In Harris v. Forklift Systems, Inc., 510 U.S. 17 (1993), the United States Supreme Court ended the ongoing debate over whether evidence of psychological injury was required to succeed in a sexual harassment case. Adopting a middle ground between "making actionable any conduct that is merely offensive and requiring the conduct to cause a tangible psychological injury," the high Court in Harris recognized that "a discriminatorily abusive work environment, even one that does not seriously affect employees' psychological well-being, can and often will detract from employees' job performance, discourage employees from remaining on the job, or keep them from advancing in their careers." Id. at 21-22. Rejecting the district court's standard of requiring proof that the plaintiff's "'psychological well-being'" was "'seriously affected,'"the United States Supreme Court held that the test for recovery is whether "the work environment would reasonably be perceived, and is perceived, as hostile or abusive." 510 U.S. at 22. While clearly validating the relevance of inquiring into the sexual harassment plaintiff's "psychological well-being" as a means of "determining whether the plaintiff actually found the work environment abusive or hostile," the high Court was emphatic in its holding in Harris that the harassing conduct at issue does not have to be "psychologically injurious" to entitle a plaintiff to recovery. Id. at 22-23.