ABSTRACT

Teresa Harris was a manager at Forklift Systems, Inc., an equipment rental firm, from April 1985 to October 1987. The company's president, Charles Hardy, frequently and publicly made derogatory, gender-based comments to Harris and other female employees. Overruling both the district and the appeals courts, the Supreme Court upheld Harris's claim of sexual harassment. Writing for a unanimous Court, Justice Sandra Day O'Connor said that an establishment of psychological injury was not required for a claim of sexual harassment. A discriminatorily abusive work environment, even one that does not seriously affect employees' psychological well-being, can and often will detract from employees' job performance, discourage employees from remaining on the job, or keep them from advancing in their careers." The Court said that an "abusive environment" can be determined only by looking at the totality of circumstances. The Court admitted that these standards were somewhat imprecise, but could find "no test more faithful to the inherently vague" language of Title VII.