In 1980, Bonnie Robichaud, a lead hand at the Air Defence Command Base in North Bay, filed a complaint of sexual harassment against her supervisor (Dennis Brennan) and her employer (the Department of National Defence). A Human Rights Tribunal found that Robichaud had not been sexually harassed by Dennis Brennan, because she had voluntarily engaged in sexual acts with him. A Review Tribunal overturned this decision when it determined that Brennan had coerced Robichaud into sexual submission by using threats of employment-related reprisals. Voluntary participation is not the same as consensual participation, it underscored. The Tribunal ruled that Brennan had sexually harassed Robichaud and that the Department of National Defence was strictly liable. Subsequently, this ruling was partially overturned by the Federal Court of Appeal who agreed that Brennan had sexually harassed Robichaud, but decided that the complaint against the employer was unsustainable. However, the Supreme Court of Canada overturned this decision, ruling that "an employer is responsible for the unauthorized discriminatory acts of its employees in the course of their employment under the Canadian Human Rights Act." (Robichaud et al. v. The Queen. 40 D.L.R. (4th) 577 Supreme Court of Canada, July 29, 1987).