Fairly recently in our country, anyone who was not a white male had a very slim chance of obtaining a well-paid job or a promotion. In her chronicle, entitled "In Our Time: Memoir of a Revolution," Susan Brownmiller recollects filling out a job application in the `60's which asked for the date of her last period and whether she had ever had an illegal operation. Such questions were not uncommon at that time. Employers would routinely question a prospective employee about her personal life, such as whether she was married, pregnant, or planning to become pregnant. Fortunately, due to several civil rights acts, such questions are now illegal. However, gender-based discrimination does still exist within the workplace; the two most common forms of which are sexual harassment and wage discrimination. .
The most obvious type of sexual harassment is direct, for example, when an employer extends job opportunities, raises, or promotions as a reward for sexual favors. Another manner of sexual harassment is known as hostile-environment harassment, which, the text book states, "occurs when an employee is subjected to sexual conduct or comments that interfere with the employee's job performance or are so pervasive or severe as to create an intimidating, hostile environment." Two questions concerning harassment soon arose. One question concerned how to determine whether an environment was, in fact, hostile. The second questioned whether the victim must have suffered emotional or psychological effects as a result of the offensive conduct in order to make a complaint. In answer to both, Justice O"Connor stated "So long as the environment would reasonably be perceived, and is perceived, as hostile or abusive, there is no need for it also to be psychologically injurious." The court has since gone on to state that employers must take reasonable precautions to protect their employees from sexual harassment, and that Title VII also covers situations where a person is being harassed by a member of the same sex.