In employment law, hostile environment sexual harassment refers to a situation where employees in a workplace are subject to a pattern of exposure to unwante sexual behavior from persons other than an employee's direct supervisor where supervisors or managers take no steps to discourage or discontinue such behavior. It is distinguished from "quid pro quo" sexual harassment, where a direct supervisor seeks sexual favors in return for something within the supervisor's powers, such as threatening to fire someone, or offering them a raise. Quid pro quo has been recognized as actionable for decades, but hostile environment has only been recognized as an actionable behavior since the late 1980s as courts have made findings that the loss of employment or constructive dismissal has been caused by such behavior. Some situations that have been ruled to constitute such a hostile environment are: