The United States Supreme Court held that an employer's conduct need not seriously affect an employee's psychological well-being or cause the employee to suffer tangible injury to be actionable as hostile work environment harassment in violation of Title VII of the Civil Rights Act of 1964.
Harris v. Forklift Systems, Inc., 114 S. Ct. 367 (1993).
Kathleen A. Gleeson,
Constitutional Law - Civil Rights Act - Title VII - Sex Discrimination - Hostile Work Environment Sexual Harassment,
Duq. L. Rev.
Available at: https://dsc.duq.edu/dlr/vol33/iss1/9