"Barnes v. Train" (1974) is commonly viewed as the first sexual harassment case in America, even though the term "sexual harassment" was not used. In 1976, "Williams v. Saxbe" established sexual harassment as a form of sex discrimination when sexual advances by a male supervisor towards a female employee, if proven, would be deemed an artificial barrier to employment placed before one gender and not another. In 1980 the Equal Employment Opportunity Commission (EEOC) issued regulations defining sexual harassment and stating it was a form of sex discrimination prohibited by the Civil Rights Act of 1964. In the 1986 case of "Meritor Savings Bank v. Vinson", the Supreme Court first recognized "sexual harassment" as a violation of Title VII, established the standards for analyzing whether the conduct was welcome and levels of employer liability, and that speech or conduct in itself can create a "hostile environment". This case filed by Mechelle Vinson ruled that the sexual conduct between the subordinate and supervisor could not be deemed voluntary due to the hierarchical relationship between the two positions in the workplace. Following the ruling in "Meritor Savings Bank v. Vinson", reported sexual harassment cases grew from 10 cases being registered by the EEOC per year before 1986 to 624 case being reported in the subsequent following year. This number of reported cases to the EEOC rose to 2,217 in 1990 and then 4,626 by 1995.