Personal Liberties

Equal Employment Opportunity Commission v. Catastrophe Management Solutions

Requiring “professional” hairstyles is not intentional racial discrimination

Catastrophe Management Solutions requires its employees to be “dressed and groomed in a manner that projects a professional and businesslike image” and does not allow hairstyles that are “excessive” or an “unusual color.” An African-American woman with dreadlocks was offered a job on the condition that she change her hairstyle to comply with company policy. She complained to EEOC, which sued Catastrophe for violating Title VII’s prohibition of intentional racial discrimination. The district court dismissed the case. On appeal, PLF filed an amicus brief arguing that an employment policy that requires professional haircuts, and interprets and applies the policy to prohibit dreadlocks on everyone, can never facially discriminate against black individuals as a matter of law. The Eleventh Circuit affirmed.

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