Hollins v. Atlantic Company, Inc.

Eunice Hollins (plaintiff) worked at Atlantic Company, Inc. (Atlantic) (defendant). Atlantic had a personal-grooming policy, pursuant to which hairstyles were to be “neat and well groomed.” The policy prohibited “rollers and other hair setting aids” and stated that women might be required to tie their hair back. In 1994, Hollins, who was Black, arrived at work with her hair in a finger-waves style. Hollins’s foreman informed her that the style was unacceptable because, even though it was neat and well groomed, it was “eye catching.” Hollins changed her hairstyle. In 1995, the plant manager informed Hollins that if she wished to change her hairstyle, she should present a photo of the proposed style to her supervisor for preapproval. When she did so, her supervisor rejected the style. In 1996, Hollins arrived at work with her hair in a ponytail—the same style at least five White women working under the same supervisors as Hollins wore on many occasions without incident. Hollins’s supervisor informed her that the ponytail was “too drastic” and reminded her that she was supposed to ask about new styles prior to changing hers. Hollins was told that her failure to conform to the guidelines could affect her performance reviews and lead to termination. Hollins changed back to a hairstyle previously approved by her supervisors. Her foreman told her that although it was preapproved, she should have informed him in advance that she planned to change her style. In 1996, Hollins filed an Equal Employment Opportunity Commission (EEOC) complaint, alleging that she was subject to racial discrimination based on the application of the grooming standards. In 1997, Hollins wore a ponytail to work, and her new foreman, who was aware of the complaint, met with other employees to discuss the issue. They agreed that an employee’s hairstyle should not “call attention” to the employee, then informed Hollins that the hairstyle was unacceptable for that reason. Hollins was told that future violations of the policy would affect her employment, and that if her hair was important to her, she should consider employment elsewhere. The district court held that Hollins failed to demonstrate a prima facie case of racial discrimination and granted Atlantic’s motion for summary judgment. Hollins appealed.