Harris V. Forklift Systems Inc. Analysis

Harris v. Forklift Systems Inc. Analysis

Facts

The plaintiff, Teresa Harris, sued her working company Forklift Systems Inc., the defendant in sexual harassment suit. The story started with: Harris worked in the tools rental company as a manager between April 1985 and October 1987. Her boss, the chair of Forklift Systems Inc., Charles Hardy, always exposed Harris to gender-based oral abusive remark while she was working in the company. Harris and other female workers were targeted by the president, Hardy, with sexual innuendos, sexually expressive remarks, and sexually obviously movements. She said that the sexually harassing behavior of Hardy caused her to suffer symptoms that is similar to the PTSD. For example, Hardy called Harris as “a dumb ass woman” and proposing to go Holiday Inn to discuss opportunity to raise or promotion. Harris has confronted Hardy about his sexist behavior, he apologized and stopped for sometimes, so, she stayed at work, but soon, he resumed the sexual behavior to Harris. Therefore, Harris resigned from the job after a month. The plaintiff, Teresa Harris, claimed Forklift about the Hardy’s sexist and sexual discrimination which had generated a hostile and offensive working environment for her based on her sexual category under the Title VII of the Civil Rights Act of 1964, which is about the unlawful practice for employers to categorize against any individual on the basis of sex, race, religion or natural origin. The district court concluded that Hardy did not create abusive work environment,” so, Harris appealed to the United States Court of Appeals.

History

A U.S. magistrate judge heard the case and the recommendation was accepted by the district court. The court determined the defendant was crude and bad-mannered, but the United States District Court for the District of Tennessee concluded that the harassment made by Hardy did not create an “abusive work environment” although Harris and “reasonable women” might find it offensive or uncomfortable under the circumstances. The reason was that it did not create serious psychological injury or affect the performance of Harris at work. The court said that Harris did not provide adequate or clear evidence to show that the plaintiff’s conduct influenced the performance of Harris’s job or caused severe psychological damage to the employee; therefore, Hardy did not violate to the Title of VII. So, it became a “Close Case.” Harris appealed to the United States Court of Appeals that affirmed the decision of District Court.

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