The first case of sexual harassment was litigated in 1974. In that and subsequent cases, courts decided that the type of behavior under discussion was not included in the Civil Rights Act of 1964. However, judicial attitudes began to change in late 1976, when courts, for the first time, held the employer responsible for the acts of its supervisory personnel. In 1980 the Equal Employment Opportunity Commission issued guidelines defining sexual harassment. In 1981, the case of Bundy v. Jackson marked the first time that a court recognized that sexual harassment was actionable for a reason other than one of job harm. The only case to reach the United States Supreme Court was that of Meritor Savings Bank v. Vinson in 1986; this case gave a clearer definition to the concept of a "hostile environment." However, judicial decisions on the subject of sexual harassment are inconsistent, and the issue currently seems to be in a state of chaos. However, American employers must acknowledge the issue and develop comprehensive company policies against it to heighten awareness and indicate concern. Footnotes