While work related sexual harassment is certainly not a recent problem, legal liability for it has only lately gained legislative attention. The first sexual harassment case under Title VII was decided in 1976. In 1991, Title VII was amended to allow victims of sexual harassment to recover damages under federal law. In 1993, a Supreme Court decision made it easier to prove injury under this law. The federal Equal Employment Opportunity Commission states that all covered employers should provide sexual harassment training and several states have taken those guidelines to more specific extremes. California’s AB 1825 of 2004 is among the strictest and most demanding of these requirements. For businesses in these states, providing training is not just good prevention, it iscompulsory. Furthermore, recent decisions have upheld complaints against businesses that did not communicate or follow through policy, even though policy was in place.