o kinds of sexual harassment quid pro quo and hostile environment. The first, quid pro quo, is when a person in a supervisory position places the performance of sexual favors as a condition on sustaining or gaining employment or other employment benefits. Harassment of this type holds the employer strictly liable for all damages to the affected employee. The second, hostile environment harassment occurs when behavior by a co-worker or supervisor is pervasive enough to have a negative effect on the employee. The employer is only held liable for hostile work environment harassment when they had knowledge of the situation or the situation was so pervasive that the employer should have known about it. Despite the changing attitude towards sexual harassment in America, the courts have been divided on the issue of same-sex harassment. Several federal district courts skirted around the issue, but one court met this issue head on when Joseph Oncale filed suit in an Eastern Louisiana District Court against his former employer Sundowner Offshore Services, Incorporated. Joseph Oncale, a roustabout on an oil platform for Sundowner Offshore Services, Incorporated in the Gulf of Mexico, was approached in the shower by co-workers and sodomized with a bar of soap. On other occasions, these co-workers, John Lyons, Danny Pippen, and Brandon Johnson, subjected Oncale to humiliating acts such as restraining him while placing their penises on his neck and arms. Lyon's, the crane operator, and Pippen, the driller, both had supervisory positions although neither one was Oncale's immediate supervisor. Oncale complained to Sundowner's Safety Compliance Clerk, but the clerk told Joseph that the men made fun of him as well by calling him names suggesting homosexuality. The company failed to take any action against the three employees. After months of recurring encounters Oncale resigned from his position and filed a complaint against Sundowner in ...
