context of a workplace. While sexual harassment is a prominent form of workplace harassment, the United States Department of Labor defines workplace harassment as being more than just sexual harassment. "It may entail 'quid pro quo' harassment, which occurs in cases in which employment decisions or treatment are based on submission to or rejection of unwelcome conduct, typically conduct of a sexual nature. Workplace harassment may also consist of offensive conduct based on one or more of the protected groups above that is so severe or pervasive that it creates a hostile or offensive work environment or when it results in an adverse employment decision (such as being fired or demoted/reducing salary)." Thus, workplace harassment is a bigger category that encompasses sexual harassment. In the United States Types The varying harassment imposed on the victims can be categorized into two different types, physical abuse and emotional abuse. Physical abuse refers to sexual assault and violence on body, while emotional abuse refers to imposing stress and bullying. Anderson and Militello found that often managers exhibiting harassing behavior were allowed to maintain their jobs because their behavior was seen to increase productivity in the short term. A study done by Kathleen D. Ryan and Daniel K Oestereich, Driving Fear Out of the Workplace, found that many of these behaviors can range from subtle emotional cues to outward physical threats and can include; silence, direct insults and even angry outbursts. Whether these actions are intentional or brought on by stress, the result can cause the employee to feel humiliated, isolated and may cause them to lash out at others. Physical harassment Physical harassment in the workplace takes many forms. Sexual assault is one form of widely known physical harassment. Sexual assault in the workplace has gained media and academic attention mainly in the 1990s after a series of famous sex scandals. "Among the most notorious are the 1991 congressional hearings on the alleged sexual harassment of Anita Hill by Clarence Thomas, nominee to the Supreme Court; the sexual assault on female officers at a party during the 1991 annual convention of Navy fighter pilots; the dismissal of Air Force pilot Kelly Flinn for adultery in 1997; the 1998 trial and acquittal of the top ranking Army enlisted man on charges of sexual harassment; and the independent counsel investigations of President Clinton's sexual affairs with subordinates." With this cascade of sex scandals, the media