Harris worked as a rental manager for two years for Forklift Systems. Her boss, Hardy, often insulted her in front of others and made her the target of sexual slurs and suggestions. He said, "We need a man as the rental manager," and "you're a woman what do you know?" He told her she was "a dumb-ass woman," and that they should "go to the Holiday Inn to negotiate her raise." Hardy asked Harris and other women employees to get coins from his front pants pocket, throw things on the ground and ask women to pick them up, and make sexual comments about their clothing.
Harris complained to Hardy about his comments.
Hardy said that he was only kidding. When Harris arranged a deal with a customer, Hardy asked her, "What did you do, promise the guy sex Saturday night?" Harris quit and sued, claiming that Hardy's conduct created a hostile work environment. The district and appeals courts ruled against her. She appealed.

1. The court held that the actions must be severe enough to create a hostile work environment to a reasonable person. If this issue were left to a jury, might not some people on the jury, especially men, be likely to think that Harris overreacted?
2. Two concurring opinions indicated that another standard that might be focused on is whether the abusive actions are sufficient to affect work performance. Would that provide better guidance?