Harris v. Forklift Systems, Inc.

Teresa Harris (plaintiff) endured over two years of gender-driven sexual comments, innuendos, and gestures from Forklift's (defendant) president Charles Hardy; even after Harris confronted him and Hardy apologized and promised to stop, he resumed the offensive behavior, and Harris quit about a month later. Harris sued for hostile work environment sex discrimination under Title VII; the district court found a reasonable woman would have found Hardy's conduct offensive but concluded it did not rise to an actionable hostile work environment because it caused no severe psychological injury and did not interfere with Harris's job performance, and the Supreme Court granted certiorari to resolve a circuit split over whether such injury is required.