## Facts

- Christine A. Craft, a television journalist, was hired by Metromedia, Inc. to work as an evening news coanchor at KMBC-TV in Kansas City, Missouri.
- The station maintained on-air grooming and appearance expectations; Craft contended the standards were stricter for women and reflected sex-based stereotypes, including differing expectations for wardrobe frequency and style.
- After Craft began coanchoring, the station conducted audience focus groups that reacted negatively to her on-air presentation.
- In response, KMBC directed Craft to modify her appearance through materials on clothing and makeup, use of a clothing consultant, and a clothing calendar specifying what to wear.
- The station also had required other anchors, including men, to make appearance changes such as weight loss, hairstyle changes, and wardrobe adjustments.
- KMBC ultimately removed Craft from the coanchor position and reassigned her to a reporter role; Craft viewed the reassignment as a demotion and later left the station.
- Craft sued alleging (1) sex discrimination under Title VII, (2) unequal pay under the Equal Pay Act, and (3) fraudulent misrepresentation inducing her to accept employment.
- At trial, the jury returned a defense verdict on the Equal Pay Act claim; on fraud, a jury found for Craft with substantial damages, but the trial court set aside that verdict as excessive and ordered a new trial; a second jury again found for Craft on fraud.
- The trial judge rejected the advisory jury’s Title VII finding for Craft and entered judgment for Metromedia on the Title VII claim; Craft appealed adverse rulings, and Metromedia appealed the fraud judgment.

## Issues

1. Whether the station’s grooming and appearance standards, and their enforcement, constituted sex discrimination under Title VII.
2. Whether the evidence required a new trial after the defense verdict on Craft’s Equal Pay Act claim.
3. Whether Craft presented sufficient evidence of fraudulent misrepresentation under Missouri law, including proof of a present intent to deceive at the time of recruitment statements.
4. Whether Craft’s reassignment and working conditions amounted to constructive discharge.

## Decision

- The Eighth Circuit affirmed judgment for Metromedia on the Title VII claim, concluding Craft did not prove sex discrimination.
- The Eighth Circuit affirmed the verdict for Metromedia on the Equal Pay Act claim and the denial of a new trial.
- The Eighth Circuit reversed the fraud judgment and directed entry of judgment for Metromedia, holding Craft failed to make a submissible case of fraud.
- The court rejected Craft’s constructive discharge theory.

## Legal Principles

- Title VII permits employer appearance standards in a visual industry when grounded in legitimate business reasons and not shown, in application, to impose unequal burdens or discriminatory enforcement based on sex.
- Appellate review of a bench finding on Title VII liability is deferential; the judgment is upheld absent clear error in factual findings.
- Under the Equal Pay Act, a defense verdict may stand where evidence supports that pay differences were based on factors other than sex (e.g., experience, market considerations, differing roles), and denial of a new trial is reviewed for abuse of discretion.
- Under Missouri fraud law, recruitment statements about future conduct are not actionable absent evidence that, when made, the speaker had a present intention not to perform; later changes in approach or business-driven decisions do not alone prove fraudulent intent.
- Constructive discharge requires working conditions so intolerable that a reasonable person would feel compelled to resign and, where relevant, a showing that the conditions were caused by unlawful conduct.

## Conclusion

The Eighth Circuit upheld Metromedia’s defense victories on Title VII and the Equal Pay Act, and it eliminated Craft’s fraud recovery by ruling the evidence did not support a finding that the station made recruitment assurances with a present intent to deceive; the reassignment did not amount to constructive discharge.


Craft v. Metromedia, Inc., 766 F.2d 1205 (8th Cir. 1985)