Dawson v. Bumble & Bumble

In early 1999, Dawn Dawson (plaintiff) was hired as a hair assistant at Bumble & Bumble (Bumble) (defendant), a prestigious hair salon in Manhattan. Dawson enrolled in Bumble’s training program for hair stylists in addition to her duties as a hair assistant. In general, only 10–15 percent of participants in the training program graduated. Bumble employed stylists and employees who reflected varying physical appearances. Bumble regularly employed sexually nonstereotypical individuals, such as Connie Voines, who was transitioning from male to female. Dawson was lesbian and often talked about her lesbianism at work, including calling herself a “dyke.” However, two coworkers repeatedly referred to Dawson as Donald in front of colleagues and clients. Another colleague told Dawson that she “wore her sexuality like a costume” and another colleague told her that she “needed to have sex with a man.” On July 15, 2000, Voines fired Dawson for her poor performance on the job and in the training program and because of the way she dressed and wore her hair. Voines told Dawson that Voines could not send Dawson outside of the city because Dawson would frighten people. Dawson sued Bumble, alleging a hostile work environment based on sex, sex stereotyping, and sexual orientation in violation of Title VII of the Civil Rights Act of 1964, the New York State Human Rights Law, and the New York City Human Rights Law. The United States District Court for the Southern District of New York granted Bumble’s motion for summary judgment on all claims. Dawson appealed.