The whole ugly saga began in 1991 when an elderly visitor to the Buckingham Correctional Facility complained to officials about the way Spicer was dressed.

Management 101 would dictate that a supervisor talk with Spicer about the visitor's comment -- in private. That didn't happen. Instead, Spicer and her co-workers found out together.

"The memo was read at a meeting," she says, folding her perfectly manicured hands in front of her. "I didn't even pay attention to it. Even though they read my name, I had no idea they were talking about me. I was in medical later that day, and one of the nurses asked if I had seen the memo. She said I better go read it." It had been posted throughout the complex.

The memo was about nipples showing through a sweater. And it mentioned Spicer by name.

"I was so angry I requested to see the warden. ... He laughed and blew it off. So I called the department's EEOC [Equal Employment Opportunity Commission] officer. I was so humiliated."

Spicer's life changed. "I stayed in my office. I thought people were looking at me. I started to dress in layers," she says. "Then a psychologist I worked with passed me in the hall and said, 'We will have nipple check on Monday morning.' That made me layer even more."

Frustrated, embarrassed and miserable at work, she sought recourse outside the prison bureaucracy through a sexual-harassment suit. "My lawyer told me that once I decided to go ahead with the claim, it could get difficult," she says. "But there was no turning back."

Sexual harassment today isn't as glaring as the quid pro quo of the past. Cases now commonly stem from off-color jokes, sexual innuendo or uncomfortable stares. "Blatant discrimination is becoming a thing of the past," says Eva Tashjan-Brown, a Richmond partner at McGuire, Woods, Battle and Boothe. She handles nothing but employment discrimination cases. "What we saw years ago is not what we're seeing in lawsuits today. People are more aware, more sophisticated."

Laws governing sexual harassment in the workplace have been around since the passage of Title VII of the Civil Rights Act of 1964, which prohibits discrimination. In 1986 the U.S. Supreme Court made history when it ruled on its first sexual-harassment case, Meritor FSB vs. Vinson. Its unanimous opinion held that sexual harassment indeed violates Title VII if it creates a hostile or offensive environment, regardless of whether it threatens the individual's job. The nation's top court set a path for future harassment claims. "The Vinson case is a sign of a sea change," says Ann Coughlin, a University of Virginia law professor.

In November, the Supreme Court again returned to the issue of sexual-harassment law when it agreed to hear a former Florida lifeguard's case to clarify when victims can force their employers to pay damages. A decision in that case is expected this summer, and employment-law experts are anxious to learn the outcome.

Public awareness is growing, not only because of these cases, but in light of such high-profile episodes as the Anita Hill and Clarence Thomas hearings and Paula Jones' suit against President Clinton. What happened to Spicer just six years ago is less likely today.

"We are going through a shift in the way the sexes treat each other at work," Coughlin says. "Workplaces used to be saturated with sexual remarks. There is a sense that the rules of the game have changed, at least at the formal level. And mechanisms are in place to try to eliminate harassment from the work environment."

The laws have gotten complex. But under the threat of litigation, employers are taking sexual harassment seriously. The result may be less egregious behavior on the job, and a greater likelihood that harassed employees will come forward.

Many sexual-harassment cases, however, are unfounded. According to Gloria Underwood, area director for the Richmond EEOC office, a small percentage of charges brought nationally have merit. But businesses don't want to play the odds. They're finding that the best way to defend against harassment claims is to stop harassment from happening.

On the sexual-harassment watch, there's always a new wrinkle, says Buddy Stalnaker, director of human resources and administration at Richmond-based tobacco company Swedish Match North America Inc.

"We've had harassment policies and training in place for many years," he says. "More recently with the advent of network computers, this is a new challenge. We remind employees that we can monitor their e-mail. But more importantly we ask them to bring anything that makes them uncomfortable to someone's attention. We have a totally open-door policy. ... On this issue, we don't worry about the chain of command."

With the help of its legal consultant -- Gene Webb, a partner at Mays & Valentine -- Swedish Match has developed what Stalnaker calls a trusting work environment. "It is important to create the right kind of organizational culture," he says. "In our performance management program we teach ... the principle of applied behavior. We want employees to be aware of how what they do affects those around them."

According to Webb, all companies should have a written policy that lets workers know, in clear language, what the rules are. This should help stop harassment, but there's another reason for getting it in writing: Courts have seen policies against sexual harassment and well-established grievance procedures as a way to avoid liability.

"You have to make sure all employees know and understand the policy. It should be posted, be in the handbook and training should be given," Webb says. "The policy must also be enforced, which means that there have to be mechanisms for employees to feel comfortable reporting the activity." Because the supervisor is often the harasser, there should be more than one way of filing a complaint.

Employees often go directly to the EEOC or to court because they fear retaliation, don't think they'll be taken seriously, or don't know that their companies have channels for reporting harassment. So employers need to periodically review the information with workers.

Stalnaker says a company can get into trouble if it thinks it can write a policy, hold a training session and be done with the issue. "The policy can't be a shelf document. You have to actively pursue it daily. If you don't, that's when you'll get surprised."

Webb notes that while it's important to take steps to protect the person making the complaint, it's equally incumbent on the employer to make sure a violation actually occurred. "There must also be procedures for prompt and fair investigation," he says.

Marty Langelan, a workplace consultant, recommends that employers put emphasis, not only on what's unacceptable, but on what people can do on their own to combat harassment. She calls it psychological judo. "There was this woman in Texas; she was in a traditionally nonfemale work environment," Langelan says. "Her boss was the ring leader, and every time the guys would start harassing her, she would whip her notebook out of her tool chest and start writing down everything they said. Actions like this flip the power dynamic. It is a very powerful technique."

Langelan's consulting firm, Langelan & Associates of Washington, D.C., specializes in sexual harassment policies and procedures and other sensitive workplace issues. She says employers need to be explicit when educating supervisors about sexual harassment. In training sessions, give workers examples of jokes, behavior and body language. Let them see these things in action. Employees themselves can team up to stop harassment. As Langelan notes, it can be as simple as everyone in a department shutting down the harasser by not laughing at his jokes. "Every time he tells a joke, each person gives the same response, ÔI'm not interested.' This can be very effective."

No business is immune.

What some called locker-room antics ended up costing Richmond Newspapers Inc. $140,000. The company publishes the Richmond Times- Dispatch, a sister publication to this magazine. A few men in the pressroom kept goosing a male co- worker. They thought it was all in fun, but the center of attention didn't see it that way. Hazelwood vs. Richmond Newspapers went all the way to the state Supreme Court.

Frank McDonald, vice president and personnel director for Richmond Newspapers, says what happened was something that takes places every day in locker rooms and on ball fields. But the bottom line, he says, was that the horseplay was unwelcomed by the employee. In what the legal community refers to as the "goosing case," the charges did not fall under sexual harassment but rather assault and battery.

Since the Hazelwood case, the issue of same-sex harassment has again come into question, but earlier this year the Seventh Circuit Court ruled that same-sex actions are also illegal under Title VII. "When one's genitals are grabbed, when one is denigrated in gender-specific language, and when one is threatened with sexual assault, it would seem impossible to de-link the harassment from the gender of the individual harassed," the court ruled.

And as far as locker-room antics being tolerated again at Richmond Newspapers, McDonald says, no way. "If you do it, you get fired."

By the time Spicer's claim went to court, things got fairly tense. "It made everybody pick sides," she says. "And I was having all the classic rape victim symptoms. I couldn't sleep, eat. I was so depressed I had to go to a counselor."

The U.S. District Court for the Eastern District of Virginia found the Department of Corrections guilty of sexual harassment. The department was ordered to pay Spicer almost $30,000 for attorneys' fees, an amount that remains on appeal.

For Spicer the ruling in the sexual-harassment case was bittersweet.

"You can't find glory or happiness in that type of win," she says, "although it is a victory for others. Things have changed dramatically at the Department of Corrections." There's new leadership. Sexual-harassment training is mandatory for all new officers, and working for the department is great, she says.

"Mr. Angelo does not play. He will not tolerate any type of harassment. If you're doing it, you better stop before you get caught, because you'll be out of here." She's referring to the philosophy of the head of the Department of Corrections, Ron Angelo. "It starts at the top and trickles down."

Filing the claim was tough going, but Spicer says she would do it again. As a 17-year veteran of the department, she had no intention of leaving a job she loves. And she's comfortable with the outcome of her case. "Now everyone is very conscious of harassment, and it is just not tolerated. The [Department of Corrections] is now taking a very proactive approach," she says. "And I'll always stand up for myself. My mother taught me that."