Hostile work environment as a form of sexual harassment was first recognized by the U.S. Supreme Court in the case of Meritor Savings Bank v. Vinson. In this case, the Supreme Court held that Title VII does not require a tangible job detriment for sexual harassment to be actionable, stating that unwelcome conduct constituting hostile work environment harassment must be “sufficiently severe or pervasive to alter the conditions of the victim’s employment and create an abusive working environment.” Examples of such conduct may