Supreme Court of the United States · 1993-11-09
Case and law context
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
| Case | Element | Holding and scope | Variant | Exact source quotations |
|---|---|---|---|---|
| /us/510/0017-01 — Supreme Court of the United States · 1993 | Adverse employment action affecting compensation, terms, conditions, privileges, or status | not_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 variant | No source quotation recorded for this block. |
| /us/510/0017-01 — Supreme Court of the United States · 1993 | Discriminatory 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.Source: docroot/ir/caselaw/us_510.jsonl#/us/510/0017-01; Unicode character offsets [315:480] (end exclusive); SHA-256 d1ea22ac767a8da9f8196f8e0b5a1a9926fdbf322dd6be788952d6040b67ddef.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.Source: docroot/ir/caselaw/us_510.jsonl#/us/510/0017-01; Unicode character offsets [486:652] (end exclusive); SHA-256 d1ea22ac767a8da9f8196f8e0b5a1a9926fdbf322dd6be788952d6040b67ddef.He threw objects on the ground in front of Harris and other women, and asked them to pick the objects up.Source: docroot/ir/caselaw/us_510.jsonl#/us/510/0017-01; Unicode character offsets [1126:1231] (end exclusive); SHA-256 d1ea22ac767a8da9f8196f8e0b5a1a9926fdbf322dd6be788952d6040b67ddef. |
| /us/510/0017-01 — Supreme Court of the United States · 1993 | Covered entity: employer, employment agency, or labor organization | not_reached Excluded from merits counts rule-announced / merits claim: (a)(1) | Unspecified variant | No source quotation recorded for this block. |
| /us/510/0017-01 — Supreme Court of the United States · 1993 | Severe or pervasive hostile or abusive working environment | not_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.”Source: docroot/ir/caselaw/us_510.jsonl#/us/510/0017-01; Unicode character offsets [653:861] (end exclusive); SHA-256 d1ea22ac767a8da9f8196f8e0b5a1a9926fdbf322dd6be788952d6040b67ddef.Again in front of others, he suggested that the two of them “go to the Holiday Inn to negotiate [Harris’] raise.”Source: docroot/ir/caselaw/us_510.jsonl#/us/510/0017-01; Unicode character offsets [891:1004] (end exclusive); SHA-256 d1ea22ac767a8da9f8196f8e0b5a1a9926fdbf322dd6be788952d6040b67ddef.Hardy occasionally asked Harris and other female employees to get coins from his front pants pocket.Source: docroot/ir/caselaw/us_510.jsonl#/us/510/0017-01; Unicode character offsets [1019:1119] (end exclusive); SHA-256 d1ea22ac767a8da9f8196f8e0b5a1a9926fdbf322dd6be788952d6040b67ddef.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?”Source: docroot/ir/caselaw/us_510.jsonl#/us/510/0017-01; Unicode character offsets [1605:1831] (end exclusive); SHA-256 d1ea22ac767a8da9f8196f8e0b5a1a9926fdbf322dd6be788952d6040b67ddef.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.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.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.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.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.”Source: docroot/ir/caselaw/us_510.jsonl#/us/510/0017-01; Unicode character offsets [7173:7345] (end exclusive); SHA-256 d1ea22ac767a8da9f8196f8e0b5a1a9926fdbf322dd6be788952d6040b67ddef.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,”Source: docroot/ir/caselaw/us_510.jsonl#/us/510/0017-01; Unicode character offsets [9400:9576] (end exclusive); SHA-256 d1ea22ac767a8da9f8196f8e0b5a1a9926fdbf322dd6be788952d6040b67ddef. |
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.