Eleventh Circuit: Race-Neutral Grooming Policy that Rejected Dreadlocks Was Not Disparate Treatment Discrimination


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September 15, 2016


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The Equal Employment Opportunity Commission (“EEOC”) sued an employer on behalf of a black applicant whose job offer was rescinded when she refused to change her dreadlock hairstyle.  On September 15, 2016, the Court of Appeals for the Eleventh Circuit agreed with a district court’s dismissal of the alleged discrimination complaint.  The Court reasoned that Title VII of the Civil Rights Act of 1964 prohibits adverse actions on the basis of immutable characteristics of race, whereas the dreadlocks hairstyle was a mutable choice.  This decision follows other courts in similarly rejecting the argument that hairstyles can be a “determinant of racial identity.”