San Diego Law Review

Library of Congress Authority File


Document Type



This Casenote analyzes the significance and potential effects of the decision in Harris v. Forklift Systems, Inc., a Supreme Court case decided in November 1993. This case promulgates a framework for analysis of "hostile environment" sexual harassment claims arising under Title VII of the Civil Rights Act of 1964. The author sets forth the historical backdrop of the case, as well as exploring and comparing the effect of the decision in general with the decision's effect in the Ninth Circuit in particular. The author concludes that the Harris case potentially reduces women's chances of winning sexual harassment claims in the Ninth Circuit, thus an interpretation is recommended which would universally further the purposes of Title VII, while not limiting women's claims in the Ninth Circuit.