teresa Harris and Forklift Systems passed to the Supreme Court. Fortunately for Teresa Harris and all American women and minorities, the Supreme Court ruled in favor of her and found Forklift Systems guilty of violating Title VII and creating a hostile atmosphere in the team.
As it has already been mentioned, Teresa Harris was not sexually assaulted and suffered only from comments with the related implied sense. For this reason, the judges rejected the claim of concrete psychological harm caused to the victim. Nevertheless, the court managed to “set forth a standard that “takes a middle path between…conduct that is merely offensive” and that which results in “a tangible psychological injury” (510 U.S. 17, 114 S.Ct. 367, p. 6). This decision means that the court recognized the significance of the subjective perspective of the situation when dealing with the issue of abuse at the workplace.
Even though objectively Charles Hardy did nothing but was rude to his female subordinates, subjectively, this suppressed the plaintiff and, hence, raised a question of the working environment at Forklift Systems. Apparently, there is no “mathematically precise test” to once and for all determine the extent of abusiveness of a workplace (510 U.S. 17, 114 S.Ct. 367, p. 7). This way, it is essential to look at this situation in the eyes of a plaintiff and combine subjective and objective factors.
The Concurring Opinions
The dissenting concurring opinion concerning the Harris v. Forklift Systems case was expressed by the federal district court and the Sixth Circuit Court of Appeals. More exactly, judges found that the rude words and actions of the defendant did not interfere with the plaintiff’s work performance (510 U.S. 17, 114 S.Ct. 367). In other words, even though what Charles Hardy did was actually offensive, this did not deprive Teresa Harris of the opportunity to work as usual and put her physical well-being and life in danger. What is more, as one of the federal court judges put it, “I do not believe that he created a working environment so poisoned as to be intimidating or abusive to [Harris]” (510 U.S. 17, 114 S.Ct. 367, p. 5). From these words, it seems that the judges expected Teresa Harris to treate as something that goes without saying until it does not cause tangible harm.
In addition to what has already been mentioned, an ordinary person might suggest that there is no reason to punish Forklift Systems because their president is simply a person with such an abusive mindset. What is more, it is not clear how he treated his male subordinates and whether he was rude to them as well. The inference from this view is that Charles Hardy did not deprive Teresa Harris of equal rights for employment and was a person who was taught to disrespect women.
Personal Opinion
I entirely support the final decision of the US Supreme Court. From my point of view, it seems right that it is not necessary to psychologically hurt a person to destroy the stability and respectfulness of the working environment. Indeed, to some extent, it seems as if Teresa Harris sued her former employer for no reason because he did not fire, beat, or rape her. At the same time, it is fair that Teresa Harris raised this question because there was no guarantee that Hardy’s name-calling and unambiguous approaches would not turn into something more severe and harmful. What is more, this case shows that employers should be responsible not only for the working conditions and safety of the staff members but also for their own behavior and attitude to them.
References
510 U.S. 17, 114 S.Ct. 367. Harris v. Forklift Systems Supreme Court case.
Farrell, H. M., & Saleh, F. M. (2021). Boundary, harassment, and the# MeToo Era. In Fabian M. Saleh, John M. Bradford, Daniel J. Brodsky (Eds.), Sex Offenders: Identification, Risk Assessment, Treatment, and Legal Issues, (pp. 461-465). Oxford University Press.