Craft v. Metromedia, Inc.

766 F.2d 1205 (1985)

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Craft v. Metromedia, Inc.

United States Court of Appeals for the Eighth Circuit
766 F.2d 1205 (1985)

Facts

KMBC-TV (the station), a television station owned by Metromedia, Inc. (defendant) enforced grooming and appearance standards for its news anchors. The standards for male anchors focused on cultivating a professional image. The standards for female anchors focused on cultivating professional elegance, emphasizing femininity by wearing clothing with ruffles and bows and refraining from appearing too masculine or aggressive. Women were encouraged not to wear the same outfit more than once every few weeks, but men were allowed to repeat outfits weekly and to wear the same suit twice in the same week as long as it was paired with different ties. The station hired Christine Craft (plaintiff) as a coanchor but soon became concerned about her appearance. In response to focus groups that responded negatively to Craft, the station took several steps to encourage her to improve her appearance. Craft was given books and other materials concerning clothing and makeup, she was required to work with a clothing consultant, and she was provided with a clothing calendar that dictated which clothing she should wear each workday. Other anchors at the station had been asked to change their appearances, including several male anchors who had been instructed to lose weight, change their hairstyles, or modify their wardrobes. Despite the station’s efforts to improve Craft’s appearance, focus groups continued to respond negatively to her, and she was reassigned to a reporter role. Craft sued Metromedia, alleging sex discrimination in violation of Title VII of the Civil Rights Act of 1964. She argued (1) that the station’s appearance standards were discriminatory because they were based on gender stereotypes and (2) that the standards were enforced more rigorously against women than against men. The district court found for Metromedia, reasoning that the station’s standards were focused on consistency of appearance, coordination of colors and textures, and the effects of studio lighting on the anchors’ appearances. The court further found that any emphasis on feminine stereotypes was merely incidental and was therefore permissible pursuant to Title VII.

Rule of Law

Issue

Holding and Reasoning (Gibson, J.)

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