Dawson v. Bumble & Bumble

Argued: February 25, 2004 BACKGROUND This is an employment discrimination case. Plaintiff-Appellant Dawn Dawson, a self-described ""lesbian female, who does not conform to gender norms in that she does not meet stereotyped expectations of femininity and may be perceived as more masculine than a stereotypical woman,"" claims that she suffered discrimination on the basis of sex, sex stereotyping, and/or sexual orientation in violation of federal, state, and municipal law. See Title VII of the Civil Rights Act of 1964 (""Title VII""), 42 U.S.C. § 2000e et seq.; New York State Human Rights Law (""NYSHRL""), N.Y. Exec. Law § 290 et seq.; New York City Human Rights Law (""NYCHRL""), N.Y.C. Admin. Code, Title 8. Dawson's former employer, Defendant-Appellee Bumble & Bumble, describes itself as ""a prestigious, high-end hair salon in Manhattan, known for its innovative hair cutting techniques."" Dawson was hired by Bumble & Bumble in early 1999 as a ""hair assistant."" Dawson describes the duties of this position as including ""assisting [hair] stylists in all aspects of their jobs, keeping their work areas in the salon clean, escorting clients to different areas of the salon, shampooing clients' hair, and blow-drying clients' hair.""