/us/510/0017-01

Supreme Court of the United States · 1993-11-09

Original case on neochart.com

Case and law context

42 U.S.C. § 2000e-2

Role: rule-announced; posture: civil; bench trial (magistrate report adopted) for employer, affirmed by CA6; certiorari on whether hostile-environment harassment requires serious psychological injury; result: remanded; claim: (a)(1)

Instances and excluded annotation blocks

Annotation blocks, including explicitly excluded context
CaseElementHolding and scopeVariantExact source quotations
/us/510/0017-01 — Supreme Court of the United States · 1993Adverse employment action affecting compensation, terms, conditions, privileges, or statusnot_reached
Excluded from merits counts
rule-announced / merits

claim: (a)(1)

Plaintiff quit after the harassment resumed; no constructive-discharge or tangible-action question is discussed. The Court treats the abusive environment itself as the discrimination in "terms, conditions, or privileges".
Unspecified variantNo source quotation recorded for this block.
/us/510/0017-01 — Supreme Court of the United States · 1993Discriminatory causation ("because of" protected trait)satisfied
Excluded from merits counts
applied / lower-court

basis: proved; claim: (a)(1)

Magistrate's finding, recited and not disturbed; the sex-based character of the conduct was not in dispute before the Court.
sex-based-harassment/gender-insults-and-sexual-innuendo-by-company-president
Teresa Harris worked as a manager at Forklift Systems, Inc., an equipment rental company, from April 1985 until October 1987. Charles Hardy was Forklift’s president.
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Evidence kind: fact; polarity: supports; absent flag: 0; quoted-rule flag: 0 (1 = tagged; 0 = not tagged)

Magistrate found that, throughout Harris’ time at Forklift, Hardy often insulted her because of her gender and often made her the target of unwanted sexual innuendos.
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Evidence kind: fact; polarity: supports; absent flag: 0; quoted-rule flag: 0 (1 = tagged; 0 = not tagged)

He threw objects on the ground in front of Harris and other women, and asked them to pick the objects up.
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Evidence kind: fact; polarity: supports; absent flag: 0; quoted-rule flag: 0 (1 = tagged; 0 = not tagged)

/us/510/0017-01 — Supreme Court of the United States · 1993Covered entity: employer, employment agency, or labor organizationnot_reached
Excluded from merits counts
rule-announced / merits

claim: (a)(1)

Unspecified variantNo source quotation recorded for this block.
/us/510/0017-01 — Supreme Court of the United States · 1993Severe or pervasive hostile or abusive working environmentnot_reached
Excluded from merits counts
rule-announced / merits

claim: (a)(1)

Court fixes the test (objective + subjective abusiveness, totality of circumstances; no psychological-injury requirement) but does not apply it: whether the president's conduct met it is left for remand. The trial court's not-satisfied finding is vacated because it rested on the wrong standard. The `held` lines reject the lower court's test; they are not an application to facts.
severe-or-pervasive/psychological-injury-not-required
Hardy told Harris on several occasions, in the presence of other employees, “You’re a woman, what do you know” and “We need a man as the rental manager”; at least once, he told her she was “a dumb ass woman.”
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Evidence kind: fact; polarity: supports; absent flag: 0; quoted-rule flag: 0 (1 = tagged; 0 = not tagged)

Again in front of others, he suggested that the two of them “go to the Holiday Inn to negotiate [Harris’] raise.”
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Evidence kind: fact; polarity: supports; absent flag: 0; quoted-rule flag: 0 (1 = tagged; 0 = not tagged)

Hardy occasionally asked Harris and other female employees to get coins from his front pants pocket.
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Evidence kind: fact; polarity: supports; absent flag: 0; quoted-rule flag: 0 (1 = tagged; 0 = not tagged)

But in early September, Hardy began anew: While Harris was arranging a deal with one of Forklift’s customers, he asked her, again in front of other employees, “What did you do, promise the guy . . . some [sex] Saturday night?”
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Evidence kind: fact; polarity: supports; absent flag: 0; quoted-rule flag: 0 (1 = tagged; 0 = not tagged)

Conduct that is not severe or pervasive enough to create an objectively hostile or abusive work environment — an environment that a reasonable person would find hostile or abusive — is beyond Title VII’s purview.
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Evidence kind: rule; polarity: not recorded; absent flag: 0; quoted-rule flag: 0 (1 = tagged; 0 = not tagged)

if the victim does not subjectively perceive the environment to be abusive, the conduct has not actually altered the conditions of the victim’s employment, and there is no Title VII violation.
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Evidence kind: rule; polarity: not recorded; absent flag: 0; quoted-rule flag: 0 (1 = tagged; 0 = not tagged)

So long as the environment would reasonably be perceived, and is perceived, as hostile or abusive, Meritor, supra, at 67, there is no need for it also to be psychologically injurious.
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Evidence kind: rule; polarity: not recorded; absent flag: 0; quoted-rule flag: 0 (1 = tagged; 0 = not tagged)

These may include the frequency of the discriminatory conduct; its severity; whether it is physically threatening or humiliating, or a mere offensive utterance; and whether it unreasonably interferes with an employee’s work performance.
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Evidence kind: rule; polarity: not recorded; absent flag: 0; quoted-rule flag: 0 (1 = tagged; 0 = not tagged)

We therefore believe the District Court erred in relying on whether the conduct “seriously affect[ed] plaintiff’s psychological well-being” or led her to “suffe[r] injury.”
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Evidence kind: held; polarity: not recorded; absent flag: 0; quoted-rule flag: 0 (1 = tagged; 0 = not tagged)

The District Court’s application of these incorrect standards may well have influenced its ultimate conclusion, especially given that the court found this to be a “close case,”
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Evidence kind: held; polarity: not recorded; absent flag: 0; quoted-rule flag: 0 (1 = tagged; 0 = not tagged)

Court interpretations recorded from this case

interpretation

Conduct that is not severe or pervasive enough to create an objectively hostile or abusive work environment — an environment that a reasonable person would find hostile or abusive — is beyond Title VII’s purview.

/us/510/0017-01 — Supreme Court of the United States · 1993

Conduct that is not severe or pervasive enough to create an objectively hostile or abusive work environment — an environment that a reasonable person would find hostile or abusive — is beyond Title VII’s purview.
Source: docroot/ir/caselaw/us_510.jsonl#/us/510/0017-01; Unicode character offsets [5643:5855] (end exclusive); SHA-256 d1ea22ac767a8da9f8196f8e0b5a1a9926fdbf322dd6be788952d6040b67ddef.

Harassment so severe or pervasive as to alter the conditions of the victim's employment and create an objectively and subjectively abusive working environment.

interpretation

if the victim does not subjectively perceive the environment to be abusive, the conduct has not actually altered the conditions of the victim’s employment, and there is no Title VII violation.

/us/510/0017-01 — Supreme Court of the United States · 1993

if the victim does not subjectively perceive the environment to be abusive, the conduct has not actually altered the conditions of the victim’s employment, and there is no Title VII violation.
Source: docroot/ir/caselaw/us_510.jsonl#/us/510/0017-01; Unicode character offsets [5866:6058] (end exclusive); SHA-256 d1ea22ac767a8da9f8196f8e0b5a1a9926fdbf322dd6be788952d6040b67ddef.

Harassment so severe or pervasive as to alter the conditions of the victim's employment and create an objectively and subjectively abusive working environment.

interpretation

So long as the environment would reasonably be perceived, and is perceived, as hostile or abusive, Meritor, supra, at 67, there is no need for it also to be psychologically injurious.

/us/510/0017-01 — Supreme Court of the United States · 1993

So long as the environment would reasonably be perceived, and is perceived, as hostile or abusive, Meritor, supra, at 67, there is no need for it also to be psychologically injurious.
Source: docroot/ir/caselaw/us_510.jsonl#/us/510/0017-01; Unicode character offsets [7638:7821] (end exclusive); SHA-256 d1ea22ac767a8da9f8196f8e0b5a1a9926fdbf322dd6be788952d6040b67ddef.

Harassment so severe or pervasive as to alter the conditions of the victim's employment and create an objectively and subjectively abusive working environment.

interpretation

These may include the frequency of the discriminatory conduct; its severity; whether it is physically threatening or humiliating, or a mere offensive utterance; and whether it unreasonably interferes with an employee’s work performance.

/us/510/0017-01 — Supreme Court of the United States · 1993

These may include the frequency of the discriminatory conduct; its severity; whether it is physically threatening or humiliating, or a mere offensive utterance; and whether it unreasonably interferes with an employee’s work performance.
Source: docroot/ir/caselaw/us_510.jsonl#/us/510/0017-01; Unicode character offsets [8291:8527] (end exclusive); SHA-256 d1ea22ac767a8da9f8196f8e0b5a1a9926fdbf322dd6be788952d6040b67ddef.

Harassment so severe or pervasive as to alter the conditions of the victim's employment and create an objectively and subjectively abusive working environment.