## Facts

- Catastrophe Management Solutions (CMS), a claims-processing company in Mobile, Alabama, hired customer service representatives for a call-center position with no public contact.
- CMS maintained a written grooming policy requiring a “business/professional image” and prohibiting “excessive hairstyles.”
- Chastity Jones, a Black applicant, interviewed in business attire while wearing short dreadlocks.
- A CMS manager told Jones she was hired subject to completing pre-employment requirements.
- In a later private conversation, the manager told Jones CMS would not hire her with dreadlocks, stating that dreadlocks “tend to get messy,” and referenced a prior applicant who cut off dreadlocks to obtain employment.
- Jones refused to cut her hair, and CMS rescinded the job offer.
- The EEOC sued under Title VII on Jones’s behalf, alleging the dreadlock prohibition constituted race discrimination and imposed more burdensome requirements on Black applicants.
- The EEOC’s proposed amended complaint alleged dreadlocks are physiologically and culturally associated with people of African descent.

## Issues

1. Whether the EEOC plausibly alleged intentional race discrimination (disparate treatment) under Title VII based on CMS’s enforcement of a race-neutral grooming policy prohibiting dreadlocks.
2. Whether a dreadlocks ban targets an immutable racial characteristic protected by Title VII or instead regulates a mutable hairstyle.
3. Whether the district court properly denied leave to amend as futile.

## Decision

- The Eleventh Circuit affirmed dismissal under Rule 12(b)(6).
- The court held the EEOC did not plausibly allege CMS intentionally discriminated against Jones “because of” race.
- The court concluded a prohibition on dreadlocks regulates a mutable hairstyle, not an immutable racial characteristic, under controlling precedent.
- The court affirmed denial of leave to amend because the proposed amended complaint still failed to state a disparate-treatment claim.

## Legal Principles

- Title VII disparate-treatment liability requires plausible allegations of intentional discrimination because of a protected trait; disparate impact allegations are not sufficient when that theory is disclaimed.
- Under Eleventh Circuit precedent, Title VII race discrimination protection centers on immutable racial characteristics (including natural hair texture), not mutable grooming choices such as particular hairstyles.
- A facially race-neutral grooming policy does not plausibly show discriminatory intent absent allegations of discriminatory application (e.g., unequal enforcement by race) or targeting of an immutable racial trait.
- Leave to amend may be denied as futile when the proposed amended complaint would still fail to state a claim.

## Conclusion

The Eleventh Circuit held that, on the pleaded facts and under existing circuit precedent, a workplace rule barring dreadlocks—without allegations of discriminatory enforcement or discrimination tied to an immutable racial characteristic—does not plausibly allege intentional race discrimination under Title VII, and amendment was properly denied as futile.


Equal Emp. Opportunity Comm’n v. Catastrophe Mgmt. Sols., 852 F.3d 1018 (11th Cir. 2016)