Sexual Harassment is a violation that falls under Title VII of the Civil Rights Act of 1964 as "Sex Discrimination in the workplace (The Free Dictionary.com, 2014). Explanation of this violation states any unasked sexual favors or request for sex, including any verbal or physical actions that are of a sexual nature that can create a hostile or offensive work atmosphere (The Free Dicttionary.com 2014). Sexual Harassment Law has two primary categories: Quid Pro Quo, a more blatant form of sexual harassment, referring to demands from a position of power (HG.org, 2014). The second category is Hostile Environment; this type of sexual harassment is the one that is most prevalent occurs (HG.org, (2014). Hostile environment refers to an employee that is subject to frequent sexual conversation, storytelling, nude pictures or images and sexual advances to the point that interferes with an employee's ability to work effectively because of the mental stress (HG.org, 2014). Sexual harassment may also include cartoons pictures or object of a sexual nature (The Free Dictionary.com, 2014) .
In 1987, Elyse Roberts began working at Intake and Misdemeanor Bureau as a new attorney. Elyse Roberts worked as an Assistant District Attorney for the District of Columbia, in the Office of the District Attorney. She received a "good" evaluation, after seven months on the job. Her next job assignment was in the Felony Trial Bureau where she worked with a small staff of 20 attorneys and shared an office with Kevin Murphy, an attorney with four years of experience. During the year Elyse worked in the Felony Trial Bureau, her performance evaluation decreased from "good to fair to poor. Elyse stated that Kevin Murphy's obnoxious comments started as soon as she arrived. She stated Kevin made remarks of a sexual nature as well as sexual overtones. His behavior continued even after she requested he not use that type of language also after Elyse spoke with their supervisor concerning Kevin's actions.