527 F. Supp. 229 (S.D.N.Y. 1981)
Rogers v. American Airlines, Inc.
Does an employer's grooming policy that bans certain hairstyles which are predominantly associated with a particular race constitute racial discrimination under Title VII of the Civil Rights Act?
Under Title VII of the Civil Rights Act, employment practices that are not intentionally discriminatory but result in disparate impact on protected classes must be justified by business necessity to avoid being deemed unlawful.
The court held that American Airlines' grooming policy did not constitute racial discrimination under Title VII, as Rogers failed to demonstrate that the policy had a disparate impact on African American women, nor did she establish that the policy was implemented with discriminatory intent.
The Rogers case is significant because it highlights the importance of evidence in claims of discrimination based on policies that indirectly affect racial groups. The case underscores that plaintiffs must provide clear evidence demonstrating how facially neutral policies result in discrimination. This decision informs students about the evidence needed to establish both intentional and disparate impact discrimination claims, emphasizing the procedural and substantive hurdles faced in employment discrimination litigation.