In the 1970's, courts first acknowledged that employees were within their rights to sue their employer when they were subjected to unlawful sexual harassment under Title VII. Throughout the 1990's, the courts have continued to define various types of behavior that constitute actionable sexual harassment. In 1998 the U.S. Supreme Court decided several landmark cases that dramatically changed the legal underpinnings for sexual harassment law. These new cases set forth new and broader standards for holding employers liable when management-level employees engage in conduct that creates a hostile environment for subordinates. Also in the same term, the Court found that same-sex harassment can create employer liability. This ruling has pervasive implications for all sorts of workplace conduct, such as all-male "horseplay" and all-female personal talk. Evolving and expanding sexual harassment law underscores the importance of employers' continual and effective management training. Employers must ensure that their workplace harassment prevention policies and all other policies are up-to-date and that they are effectively communicated to each employee. The policy should clearly define what constitutes harassing behavior, and the employer should reinforce a zero-tolerance response and outline the range of disciplinary consequences for harassers.