DRAFT: This module has unpublished changes.

For a second, let's create a hypothetical situation, a hypothetical situation where living in a world of braids, dreadlocks, tight coils, and "afrocentric" hairstyles is considered the standard. This is the ideal beauty, the internalized professionalism that all employers seek and expect. For this hypothetical world, I will walk you through one of the cases I will later discuss but I will reverse the roles to fit the expectations of the new standard.  I use a fictional storyline here to reflect assumed attitudes.


Ally, a white female, has worked with American Airlines for eleven years. Her responsibilities consist of direct contact with passengers by issuing boarding passses, checking luggages, etc. She has honored the mandated standard by perming her hair into a very tightly coiled texture that adheres to company grooming qualifications. One day, she doesn't have the funds to maintain her tightly coiled appearence, so she comes to work with her hair straightened, her natural texture. She is addressed by an American Airline representative who assures Ally that she is violating the grooming standards. Ally assures this representative that the grooming policy is unfair, that she should be allowed to wear her hair straight, and, as such, the policy violates her Thirteenth Amendment right under title VII of the U.S. Constitution which verifies that employers "...cannot discriminate based on race, color, religion, sex, and national origin" (Equal Opportunity Employment Commission). Hair texture falls deeply within these categories, but the representative stands firmly on the grooming criteria so Ally takes the case to court.


During the trial, the grooming standard issued to all employees was repeated. By issuing this standard to all, the defendent reassures the court that this is not an example of discrimination. The plaintiff, Ally, assures the jury that equal standards to all does not necessarily mean fair. Would Ally have won her court case?


This hypothetical situation may seem far-fetched to some since straght hair (or hair that can be straightened without the use of chemical processing) is the norm, but it is very familiar to others. This is the reality of many African American Women in the workplace: the reality of having to conform to a standard that is not easily accomodating. These grooming tactics may not come across as lucid as I'd like in my hypothetical analogy since we may have internalized "straightened" hair, but maybe taking a look at reoccuring cases will shed light on this ongoing problem. 


The first case we'll review is Rogers Vs. American Airlines in 1981.


Title and Citation: Renee Rogers Vs. American Airlines, No. 81 Civ. 4474


Facts of the Case: Renee Rogers, an African American Women, has worked for American Airlines for 11 years. Her job responsibiliities require constant personal contact with passengers through issuing boarding passes, greeting passangers, and checking luggage. American Airlines prohibits an all-braided hairstyle for specific employment positions. Renee Rogers argues that this prohibition violates her 13th Amendment right under Article VII of the Civil Rights.


Issues: Does the grooming policy enforced by American Airlines discriminate against Renee Rogers as an African American Women?


Holding: The motion is denied.



  • The plaintiff failed to provide evidence that this prohibition is affecting anybody else but her.
  • The plaintiff failed to provide evidence that all braided hair style is exclusive to African American Women
  • This is considered an "easily changeable characteristic", which does not discriminate against natural origins or race.

In my condensed version of the Rogers Vs. American Airlines case brief, I suggest that the biggest argument upheld in court (and the court cases to come) is the notion that braids are considered an "easily changeable characteristic"; but changeable to what? So far, we don't have many options to choose from since braids are prohibited.


Let's look at the court case Hollins Vs. Atlantic in 1999 where further boundaries have been placed to limit the creativity and freedom of African American Hairstyles. 


Title and Citation:Eunice Hollins Vs. Atlantic Co. INC, No. 1:97 CV 175


Facts of the Case: Eunice Hollns was an employee at Atlantic Co. for 3 years. She came to work with "finger waves" and was told her hair preference was not permitted. She continuously came back to work with a style that was not suitable, so management requested she bring in a picture of the style she planned on doing before she decided to get it. This became the routine, until she decided to file a discriminatory complaint. Once this was filed, she claimed that the company penalized her for the filing because her performance rating dropped from 5 to 4 under both categories of personal appearence and correspondence. 


Issue: Did Atlantic Co. discriminate against Eunice Hollins by regulating her hair styles and penalizing her for filing a complaint?


HoldingPlaintiff has "failed to make a prima facie case of race discrimination and retaliation, and as such, Defendents motion for Summary Judgement should be granted"




  • No evidence of retaliation exists.
  • Plaintiff failed to persuade the court that there was an intentional discrimination.
  • An employer can legally enforce a grooming policy that will adhere to the image of the company (can not be too "eye catching").
  • Plaintiff did not prove that she was treated differently than another "non minority" employees in her similar position. 


The Eunice Hollins Vs. Atlantic Co. has introduced us to yet another hair boundary. Relative to the employer, African American women cannot have fingerwaves in the workplace. The standard of a hairstyle not being "too eye catching" is definitely troubling to hear. It opens a floodgate for more criticism on what is not considered standard. The standard remains straight-hair, features that are constantly being imposed upon African American women in the workplace.


Let's take a look at our next case, Niles Dodd Vs. SEPTA Police Department in 2002.


Title and Citation Number: Niles Dodd Vs. SEPTA (Southeastern Pennsylvania Transportation Association) Police Department, No. 06-4213


Facts of the Case: Niles Dodd is a Rastafarian police officer for SEPTA. He has constantly approached management about his hostile environment, because the other employees harass him about his deadlocks. Management has insisted that he cut them even stating that it "doesn't trust men with that hair style." Niles was terminated twice from his job for not complying, then brought the issue to the Equal Opportunity Employment Department. 


Issue: Is this an example of sex-based discrimination and religious prejudice?


Holding: "the permission to dismiss will be granted at part and denied at part"--- this is applied to sex-based discrimination, but not to religious prejudice.




  • There has been indication that some policies have been burdencome to one gender than the other.
  • Plaintiff failed to imply that the grooming standards were in place for discriminatory purposes.


Now, although this case is pertaining to a man, it is important to include it, nonetheless, to set the tone for another boundary that is barred from us: dreadlocks. This case has proven that there has been sex-discrimination in place, but failed to realize that there are religious prejudices at the forefront as well.


Let's review our next case, Patricia Pitts Vs. Wild Adventures INC. in 2008.


Title and Citation: Patricia Pitts Vs. Wild Adventures INC. 7:06-CV-62-HL


Facts of the Case: Patricia Pitts was employed by Wild Adventures theme park in Georgia starting in 2001. She achieves upward mobility as she is promoted from Guest Services Team Leader to Guest Services Supervisor. Two years later, the white Guest Services Manager approaches her and states her dissaproval of her cornrows. Patricia changes her hair to twists and her manager still dissaproves. After her hairstyles continuously dissapoint, the manager took initiative by posting flyers stating that "cornrows, dreadlocks, beads and shells" are prohibited. After another two year time period, which was said to accumulate to her "lengthy disciplinary" record, she was fired. 


Issue: Was she discriminated against because of the set grooming policy and during her termination?


Holding: Defendents Motion is granted



  • Grooming policies are kept relative to the employer, as long as it does not discriminate on the basis of "immutable charachteristics."
  • Plaintiff did not introduce evidence proving that she has been replaced by someone outside of her class, or that anyone outside her class were treated more "favorably."
  • There is no direct evidence of retaliation regarding termination.

We are currently in the year of 2008 and we have not seen a winning case yet. What we have seen, however, is another addition to the boundaries placed on African American Woman: cornrows.


It is clear that there has been great attention to these boundaries, because in 2010 the Equal Opportunities Employment Commission took a stand against the Lawrence Transportation System. 


Title and Citation: Equal Employment Opportunity Commission Vs. Lawrence Transportation Systems INC. 


Facts of the Case: Christopher Woodson applied to be a loader for Transportation Systems INC. Upon his follow-up with the manager, the manager told him that they are considering him for the job, but he must cut his hair. Woodson told him it is against his religion, Rastafarianism, and in order to be one with nature, he can not cut them. Woodson offered to tie his hair up and wear a wrap to try and accomodate the grooming standards, but the manager disapproved.


Issue: Is neglecting to hire Christopher Woodson because of his Rastafarian religion considered discrimination under the 13th Amendment and article VII of the Civil Rights?


Holding: "...mistrial after jury could not come up with a verdict, but agreed on a voluntary settlement"; One required settlement consisted of Lawrence Transportation system to paying $30,000.00



  • It is not just to have a person choose between their religion and their job.


It is 2010 and we have made some progress!


Let's look at our last case: the Equal Opportunities Commission Vs. Catastrophe Management Solutions in 2014.


Title and Citation: Equal Opportunities Commission Vs. Catastrophe Management Solution, No. 13-00476-CB-M


Facts of the Case: The Catastrophe Management Solution set a policy for employment that prohibits dreadlocks. The requirement however only states "...groomed in a manner that projects a professional and businesslike image while adhering to company and industry standards..." "No excessive hairstyles and unusual colors are acceptable...". The defendent claims that dreadlocks is implied in this criteria.


Issue: Is this an example of intentional discrimination?


Holding: The case is dissmissed ruling in favor of the defendent.



  • Grooming policies are relative to the employer as long as it does not interfere with Article VII stating that the grooming policies does not ask to change "immutable characteristics."
  • Dreadlocs is "non-unique" and can apply to whites as well, making its prohibition equal.

It's 2014 and this is our most recent ruling. We've made some minute progress, but not nearly enough. Slogans such as "eye catching" and "easily changeable" have been the ongoing argument against African American hairstyles; these slogans keep the freedom to express ourselves, our culture, caged. It's a shame that African Americans have even tried to bend for grooming policies, like Christopher Woodson who insisted on tieing his hair up when employers have no intentions to do the same for us.


DRAFT: This module has unpublished changes.