In the United States, as well as in many parts of the world, the lack of gender equality has created many cases of harassment, discriminatory behavior and comments towards women in the workplace Work. Women are generally paid less than men and typically hold smaller positions in companies than men. According to a 2017 Pew Research Center analysis of average hourly earnings of workers in the United States – “women earned 82% of what men earned” (Graf, Brown, Patten, para 1). In 1980, the pay gap between men and women was 89 cents, today it has reduced to 18 cents. That said, even though the pay gap between men and women has narrowed, it still exists today. Say no to plagiarism. Get a tailor-made essay on "Why Violent Video Games Shouldn't Be Banned"? Get an original essay In addition to pay inequality between men and women, there are also sometimes issues of gender-based conduct and harassment in the workplace . An example of this is shown in the 1992 court case Harris v. Forklift Systems. Forklift Systems employee Teresa Harris has filed a civil rights lawsuit against Forklift Systems president Charles Hardy, alleging he created an "abusive work environment" and harassed and targeted her because of her gender. The magistrate found that Hardy made comments several times towards him, such as; “You're a woman, what do you know?”, “We need a man to be a rent administrator,” calling her “an idiot” and even suggesting that the two “go to the Holiday Inn to negotiate increases” (Harris v. . Forklidt Systems, Inc., 510 US 17, 21 (1993) Regarding harassing and discriminatory conduct, Hardy asked female employees to reach into their front pants pockets to grab coins and throw objects in front of workers who asked. In 1987, Harris brought these unacceptable comments and actions to Hardy's attention. Hardy was quick to apologize and assure Harris that he was only joking, with no intent of harm or offense. A month after Harris confronted Hardy, he did a comment before a Forklift customer claiming that she had sex with the boy. Month later, Harris quit her job at Forklift Systems and took to court, suing Forklift Systems for the Middle District of Tennessee found this to be a "close case" and found that Hardy's comments and conduct did not create an offensive work environment and that the praise given merely offended Harris and would be considered merely offensive, and nothing more, from a reasonable woman. Although the court found the comments and conduct through the magistrate to be truthful, it concluded that Hardy's conduct and comments were not serious enough to interfere with Harris' work performance, cause her physical injury, or serious enough to adversely affect her well-being psychological. being. The United States Court of Appeals for the Sixth Circuit concurred and affirmed this decision. Certiorari was granted to resolve a conflict between the Circuits as to whether the conduct was necessary to cause physical injury to an employee or seriously impair the employee's psychological well-being for it to be considered an “abusive work environment.” Looking at Title VII of the Civil Rights Act of 1964, it states that it is; “an unlawful employment practice that permits an employer to discriminate against any individual with respect to his or her pay, terms, conditions, or privileges of employment, because of his or her race, color, religion, sex, or national origin.