Harris v. Forklift Systems, Inc., 510 U.S. 17 (1993), is a US labor law case in which the Supreme Court of the United States clarified the definition of a "hostile" or "abusive" work environment under Title VII of the Civil Rights Act of 1964.
In a unanimous opinion written by Justice Sandra Day O'Connor, the Court held that a determination about whether a work environment is hostile or abusive requires a consideration of all relevant circumstances.
"[1] Teresa Harris claimed that the President of Forklift Systems, Inc, Charles Hardy, discriminated against her and subjected her to sexual innuendo at work on multiple occasions, including in front of other employees.
The District Court held that the evidence presented by Harris was not sufficient to show that Hardy's behavior actually affected the conditions of her employment; therefore, there was no Title VII violation.
Moreover, even without regard to these tangible effects, the very fact that the discriminatory conduct was so severe or pervasive that it created a work environment abusive to employees because of their race, gender, religion, or national origin offends Title VII's broad rule of workplace equality.
The appalling conduct alleged in Meritor, and the reference in that case to environments "'so heavily polluted with discrimination as to destroy completely the emotional and psychological stability of minority group workers,'" id., at 66, quoting Rogers v. EEOC, 454 F.2d 234, 238 (CA5 1971), cert.
We need not answer today all the potential questions it raises, nor specifically address the Equal Employment Opportunity Commission's new regulations on this subject, see 58 Fed.
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.