Harris V. Forklift Systems Inc Summary

Case Name, Citation, and Court:
Harris v. Forklift Systems, Inc.,
510 U.S. 17, 114 S.Ct 367, 126 L.Ed.2d 295 (1993)
United States Supreme Court
Summary of the Key Facts:
The petitioner Harris suede Forklift Systems, Inc and claiming the conduct of sexual harassment from the Forklift's president which create " abusive work environment."
Ms. Harris believe which was the violation of Title VII of the Civil Right Act of 1964 because the harassment that she experienced was based on gender.
Mr. Hardy, the president of Forklift Systems, Inc, told sexually and professionally inappropriate comments and statements in front of other employees on several occasions.
Ms. Harris complained to Mr. Hardy about his conduct before, but Mr. Hardy responds that he was only joking, and he apologized for his actions. Also, Mr. Hardy promised that he world stop, and base on his promise Ms. Harris stayed on the job. However, a few months later Mr. Hardy began his arrestments again as he did before.

At the lower level Magistrate court, found this case as a close case because the court believe Mr.

Hardy's conduct may offended the individual but it's not enough to create abusive work environment. Ms. Harris doesn’t suffer any physical injury and it's hard to assume her psychological wellbeing.
Also, District Court of Middle District of Tennessee Adopted the Magistrate court result and found this case as a close case because they believe the facts are not enough to lead to abusive work environment. They also make this decision by following precedent circuit case, Rabidue v. Osceola Refining

Co.
The Appeals court, the 6th U.S circuit court juries decide that Mr. Hardy conducts were obvious enough to warrant for harassment. However, the class of plaintiff seeking to recover from this case is limited to those who suffered harm. The court believe that Ms. Harris must suffered legal harm to sued Forklift Systems for creating "abusive work environment."
Issue:
The consequences that Ms. Harris experienced were good enough to sue Forklift System, Inc., under the Title VII of the Civil Right Act of 1964 as an "abusive work environment" harassment?
Holding:
Yes
Summary of the Court’s Reasoning:
First, the title 7th of Civil Right act forbid in discrimination in employment on basis of race, color, ethnicity, religion, gender or country origin. For that reason, Mr. Harris can sue Forklift System, Inc., because Mr. Hardy conduct were very much related to gender discrimination.
The Title 7th come into play before the harassing conduct lead to nervous breakdown. Mr. Hardy action may not be seriously affect reasonable employee's psychological wellbeing, however; the type of harassing which Mr. Hardy conduct could detract from employee's job performance and could create abusive work environment for employee.
The Supreme court refer back to holding of Meritor Saving Bank vs Vinson, 477 U.S 57.66 (1986): state that "plaintiff may establish a violation of Title VII by proving that discrimination based on sex has create a hostile or abusive work environment." Title 7th specify that if one members of sex were experiencing the unfavorable terms employment which member of the other sex does not experienced.
Even though, Mr. Hardy conducts were not severely harm or damaged physical or psychological wellbeing of Ms. Harris, Harris was able to prove that her actual productivity has declined because of the harassment and its altered her working conditions. Which prove that Mr. Hardy actions created the abusive work environment.
Supreme court also refer back to similar case from 1988. Davis v. Monsanto Chemical Co., 858 F. 2d 345, 349 (CA6 1988) which reaffirms that a reasonable person who experienced discriminatory conduct would find themselves declined in work performance and undergo abusive work conditions as Ms. Harris claimed.