In April of 1985, Theresa Harris started work as a manager for Forklift Systems, Inc. (Forklift). During Harris’s two and one-half years with Forklift, she was subjected to gender-based insults and unwanted sexual innuendos from Charles Hardy, the firm’s president. Several times, for example, Hardy told Harris: “You’re a woman, what do you know?” and “We need a man as the rental manager.” Once, he suggested that he and Harris negotiate her raise at the Holiday Inn. Hardy also would ask Harris and other female employees to get coins from his front pants pocket, and to pick up objects that he threw on the ground. After Harris complained to Hardy in August of 1987, he apologized and promised to stop his offensive behavior. In early September, however, he inquired whether Harris had promised sex to a customer with whom she had concluded a deal on Forklift’s behalf. Is Hardy’s behavior sufficiently severe or pervasive to raise a possible work environment sexual harassment claim? Is the test here whether Harris subjectively thought that Hardy’s behavior was severe or pervasive, or whether a reasonable person would think so? Whether a reasonable woman would think so? Does Harris have to show actual psychological harm to recover for work environment harassment?

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