Sexual harassment has long been an issue in the workplace and is not taken lightly by the justice system. In the recent case of Smith v. Rock Ten Services, a former employee of a Tennessee box maker was repeatedly touched on the buttocks by a male coworker and was awarded $300,000 in a lower court judgment which was affirmed by the US Court of Appeals for the Sixth Circuit on February 10, 2016. In this case, the employer claimed the touching was just “mere horseplay”, but the trial and appellate courts found that, in reality, there was a hostile work environment which was actionable sexual harassment. In fact, there had been a history involving the same perpetrator which had not been dealt with by the employer. As a result, the employer was held reliable for these damages.