From the study of this legal case, we learn Judge of District Court (for the Middle District of Tennessee dismissed plaintiff’s case, who was a former employee of Forklift. The plaintiff declared that the conduct of president/employer, Charles Hardy, come to the hostile work environment and it was alleged that the repressive work environment allowed/facilitated harassment and discrimination, which was also based on gender (Justica, 2018).
The facts of the case
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- The former employee, Teresa Harris, filed Class/Title VII action, in which she alleged that the conduct of the accused, Charles Hardy, added hostile work environment (can be defined as harassment).
- The plaintiff/petitioner (Harris) alleged that the harassment was based on gender.
- We learn that the District Court had dismissed the action, as it concluded that not the psychological injury was apparent.
- District Court found that the president of Forklift (accused) often insulted Harris and the plaintiff was often made an aim of sexual innuendos. Nevertheless, the District Court concluded that the contentious remarks, which were directed towards Harris, did not create an abusive or hostile work environment.
- The former employee moved the appellant court.
The Main Issue before the Court
We know the fact that District Court for Middle District of Tennessee, discharged plaintiff’s claim that the work environment was abusive and in this work environment, harassment was based on gender. However, after the dismissal, plaintiffs moved the appellant court, where Supreme Court’s Justice decided the case.
Supreme Court’s Justice, Sandra Day O’Connor, had to decide whether the claim, of the plaintiff, that behavior (at the workplace) of Charles Hardy (president/employer) amounted to the hostile work environment and facilitated/encouraged gender-based harassment was true/valid or not. Also, the Supreme Court had to define factors and circumstances, which makes the work environment abusive or hostile.
Abusive work environment and harassment at workplace (which could be different nature) are serious issues, regarding which legislature has passed strong legislation. Courts too are quite sensitive regarding the issue of sexual harassment and abusive work environment. However, like all cases, a case is decided on evidence, which must be discernable, so that its reliability and validity could be tested.
The court had to decide, whether the Class VII action is actionable or not. Secondly, the court had to examine the validity of evidence, which was provided in front of the court. In fact, in a court of law, it all comes to down to the internal consistency and validity/credibility of evidence.
The Supreme concluded that under Title VII, a lawsuit was actionable at law; however, “a court must consider following circumstances and procedures.”
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- The conduct should not seriously affect the employee, both physically and psychologically.
- As per Meritor Standards, a work environment will classify as abusive work environment, when it can be objectively defined as an abusive work environment (abusive or objectively hostile work environment). Also, the perception of the victim (subjective) must be considered by the court as well.
- Whether an environment (work) is abusive or hostile (actionable), shall be determined after considering factors mentioned above (1 &2), not any one factor.
Title VII
Title VII prohibits discrimination, which could be any nature. It is a prevention against discrimination concerning “privileges of employment, terms, or conditions,” which might be based on 1) Race, 2) Color, 3) Sex, 4) Sexual-Orientation or 5) national origin. This kind of discrimination is not limited to few types, but rather it encompasses all sorts of incongruent treatment of both women and men in corporate/employment. It also embraces compelling people to work in a hostile, repressive, or abusive environment (EEOC.Gov, 2018).
Title VII is violated when the workplace is permeated with discriminatory intimidation, ridicule, and insult that is sufficiently severe or pervasive to alter conditions of victim’s employment and create the abusive working environment. (Civil Rights Act of 1964)
The decision of the Court
The decision of the Court pertained to the classification or definition of the abusive or hostile work environment. In the year 1993, political understandings were changing, which were also influenced laws, regulations, and legal understandings. In this Supreme Court’s decision, under Title VII of Civil Rights Acts of 1964, Supreme Court (of the United States), defined abusive or hostile work environment (Our Documents.Org, 2018).
It identified two factors and suggested that these factors a court should consider in totality, rather than in isolation, which means that two factors should be held/considered simultaneously and not in isolation. Also, The Supreme Court also concluded that both Reversal and Remand are essential, as District Court’s imperfect application, of existing legal understanding and standard, may have affected, its eventual inference, which was that work environment was not hostile or abusive for plaintiff/petitioner Harris.
The reasons for the decision
The reason(s) for the decisions were;
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- Despite acknowledging that fact that abusive and discriminatory remarks were made against Harris (and she was sexually harassed), the District Court dismissed the claim that the work environment was abusive or hostile.
- District Court’s application of legal standard was erroneous.
- The District Court and Circuit Court did not consider all the circumstances or factors, which were essential to consider.
Concurring or Dissenting Opinions
As the decision, of the Supreme Court, was unanimous; therefore, there were none rebellious opinions.
Did the Court make Correct Decision?
The court made a correct decision, as at that time, there was no clear definition or classification of abusive or hostile working environment. The Supreme Court of the United States identified circumstances, and factors, which may aid in defining or classifying a hostile or abusive work environment. Also, the Supreme Court also decided reversal and remand of the case, which was a correct decision.
References
EEOC.Gov. (2018). Title VII of the Civil Rights Act of 1964. Retrieved from https://www.eeoc.gov/laws/statutes/titlevii.cfm
Justica. (2018). Harris v. Forklift Systems, Inc., Retrieved from https://supreme.justia.com/cases/federal/us/510/17/case.html
Our Documents.Org. (2018). Civil Rights Act (1964). Retrieved from https://www.ourdocuments.gov/doc.php?flash=false&doc=97
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