In Philadelphia Housing Authority v. American Federation of State, County and Municipal Employees, 956 A.2d 477 (Pa. Cmwlth. 2008), Thomas Mitchell, an employee of the Philadelphia Housing Authority (PHA), was discharged for sexual harassment of a female co-worker after an investigation of the co-worker's formal complaint revealed that she had been subjected to an ongoing course of sexual harassment by Mitchell and that Mitchell had a pattern of sexually harassing female employees. The arbitrator characterized Mitchell's behavior as "lewd, lascivious and extraordinarily perverse" but, nevertheless, concluded that PHA did not establish just cause to terminate, as required by the parties' CBA. The arbitrator sustained Mitchell's grievance and awarded a "make whole" remedy, which provided for Mitchell's unconditional reinstatement with back pay. PHA's petition to vacate the award was denied by the trial court, but this court reversed on appeal. In doing so, the Court identified the explicit, well-defined and dominant public policy against sexual harassment in the workplace, including employer prevention of such harassment, investigation of complaints of harassment and application of appropriate sanctions against those who commit such conduct. The Court then noted that "in cases where courts have upheld arbitrators' awards reinstating employees who have committed sexual harassment, there still has been some significant sanction against the offending employee." Philadelphia Housing, 956 A.2d at 485. Finally, the Court stated, In considering the issue before us, we must assume that the CBA itself calls for the remedy set forth in the arbitrator's award; the question to be asked is does a CBA requirement to reinstate Mitchell without conditions and make him whole run counter to the identified public policy against sexual harassment in the workplace. In light of the cases discussed above, we conclude that the arbitrator's interpretation of the CBA so undermines the stated public policy that it cannot be enforced. Philadelphia Housing, 956 A.2d at 486.