Equal Employment Opportunity Commission v. Catastrophe Management Solutions

Chastity Jones, a Black woman, dressed in a business suit and wore her hair in short dreadlocks when she attended an in-person interview for a telephone-based customer-service position at Catastrophe Management Solutions (Catastrophe) (defendant). Catastrophe hired Jones on the spot with a group of other applicants. After Catastrophe’s human-resources manager, Jeannie Wilson, addressed the new hires about onboarding, Wilson and Jones met privately to discuss a scheduling conflict, and at the end of that conversation, Wilson told Jones that Catastrophe could not hire her if her hair was in dreadlocks, claiming that “they tend to get messy, although I’m not saying yours are, but you know what I’m talking about.” Jones said that she would not cut her dreadlocks, and Wilson asked Jones to return her onboarding paperwork. The Equal Employment Opportunity Commission (EEOC) (plaintiff) sued Catastrophe on Jones’s behalf, arguing that refusing to hire a Black employee with dreadlocks is racial discrimination that violates Title VII of the Civil Rights Act of 1964. The district court dismissed the EEOC’s complaint, finding that a hairstyle is a mutable (or changeable) characteristic and Title VII prohibits only discrimination based on immutable characteristics. The EEOC appealed, arguing that race is a social construct with no biological definition, and race is not limited to immutable physical characteristics. The EEOC did not claim that dreadlocks are an immutable trait of Black people, but rather that dreadlocks are a natural outgrowth of Black hair texture, which is an immutable trait. The EEOC also argued that dreadlocks can symbolize racial pride and that Black people who wear dreadlocks are often stereotyped as radicals and troublemakers who will not assimilate into corporate and professional norms.