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The Legality of Employee Dress Codes and Grooming Policies

Work­place dress codes and groom­ing poli­cies are a com­mon part of employ­ment, but they can also cre­ate legal chal­lenges. Employ­ers want pro­fes­sion­al-look­ing employ­ees, while work­ers want to express them­selves and avoid unnec­es­sary restric­tions. So, where’s the legal line? Let’s break down the do’s and don’ts of work­place appear­ance policies.

Can Employers Legally Enforce Dress Codes?

Yes, employ­ers gen­er­al­ly have the right to enforce dress codes and groom­ing poli­cies, as long as they are job-relat­ed and applied fair­ly. The key legal con­sid­er­a­tions include:

  • Anti-Dis­crim­i­na­tion Laws: Poli­cies can­not dis­crim­i­nate based on race, sex, reli­gion, dis­abil­i­ty, or oth­er pro­tect­ed cat­e­gories under Title VII of the Civ­il Rights Act of 1964 (42 U.S.C. § 2000e‑2).
  • Dis­abil­i­ty Accom­mo­da­tions: Employ­ers must pro­vide rea­son­able accom­mo­da­tions for employ­ees with dis­abil­i­ties under the Amer­i­cans with Dis­abil­i­ties Act (ADA) (42 U.S.C. § 12112(b)(5)).
  • Reli­gious Accom­mo­da­tions: Employ­ees must be allowed to wear reli­gious attire (such as hijabs or yarmulkes) unless the employ­er can show an undue hard­ship (EEOC v. Aber­crom­bie & Fitch Stores, Inc., 575 U.S. 768 (2015)).
  • Gen­der and Hair Dis­crim­i­na­tion: Some courts and states have ruled that poli­cies restrict­ing nat­ur­al hair­styles (such as afros, braids, and dread­locks) can be racial­ly dis­crim­i­na­to­ry (CROWN Act laws are gain­ing momen­tum nation­wide, though not yet in West Virginia).

Dress Codes and Gender-Based Rules

His­tor­i­cal­ly, some dress codes have treat­ed male and female employ­ees differently—such as requir­ing women to wear make­up or skirts while men wear suits. While some gen­der dis­tinc­tions may still be allowed, they can­not impose a greater bur­den on one gen­der than anoth­er (Jes­persen v. Harrah’s Oper­at­ing Co., 444 F.3d 1104 (9th Cir. 2006)). Employ­ers should draft gen­der-neu­tral poli­cies that focus on pro­fes­sion­al­ism rather than out­dat­ed stereotypes.

Tattoos, Piercings, and Personal Expression

Employ­ers can restrict tat­toos and pierc­ings in most work­places, but they must apply these rules con­sis­tent­ly. If a pol­i­cy bans tat­toos, it must apply to all employees—not just cer­tain groups. How­ev­er, an employ­er may need to accom­mo­date reli­gious or cul­tur­al tat­toos if an employ­ee requests an exemption.

What About West Virginia?

West Vir­ginia fol­lows fed­er­al anti-dis­crim­i­na­tion laws but does not have spe­cif­ic dress code leg­is­la­tion. How­ev­er, employ­ees may have claims under the West Vir­ginia Human Rights Act (W. Va. Code § 5–11‑9) if a pol­i­cy dis­pro­por­tion­ate­ly affects a pro­tect­ed class.

CROWN Act Laws

CROWN Act laws, or laws mod­eled after the Cre­at­ing a Respect­ful and Open World for Nat­ur­al Hair (CROWN) Act, are a set of state and local statutes aimed at pro­hibit­ing hair dis­crim­i­na­tion. These laws pre­vent employ­ers, schools, and oth­er insti­tu­tions from dis­crim­i­nat­ing against indi­vid­u­als based on hair­styles com­mon­ly asso­ci­at­ed with a par­tic­u­lar racial, cul­tur­al, or eth­nic group.

The orig­i­nal CROWN Act was first passed in Cal­i­for­nia in 2019. It specif­i­cal­ly out­lawed dis­crim­i­na­tion against styles such as afros, braids, twists, locks (also known as dread­locks), and oth­er nat­ur­al or pro­tec­tive hair­styles often worn by Black indi­vid­u­als. Since then, many oth­er states and munic­i­pal­i­ties have adopt­ed sim­i­lar measures.

In essence, CROWN Act laws seek to ensure that peo­ple are not penal­ized, denied oppor­tu­ni­ties, or treat­ed unfair­ly sim­ply because of the nat­ur­al or pro­tec­tive ways they wear their hair.

West Vir­ginia has not adopt­ed any such law.

Best Practices for Employers

To avoid legal trou­ble, employ­ers should:

  • Make dress codes job-relat­ed and neu­tral (e.g., requir­ing safe­ty gear rather than spe­cif­ic hairstyles).
  • Apply rules con­sis­tent­ly to avoid dis­crim­i­na­tion claims.
  • Con­sid­er rea­son­able accom­mo­da­tions for reli­gious or med­ical reasons.
  • Clear­ly com­mu­ni­cate poli­cies in employ­ee hand­books and train­ing sessions.

What Employees Should Do

If an employ­ee believes a dress code is dis­crim­i­na­to­ry, they should:

  • Ask for an accom­mo­da­tion if it relates to reli­gion or disability.
  • Doc­u­ment incon­sis­ten­cies in how the pol­i­cy is enforced.
  • File a com­plaint inter­nal­ly or with the EEOC if necessary.

Conclusion

Work­place dress codes and groom­ing poli­cies must bal­ance employ­er inter­ests with employ­ee rights. While busi­ness­es can set appear­ance stan­dards, they must ensure com­pli­ance with anti-dis­crim­i­na­tion laws and pro­vide accom­mo­da­tions when required. Clear, fair poli­cies help every­one avoid legal dis­putes and main­tain a pro­fes­sion­al work environment.

Drew M. Capuder
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