case Tomkins v. Public Service Electric and Gas Co., a federal court strengthened the Arizona argument. The courts started to change direction later that year. In Williams v. Saxbe the D.C. Federal Court held that sexual harassment was actionable under Title VII and that retaliatory acts by a supervisor toward a female employee for refusing his sexual advances constituted sex discrimination. The 1977 case of Barnes v. Costle held that the plaintiff could establish a prima facie case by showing that sexual favors were requested by the supervisor as a factor in job-retention. Tomkins was also overturned that year, establishing two necessary elements for a prima facie case: 1) sexual advances were imposed as a condition of employment; and 2) these sexual advances were imposed by the employer in a sexually discriminatory manner.
Under Title VII, the Equal Employment Opportunity Commission (EEOC) can pursue a case on behalf of a plaintiff. The 1980 EEOC guidelines defined sexual harassment. Until 1981, sexual harassment suits were restricted to tangible losses, and the term itself was rarely used. The 1981 case of Bundy v. Jackson created in the courts an awareness of a correlation between sexual harassment and "hostile working environments." The attitude of the courts had by now changed dramatically, and the general public had also become more enlightened, as indicated by various surveys.
Up to 1990, the Supreme Court only addressed the issue of sexual harassment once in a 1986 case, Meritor Savings Bank v. Vinson. The first court ruled in favor o
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