Sexual Harassment Cases in the Workplace may occur on many different levels and across positions of power. Sexual harassers in the workplace may be bosses, co-workers, subordinates, and even non-employees. Likewise, anyone can become a victim of sexual harassment in the workplace regardless of their own position. Sexual harassment is a form of sexual discrimination and is therefore prohibited by Title VII of the Civil Rights Act of 1964. Throughout the years the laws surrounding sexual harassment cases in the workplace have evolved. For instance, a person who refuses the romantic advances of another worker and is then discriminated against by that worker is protected under the Title VII. In addition, individuals are protected from having to work in an environment that is deemed to be "hostile" due to discriminating conduct of a sexual nature. Factors that create a hostile environment may be offensive comments, prevailing attitudes of sexism, and offensive graffiti.