In Ellison v. Brady (9th Cir. 1991) 924 F.2d 872, the court addressed the issue, in the context of a summary judgment, of what remedial actions will shield an employer from liability for sexual harassment by co-workers. (924 F.2d at p. 881.) The Ellison court adopted the test that the remedy should be " 'reasonably calculated to end the harassment.' " (924 F.2d at p. 882.) It noted another case in which the employer's actions of fully investigating, reprimanding the harasser for "grossly inappropriate conduct," placing the offender on probation for 90 days, and warning that further misconduct would result in discharge was sufficient to prevent liability for the harassment. (924 F.2d at pp. 881-882.) The court noted: "We do not think that all harassment warrants dismissal . . . rather, remedies should be 'assessed proportionately to the seriousness of the offense.' " The penalty imposed should be sufficient to stop the harassment. (924 F.2d at p. 882.)