legal action in 1986 in the case of Mentor Savings Bank vs. Vinson, and this led to its division into two types: quid pro quo harassment, in which terms of employment are made dependent on unwanted sexual favors; and hostile environment harassment, where conduct of a sexual nature makes for a hostile work environment, which is much more difficult to prove than quid pro quo harassment. In the mid-1990s, courts began to see same-sex sexual harassment cases, and after several courts made varying decisions on such cases, it was finally decided that same-sex sexual harassment cases could only be considered if it could be proven that only members of one gender are subjected to the alleged conduct.
Sexual harassment training varies in state and local police agencies, and have been stepped up in some areas since a Supreme Court ruling in 1998 which stated that an employer is liable for its supervisors' sexual harassment even if it didn't know about it (Gowen, 2001). In Charles County, Maryland, a two-hour sexual harassment seminar will be given to 475 employees after two complaints in the last three years. More than 3,000 Maryland State Police will take an updated version of a "diversity training" course that covers sex and race issues. This program was developed in 1995 after a public furor over sexual harassment lawsuits brought by three fe
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