EEOC v. CMS Case Brief PDF

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Equal Employment Opportunity Commission v. Catastrophe Management Solutions

Case Name and Citation: Equal Employment Opportunity Commission v. Catastrophe Management Solutions Procedural History: District court dismissed plaintiff’s complaint under Rule of Civil Procedure and denied EEOC’s motion for leave to amend. Plaintiff appealed. Issues: Whether a protected trait motivated the employers race-neutral grooming policy and thus discriminated plaintiff on basis of race. Facts: The Equal Employment Opportunity Commission filed suit on behalf of Chastity Jones, a black job applicant whose offer of employment was rescinded by Catastrophe Management Solutions pursuant to its race-neutral grooming policy when she refused to cut off her dreadlocks Rules: Title VIII of the Civil Rights Act of 1964 prohibits employer discrimination based on race, more specifically to prevail on a disparate treatment claim, Title VIII plaintiff must demonstrate that employer intentionally discriminated against her on a basis of protected and immutable characteristics. Reasoning: Court reasoned that dreadlocks hairstyle was a mutable characteristic, and thus, employer did not discriminate against applicant on basis of race in violation of Title VII when it rescinded offer of employment pursuant to its race-neutral grooming policy after she refused to cut off her dreadlocks, even though hairstyle was historically, physiologically, and culturally associated with people of African descent, absent indication that employer used policy as a proxy for intentional racial discrimination. Court deemed EEOC’s compliance manual not persuasive due to inconsistencies in prior rulings. Furthermore, a numerous amount of precedent cases on the issue, including a binding one by the fifth circuit, have rejected the argument that Title VII protects hairstyles culturally associated with race. Holding: The court held that the district court did not err in dismissing the original complaint and in concluding that the proposed amended complaint was futile, because the EEOC’s original and proposed amended complaint did not state a plausible claim that CMS intentionally discriminated against Ms. Jones because of her race. Order: The court affirms....