Denny v. Elizabeth Arden Salons, Inc.
United States Court of Appeals for the Fourth Circuit
456 F.3d 427 (2006)
- Written by Laura Julien, JD
Facts
Seandria Denny (plaintiff) bought her mother Jean Denny (plaintiff) a gift package to the Red Door Salon, owned by Elizabeth Arden Salon, Inc. (Elizabeth Arden) (defendant). The Red Door Salon was a beauty salon and day spa that primarily offered body-maintenance services with tangential entertainment. The gift package included a massage, facial, manicure, hairstyle, and lunch. On May 26, 2002, Jean went to the Red Door Salon and received a massage, facial, manicure, and lunch. However, when Jean went to have her hair styled, she was informed that the salon was unable to style African American hair. The Dennys sued Elizabeth Arden under Title II of the Civil Rights Act of 1964, 42 U.S.C. § 2000 et seq., asserting that they were racially discriminated against in a place of public accommodation. The district court granted summary judgment in favor of Elizabeth Arden on the basis that a beauty salon was not a place of public accommodation as defined by Title II of the Civil Rights Act. The Dennys filed an appeal, asserting that the Red Door Salon was a place of entertainment within the meaning of Title II.
Rule of Law
Issue
Holding and Reasoning (Wilkinson, J.)
Dissent (King, J.)
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