One aspect of disparate treatment, sexual harassment, is defined as unwelcome sexual advances, requests for sexual favors, and other verbal or physical conduct of a sexual nature. Courts have imposed civil liability upon employers and coworkers under two separate theories: quid pro quo liability, in which the sexual act is the condition precedent before an individual is hired, promoted, or receives a job benefit or is the reason for a refusal to hire or to deny promotion or job benefit, or fire; and hostile environment liability when the individual works in an atmosphere made hostile or abusive by unequal treatment of the sexes. The elements of these two types of liability have been clarified in a variety of U.S. Supreme Court and lower court cases. Similarly, the courts have consistently applied agency principles to effect a remedy for sexual harassment in determining employer liability in such cases. The best way for law enforcement agencies to reduce the potential of liability is to establish clear policies and procedures that identify and prohibit conduct that constitutes sexual harassment. A mandatory and accessible grievance procedure and a mechanism for timely and through investigation of sexual harassment complaints also should be established. 60 footnotes.