Sexual harassment law presents a complex set of issues not only for lawyers but also for psychiatrists in their roles both as evaluators and clinicians. Judge Reinhardt of the US Court of Appeals for the 9th Circuit, summed up these complexities: "We tend these days, far more than in earlier times, to find our friends, lovers, and even mates in the workplace. We ... often discover that our interests and values are closer to those of our colleagues or fellow employees than to those of people we meet in connection with other activities. In short, increased proximity breeds increased volitional sexual activity." On the other hand, he notes that Title VII "entitles individuals to a workplace that is free from the evil of sexual intimidation or repression. It is frequently difficult to reconcile the two competing values." He goes on to ask, "When does a healthy constructive interest in romance become sexual harassment? To what extent is pursuit of a co-worker proper but of a subordinate forbidden? Is wooing or courting a thing of the past? Must a suitor cease his attentions at the first sign of disinterest or resistance? Must there be an express agreement before the person seeking romance may even hold the hand of the subject of his affection? Is it now verboten to steal a kiss? In the workplace? Everywhere? Under all circumstances or only some? Has the art of romantic persuasion lost its charm? Questions relating to love and sex are among the most difficult for society to answer." The US Supreme Court has stressed the need for common sense in evaluating cases of sexual harassment. Perhaps psychiatrists can play a sobering role in developing answers to these questions.