Laws against sexual harassment have been on the books since the Civil Rights Act of 1964. Although not explicitly stated as such, this was the first law prohibiting sexual harassment because it states that discrimination based on gender is prohibited. The 1976 court case of Williams v. Saxbe was the first to recognize sexual harassment as a type of sex discrimination. Then in 1977, the US Court of Appeals ruled that a female employee, who was retaliated against after rejecting the sexual advances of her male superior, had had her civil rights violated. Over the next few decades, the precise meaning of sexual harassment and how it fits under the federal law prohibiting sexual discrimination was tested and redefined through various court cases. In 1991, the landmark case of Robinson v. Jacksonville Shipyards found that the creation of a "sexually hostile environment" which included crude language and graffiti was a violation against the Civil Rights Act of 1964.