Working women have been victims of sexual harassment at least since they entered the workforce in large numbers. Public awareness of sexual harassment, however, has emerged only in the last decade, during which it has received a barrage of media attention. Since then, sexual harassment in employment has been documented as pervasive, inflicting devastating economic, physical, and psychological hardships on working women.

As with public awareness, a legal remedy for sexual harassment was long in coming. The enactment of Title VII of the Civil Rights Act of 1964 (Act) made sex discrimination in employment illegal. Nevertheless, ten more years passed before a federal court recognized sexual harassment as a form of sex discrimination under Title VII. Nor did this recognition initially cover all forms of sexual harassment. The early Title VII sexual harassment cases were limited to claims of “quid pro quo” sexual harassment: the conditioning of tangible job benefits, such as a promotion or continued employment, on the employee’s receptiveness to the employer’s sexual advances. Only very recently have courts recognized that “absolute” sexual harassment-the subjection of female employees to sexual advances, suggestions, jokes, or epithets without threatening the loss of tangible job benefits–can constitute sex discrimination.

Although quid pro quo sexual harassment can be perpetrated only by a female employee’s supervisors because only they have the power to threaten the employee’s job status, absolute sexual harassment can be perpetrated by her supervisors, coworkers, clients, and customers. Predictably, supervisors seldom engage in absolute sexual harassment because they often couple their sexual advances with explicit or implicit threats to the employee’s job, making their conduct quid pro quo harassment. Absolute harassment is most often perpetrated by an employee’s coworkers, and, in fact, statistics show that this type of harassment is at least as prevalent as quid pro quo harassment.