In the case of Teresa Harris v. Forklift Systems, Inc., 1993, the U.S. Supreme Court ruled that a plaintiff does not need to prove psychological injury in order to claim damages under Title VII of the Civil Rights Act for a hostile work environment due to sexual harassment. The court held that as long as an environment can be perceived as abusive by a reasonable person and is perceived so by the victim, it violates Title VII regardless of whether it causes tangible psychological harm or not. This decision was significant because it broadened protections against workplace sexual harassment and clarified standards for determining what constitutes a hostile work environment.

In the dissenting opinion for Teresa Harris v. Forklift Systems, Inc., Justice Scalia argued that while he agreed with the majority's decision to remand the case back to lower courts, he disagreed with their reasoning. He contended that a hostile work environment should not be considered discriminatory unless it seriously affects an employee’s psychological well-being or leads them to suffer injury. According to him, this would require proof of actual psychological harm rather than just perceived offensiveness of behavior in question. He also criticized the majority for failing to provide clear guidelines on what constitutes a hostile work environment and how severe or pervasive such conduct must be before it becomes actionable under Title VII of Civil Rights Act 1964.