Sexual harassment is a violation of Title VII and can take two forms - quid pro quo or an atmosphere of harassment (l). Quid pro quo cases occur when an employee is required to submit to advances that are sexual in nature in order to keep their job, get a promotion or obtain a raise [l]. The company andJor supervisor may be liable in these instances of harassment (2). An atmosphere of harassment occurs when the workplace atmosphere becomes one of sexual tone or suggestion (1). The employer will not be liable for au'nosphere of harassment cases if it has an antiharassment policy that the victim knew about but does not use [3). To bring a suit under the atmosphere of harassment theory, the plaintiff must show the following elements: (1) they belong to a protected class, (2} the accused's conduct was based on sex; (3) the conduct was unwelcome; (4) the conduct was severe or pervasive enough that it altered the conditions of employment; [5) the conduct created a hostile work environment and (6) the employer knew or should have known of the harassment, but did not take action (4). The culpability element could harm Lori's case because it is arguable that Daniel's behavior was not based on sex due to his disability