Summary: Workplace Discrimination Based On Augmented Appearance
Great Falls College—Montana State University
Workplace Discrimination Based On Augmented Appearance
Katrina Christopherson
Business Law and Ethics
Teri Ford-Dwyer
April 1, 2015
An amendment to the Civil Rights Act of 1964, Title VII, makes it unlawful for any employer that has more than fifteen employees to discriminate against the employee based on religion, race, sex, color or national origin (U.S. Equal Employment Opportunity Commission). The Merriam-Webster Dictionary defines discrimination as the practice of unfairly treating a person or group of people differently from other people or groups of people. Even though laws have changed and employers are treating employees more fairly, there still is a vast …show more content…
number of discrimination lawsuits every year. According to the U.S. Equal Employment Opportunity Commission, there are over 40,000 discrimination lawsuits filed every year. A large amount of these lawsuits is discrimination against appearances, even though there is no law prohibiting use of appearance in considering an employee. Augmented appearance is a huge part of the diversity in our country. There is a wide range of personal expressions that can be considered augmented, such as piercings, tattoos, plastic surgery, hairstyles, makeup, and dress code. For example, 41% of the adult workforce has tattoos and 61% has piercings (Stapaw.com). A wide range of employers in this country is fully accepting of such things with minor guidelines. However, many perceive professionalism not to include such things. Discrimination against appearances may not be easy to fight, but discrimination against religion is.
There are certain religious groups that require members to augment their appearance. The Church of Body Modification (CBM) is an example of a religious group that practices ancient and modern body modification arts. They believe that tattoos and piercings are essential to their spirituality and strengthens the bond between mind, body and soul. They believe that body modification ensures that they are spiritually complete and healthy individuals (United States Church of Body Modification). Therefore, tattoos or piercings can raise both discrimination and constitutional issues. Religious discrimination can be brought against someone who has certain religious observances and practices, as well as religious beliefs. The employer can be accountable for discrimination unless the employer demonstrates that he is unable to reasonably accommodate an employee’s or prospective employee’s religious observance or practice without undue hardship on the conduct of the employer’s business …show more content…
(Kramer). In a case involving Red Robin Gourmet Burgers, one of their employees refused to cover up a tattoo on his wrist. It was determined that he was violating company policy that tattoos and piercing must not be visible. The tattoo, consisting of bands less than a quarter-inch wide that encircled his wrist, contained writing in Coptic, that, when translated, stated: “My Father Ra is Lord. I am the son who exists of his Father; I am the Father who exists of his son.” When directed to cover up the tattoos, the employee claimed that the tattoos were obtained as part of his religion, Kemetcism. Kemeticism is a religion with roots in ancient Egypt according to the employee, “intentionally covering the tattoos would be a sin, incidentally covering the (such as by wearing gloves when it was cold or wearing long sleeve shirt) would not be a sin.” The Equal Employment Opportunity Commission claimed that Red Robin was violating the employee’s religious rights under Title VII. The Ninth Circuit court decided for the employee because the justices did not accept the restaurant’s “purported hypothetical fears and claims” that if the company made an exception for this employee regarding his tattoos, it would force the restaurant to permit all employees’ tattoos and piercings (Kramer).
Starbucks Coffee Company, which Fortune named the fifth most admired company in the world, recently changed their corporate policies regarding body augmentation. I spoke with the manager of the Great Falls Starbucks store, Sabrina Olson, and she explained the new policies and the company’s reasoning behind it. She stated that the company realized that with the younger generations entering the workforce, and the increase in social acceptance of tattoos and piercings, their policies needed “to evolve with society’s views.” Ms. Olson also stated that managers across the United States were finding it difficult to retain qualified, competent employees without tattoos and/or piercings. Until October of 2014, Starbuck’s policy forbade tattoos and piercings that were visible when wearing the company’s summer “uniform” of short-sleeve black shirts and khaki shorts. The new corporate policy states that employees are permitted to have nose rings, and tattoos, as long as they are not offensive, meaning that they cannot have curse words, be derogative to any race or religion, or be gang affiliated. After speaking with Ms. Olson, I had the opportunity to speak with some of the employees that work for Starbucks. During this process I found that they have a profound amount of respect for the company, its leaders, and their manager, Ms. Olson. The consensus among them was that since the policy change, employee morale has increased, and so has the diversity within the company. Ms. Olson said that one of the company’s slogans, “Meet me at Starbucks”, is an adage to the diversity of the customers, as well as the employees. While many companies, like Starbucks, are changing with the times, there are still many that are not willing to adapt to the “new normal” when it comes to piercings and tattoos. “According to the Equal Employment Opportunity Commission, employers are allowed to impose dress codes, as well as codes on employee appearance, as long as they do not discriminate against or hinder a person’s race, color, religion, age, national origin, or gender.” (Body art in the Workplace). For example, in a case where three employees of the Kentucky State Parks were terminated because they failed to cover their tattoos and wear their shirts tucked-in, the federal appeals court ruled that Kentucky State Parks did not violate the employee’s civil rights by enforcing the dress code. In some industries, tattoo policies are a matter of safety. For the safety of emergency personnel such as police officers, firefighters and emergency medical technicians, officials must create and enforce strict tattoo policies. In Hartford, Connecticut, there was an example of safety related tattoo policies that involved police officers with spiderweb tattoos on their arms. When the Chief of Police learned that a spiderweb tattoo might be perceived as racist and that in some locations, a racist earns that specific tattoo by killing a minority, he became concerned with the safety of his officers. In response to the “major concern” of the command staff, the Chief of Police implemented a new policy on tattoos. The policy read, “The Chief of Police has the authority to order personnel to cover tattoos that are deemed offensive and/or presenting an unprofessional appearance. Personnel shall cover that tattoo with either a flesh tone, navy blue or white type of material that matches the uniform shirt or wear a long sleeve shirt in accordance with the Winter Uniform of the Day Standard.” (Kramer). The command staff of the Hartford Police Department implemented this policy in response to concerns for the responding officers. The HPD officers respond in predominately minority communities where officers that “sport tattoos that have been associated with white supremacist groups may result in an explosive situation, endangering both the officers and the community.” (Kramer).
Another case that involved emergency personnel occurred in Montgomery, Alabama. The Montgomery fire department put into to place a new policy on tattoos, brands, and body piercings for the department personnel. The policy prohibited tattoos and brands “anywhere on the body that are obscene and/or advocate sexual, racial, ethnic, or religious discrimination” as well as those that are “prejudicial to the good order and discipline or of a nature that tends to bring discredit upon the Montgomery Fire Department and the City of Montgomery.” The policy provided that employees who obtained non-compliant tattoos or brands before the policy went into effect would be required to remove them if the fire chief or his designee felt that the circumstances warranted such removal. Otherwise, they would be grandfathered for purposes of compliance with his rule and regulation” (United States District Court, M.D. Alabama, Northern Division No. 2:06cv578-MHT).
Hartwell, a firefighter for the Montgomery fire department, felt that his fellow firefighter, Gordon, had an offensive tattoo on his bicep. Within days of the new policy going into effect, Hartwell filed a personal complaint against Gordon stating that he was personally offended by the tattoo. The tattoo was that of a skull and cross bones super imposed on a confederate flag. “Hartwell notes by way of background, the Confederate flag was at that time part of the seal of the City of Montgomery, which was displayed on fire department uniforms. This was a matter of some public controversy, and the city seal was later modified such that the flag is no longer displayed. Upon receiving Hartwell’s complaint, the fire department concluded that Gordon was not in violation of the tattoo policy and took no action.”
Although, the department did not find Gordon’s tattoo in violation of their new policy, Hartwell still found the tattoo offensive and he felt his complaint against his co-worker was the beginning of a hostile working environment. Eventually, Gordon received a promotion to district chief, and he became Hartwell’s supervisor. While he was Hartwell’s supervisor, he brought disciplinary action, and eventually demoted, Hartwell. Hartwell interpreted these actions as retaliation to his earlier claim regarding Gordon’s tattoo, and therefore claimed that working in the department constituted a hostile work environment.
In answer to Hartwell’s claim that the disciplinary actions were in retaliation, Gordon stated that disciplinary actions were in direct relation to Hartwell’s insubordination. In the first incident requiring discipline, Hartwell refused to sign an acknowledgement statement regarding a failed inspection. In another incident, Hartwell had volunteered to cover a shift, and during that shift, he left his post. He claimed this was due to illness, however, Gordon suspected that the illness was a ruse, and requested that Hartwell bring a letter from a doctor upon returning to work. Hartwell refused to provide the letter, and was subsequently written up for not following a direct order.
The previously mentioned incidents, among others, culminated in Hartwell filing a written grievance against Gordon with the assistant chief of the fire department. Upon the assistant chief reviewing the grievance, he concluded, “Hartwell had violated several department rules, including making false statements, violating the chain of command, and refusing to carry out orders.” The assistant chief recommended that Hartwell be demoted from Sergeant/Engineer to Firefighter. When Gordon carried out this recommendation and demoted Hartwell, Hartwell claimed that he was demoted in retaliation for his earlier complaint about Gordon’s tattoo.
“Hartwell brought one federal claim and one state claim. First, he brings suit for money damages under 42 U.S.C. § 1983 against Gordon in his individual capacity, claiming that Gordon violated his right to free speech under the First Amendment by causing his demotion in retaliation for his complaint regarding Gordon’s tattoo. Second, he seeks reinstatement, back pay, and attorneys’ fees via common-law writ of certiorari to the personnel board for insufficient evidence to uphold his demotion.”
The Federal claim was, “Hartwell claims that Gordon violated the First Amendment by causing his demotion in retaliation for his complaint regarding Gordon’s tattoo. The law is well established that a [public] employee may not be discharged in retaliation for speech protected under the First Amendment. However, a public employee’s freedom of speech is not absolute. To set forth a claim of retaliation, a public employee must show: (1) she was speaking as a citizen on a matter of public concern; (2) her interests as a citizen outweighed the interests of the [government] as an employer; and (3) the speech played a substantial or motivating role in the adverse employment action. If the plaintiff establishes these elements, the burden shifts to the defendant to prove [4] it would have made the same adverse employment decision absent the employee’s speech. The first two elements are issue of law: Was the employee’s speech constitutionally protected? The third and fourth elements are issues of fact: Was the adverse employment action taken in retaliation for the speech?”
The question at hand was whether Hartwell was speaking as a citizen, or was he speaking as an employee. Hartwell showed personal disdain for Gordon’s tattoo as an employee but not with the fire departments policy, which would have made his speech a public matter. “The Supreme Court held that the plaintiff’s remark was protected speech, even though the remarks were made in a private rather than public setting.” Even though Hartwell discussed his complaint in a private matter that does not determine whether it was a public or private issue. The court made the determination that Hartwell was speaking as both an employee and a citizen. “Hartwell’s affidavit does state that he “found [the tattoo] offensive and felt that it was in violation of the City of Montgomery’s Tattoo Policy….I felt that the tattoo was a symbol that advocated racial discrimination and on a public employee, was a matter of public concern.”
The court leaned more in the direction that Hartwell was speaking as a citizen on a matter of public concern. “In sum, the court finds that Hartwell spoke as a citizen on a matter of public concern when he complained that Gordon, a public employee and fellow firefighter, bore a tattoo of the Confederate flag in violation of the fire department’s tattoo policy. The court finds that there is sufficient evidence that Hartwell spoke in his capacity as a citizen rather than in his capacity as employee.”
The Federal Court reviewed all aspects of this case and in conclusion made the determination that the summary judgment should be granted in favor of Gordon on Hartwell’s federal claim. The state law claim was remanded to the state court and the State court will make an appropriate judgment.
As all of these cases exemplify, company and employee policies on tattoos, in both the public and private sector, must be seriously considered before implementing. If a policy is too generalized, it leaves a large gray area that puts the employer at risk of discrimination lawsuits and costly litigation. If the policy is too strict, it limits the pool of competent workers that the company can draw from, it inhibits diversity, and it may be perceived as infringing on employees’ Constitutional rights of freedom of expression and freedom of religion.
Works Cited
United States Church of Body Modification.
“Mission Statement”. 2015.www.uscobm.com. Web. 20 March 2015.
Commission, United States Equal Employment Opportunity. "Religiou Garb and Grooming in the Workplace." 2014. www.eeoc.gov. Web. 22 March 2015.
Harris Polls. www.harrisinteractive.com. 16-23 January 2012. Web. 22 March 2015. <www.harrisinteractive.com/NewsRoom/HarrisPolls/tabid/447/mid/1508/articeld/970/ctl/ReadCustomDefault/Default.aspx>.
Kramer, Ronald J. “Recent Developments in Government Operations And Liability Generation Y: Tattoos, Piercing, And Other Issues For The Private And Public Employer.” Urban Lawyer 38.3 (2006): 593-611. Academic Search Complete. Web. 21 March. 2015
Lee Hartwell v. The City of Montgomery, Alabama, Personnel Board of the City and County of Montgomery, Alabama, and District Chief Kelly D. Gordon, in his individual capacity. No. 2:06cv518-MHT. United States District Court, M.D. Alabama, Northern Division. 10 May 2007. Web. 28 January 2015.
Support Tattoos And Piercings At Work. www.stapaw.com/#!tattoo-in-the-worklace-statistics/c1490. March 2015. Web. 21 March
2015.
Workplace Discrimination Based On Augmented Appearance
Katrina Christopherson
Business Law and Ethics
Teri Ford-Dwyer
April 1, 2015
An amendment to the Civil Rights Act of 1964, Title VII, makes it unlawful for any employer that has more than fifteen employees to discriminate against the employee based on religion, race, sex, color or national origin (U.S. Equal Employment Opportunity Commission). The Merriam-Webster Dictionary defines discrimination as the practice of unfairly treating a person or group of people differently from other people or groups of people. Even though laws have changed and employers are treating employees more fairly, there still is a vast …show more content…
number of discrimination lawsuits every year. According to the U.S. Equal Employment Opportunity Commission, there are over 40,000 discrimination lawsuits filed every year. A large amount of these lawsuits is discrimination against appearances, even though there is no law prohibiting use of appearance in considering an employee. Augmented appearance is a huge part of the diversity in our country. There is a wide range of personal expressions that can be considered augmented, such as piercings, tattoos, plastic surgery, hairstyles, makeup, and dress code. For example, 41% of the adult workforce has tattoos and 61% has piercings (Stapaw.com). A wide range of employers in this country is fully accepting of such things with minor guidelines. However, many perceive professionalism not to include such things. Discrimination against appearances may not be easy to fight, but discrimination against religion is.
There are certain religious groups that require members to augment their appearance. The Church of Body Modification (CBM) is an example of a religious group that practices ancient and modern body modification arts. They believe that tattoos and piercings are essential to their spirituality and strengthens the bond between mind, body and soul. They believe that body modification ensures that they are spiritually complete and healthy individuals (United States Church of Body Modification). Therefore, tattoos or piercings can raise both discrimination and constitutional issues. Religious discrimination can be brought against someone who has certain religious observances and practices, as well as religious beliefs. The employer can be accountable for discrimination unless the employer demonstrates that he is unable to reasonably accommodate an employee’s or prospective employee’s religious observance or practice without undue hardship on the conduct of the employer’s business …show more content…
(Kramer). In a case involving Red Robin Gourmet Burgers, one of their employees refused to cover up a tattoo on his wrist. It was determined that he was violating company policy that tattoos and piercing must not be visible. The tattoo, consisting of bands less than a quarter-inch wide that encircled his wrist, contained writing in Coptic, that, when translated, stated: “My Father Ra is Lord. I am the son who exists of his Father; I am the Father who exists of his son.” When directed to cover up the tattoos, the employee claimed that the tattoos were obtained as part of his religion, Kemetcism. Kemeticism is a religion with roots in ancient Egypt according to the employee, “intentionally covering the tattoos would be a sin, incidentally covering the (such as by wearing gloves when it was cold or wearing long sleeve shirt) would not be a sin.” The Equal Employment Opportunity Commission claimed that Red Robin was violating the employee’s religious rights under Title VII. The Ninth Circuit court decided for the employee because the justices did not accept the restaurant’s “purported hypothetical fears and claims” that if the company made an exception for this employee regarding his tattoos, it would force the restaurant to permit all employees’ tattoos and piercings (Kramer).
Starbucks Coffee Company, which Fortune named the fifth most admired company in the world, recently changed their corporate policies regarding body augmentation. I spoke with the manager of the Great Falls Starbucks store, Sabrina Olson, and she explained the new policies and the company’s reasoning behind it. She stated that the company realized that with the younger generations entering the workforce, and the increase in social acceptance of tattoos and piercings, their policies needed “to evolve with society’s views.” Ms. Olson also stated that managers across the United States were finding it difficult to retain qualified, competent employees without tattoos and/or piercings. Until October of 2014, Starbuck’s policy forbade tattoos and piercings that were visible when wearing the company’s summer “uniform” of short-sleeve black shirts and khaki shorts. The new corporate policy states that employees are permitted to have nose rings, and tattoos, as long as they are not offensive, meaning that they cannot have curse words, be derogative to any race or religion, or be gang affiliated. After speaking with Ms. Olson, I had the opportunity to speak with some of the employees that work for Starbucks. During this process I found that they have a profound amount of respect for the company, its leaders, and their manager, Ms. Olson. The consensus among them was that since the policy change, employee morale has increased, and so has the diversity within the company. Ms. Olson said that one of the company’s slogans, “Meet me at Starbucks”, is an adage to the diversity of the customers, as well as the employees. While many companies, like Starbucks, are changing with the times, there are still many that are not willing to adapt to the “new normal” when it comes to piercings and tattoos. “According to the Equal Employment Opportunity Commission, employers are allowed to impose dress codes, as well as codes on employee appearance, as long as they do not discriminate against or hinder a person’s race, color, religion, age, national origin, or gender.” (Body art in the Workplace). For example, in a case where three employees of the Kentucky State Parks were terminated because they failed to cover their tattoos and wear their shirts tucked-in, the federal appeals court ruled that Kentucky State Parks did not violate the employee’s civil rights by enforcing the dress code. In some industries, tattoo policies are a matter of safety. For the safety of emergency personnel such as police officers, firefighters and emergency medical technicians, officials must create and enforce strict tattoo policies. In Hartford, Connecticut, there was an example of safety related tattoo policies that involved police officers with spiderweb tattoos on their arms. When the Chief of Police learned that a spiderweb tattoo might be perceived as racist and that in some locations, a racist earns that specific tattoo by killing a minority, he became concerned with the safety of his officers. In response to the “major concern” of the command staff, the Chief of Police implemented a new policy on tattoos. The policy read, “The Chief of Police has the authority to order personnel to cover tattoos that are deemed offensive and/or presenting an unprofessional appearance. Personnel shall cover that tattoo with either a flesh tone, navy blue or white type of material that matches the uniform shirt or wear a long sleeve shirt in accordance with the Winter Uniform of the Day Standard.” (Kramer). The command staff of the Hartford Police Department implemented this policy in response to concerns for the responding officers. The HPD officers respond in predominately minority communities where officers that “sport tattoos that have been associated with white supremacist groups may result in an explosive situation, endangering both the officers and the community.” (Kramer).
Another case that involved emergency personnel occurred in Montgomery, Alabama. The Montgomery fire department put into to place a new policy on tattoos, brands, and body piercings for the department personnel. The policy prohibited tattoos and brands “anywhere on the body that are obscene and/or advocate sexual, racial, ethnic, or religious discrimination” as well as those that are “prejudicial to the good order and discipline or of a nature that tends to bring discredit upon the Montgomery Fire Department and the City of Montgomery.” The policy provided that employees who obtained non-compliant tattoos or brands before the policy went into effect would be required to remove them if the fire chief or his designee felt that the circumstances warranted such removal. Otherwise, they would be grandfathered for purposes of compliance with his rule and regulation” (United States District Court, M.D. Alabama, Northern Division No. 2:06cv578-MHT).
Hartwell, a firefighter for the Montgomery fire department, felt that his fellow firefighter, Gordon, had an offensive tattoo on his bicep. Within days of the new policy going into effect, Hartwell filed a personal complaint against Gordon stating that he was personally offended by the tattoo. The tattoo was that of a skull and cross bones super imposed on a confederate flag. “Hartwell notes by way of background, the Confederate flag was at that time part of the seal of the City of Montgomery, which was displayed on fire department uniforms. This was a matter of some public controversy, and the city seal was later modified such that the flag is no longer displayed. Upon receiving Hartwell’s complaint, the fire department concluded that Gordon was not in violation of the tattoo policy and took no action.”
Although, the department did not find Gordon’s tattoo in violation of their new policy, Hartwell still found the tattoo offensive and he felt his complaint against his co-worker was the beginning of a hostile working environment. Eventually, Gordon received a promotion to district chief, and he became Hartwell’s supervisor. While he was Hartwell’s supervisor, he brought disciplinary action, and eventually demoted, Hartwell. Hartwell interpreted these actions as retaliation to his earlier claim regarding Gordon’s tattoo, and therefore claimed that working in the department constituted a hostile work environment.
In answer to Hartwell’s claim that the disciplinary actions were in retaliation, Gordon stated that disciplinary actions were in direct relation to Hartwell’s insubordination. In the first incident requiring discipline, Hartwell refused to sign an acknowledgement statement regarding a failed inspection. In another incident, Hartwell had volunteered to cover a shift, and during that shift, he left his post. He claimed this was due to illness, however, Gordon suspected that the illness was a ruse, and requested that Hartwell bring a letter from a doctor upon returning to work. Hartwell refused to provide the letter, and was subsequently written up for not following a direct order.
The previously mentioned incidents, among others, culminated in Hartwell filing a written grievance against Gordon with the assistant chief of the fire department. Upon the assistant chief reviewing the grievance, he concluded, “Hartwell had violated several department rules, including making false statements, violating the chain of command, and refusing to carry out orders.” The assistant chief recommended that Hartwell be demoted from Sergeant/Engineer to Firefighter. When Gordon carried out this recommendation and demoted Hartwell, Hartwell claimed that he was demoted in retaliation for his earlier complaint about Gordon’s tattoo.
“Hartwell brought one federal claim and one state claim. First, he brings suit for money damages under 42 U.S.C. § 1983 against Gordon in his individual capacity, claiming that Gordon violated his right to free speech under the First Amendment by causing his demotion in retaliation for his complaint regarding Gordon’s tattoo. Second, he seeks reinstatement, back pay, and attorneys’ fees via common-law writ of certiorari to the personnel board for insufficient evidence to uphold his demotion.”
The Federal claim was, “Hartwell claims that Gordon violated the First Amendment by causing his demotion in retaliation for his complaint regarding Gordon’s tattoo. The law is well established that a [public] employee may not be discharged in retaliation for speech protected under the First Amendment. However, a public employee’s freedom of speech is not absolute. To set forth a claim of retaliation, a public employee must show: (1) she was speaking as a citizen on a matter of public concern; (2) her interests as a citizen outweighed the interests of the [government] as an employer; and (3) the speech played a substantial or motivating role in the adverse employment action. If the plaintiff establishes these elements, the burden shifts to the defendant to prove [4] it would have made the same adverse employment decision absent the employee’s speech. The first two elements are issue of law: Was the employee’s speech constitutionally protected? The third and fourth elements are issues of fact: Was the adverse employment action taken in retaliation for the speech?”
The question at hand was whether Hartwell was speaking as a citizen, or was he speaking as an employee. Hartwell showed personal disdain for Gordon’s tattoo as an employee but not with the fire departments policy, which would have made his speech a public matter. “The Supreme Court held that the plaintiff’s remark was protected speech, even though the remarks were made in a private rather than public setting.” Even though Hartwell discussed his complaint in a private matter that does not determine whether it was a public or private issue. The court made the determination that Hartwell was speaking as both an employee and a citizen. “Hartwell’s affidavit does state that he “found [the tattoo] offensive and felt that it was in violation of the City of Montgomery’s Tattoo Policy….I felt that the tattoo was a symbol that advocated racial discrimination and on a public employee, was a matter of public concern.”
The court leaned more in the direction that Hartwell was speaking as a citizen on a matter of public concern. “In sum, the court finds that Hartwell spoke as a citizen on a matter of public concern when he complained that Gordon, a public employee and fellow firefighter, bore a tattoo of the Confederate flag in violation of the fire department’s tattoo policy. The court finds that there is sufficient evidence that Hartwell spoke in his capacity as a citizen rather than in his capacity as employee.”
The Federal Court reviewed all aspects of this case and in conclusion made the determination that the summary judgment should be granted in favor of Gordon on Hartwell’s federal claim. The state law claim was remanded to the state court and the State court will make an appropriate judgment.
As all of these cases exemplify, company and employee policies on tattoos, in both the public and private sector, must be seriously considered before implementing. If a policy is too generalized, it leaves a large gray area that puts the employer at risk of discrimination lawsuits and costly litigation. If the policy is too strict, it limits the pool of competent workers that the company can draw from, it inhibits diversity, and it may be perceived as infringing on employees’ Constitutional rights of freedom of expression and freedom of religion.
Works Cited
United States Church of Body Modification.
“Mission Statement”. 2015.www.uscobm.com. Web. 20 March 2015.
Commission, United States Equal Employment Opportunity. "Religiou Garb and Grooming in the Workplace." 2014. www.eeoc.gov. Web. 22 March 2015.
Harris Polls. www.harrisinteractive.com. 16-23 January 2012. Web. 22 March 2015. <www.harrisinteractive.com/NewsRoom/HarrisPolls/tabid/447/mid/1508/articeld/970/ctl/ReadCustomDefault/Default.aspx>.
Kramer, Ronald J. “Recent Developments in Government Operations And Liability Generation Y: Tattoos, Piercing, And Other Issues For The Private And Public Employer.” Urban Lawyer 38.3 (2006): 593-611. Academic Search Complete. Web. 21 March. 2015
Lee Hartwell v. The City of Montgomery, Alabama, Personnel Board of the City and County of Montgomery, Alabama, and District Chief Kelly D. Gordon, in his individual capacity. No. 2:06cv518-MHT. United States District Court, M.D. Alabama, Northern Division. 10 May 2007. Web. 28 January 2015.
Support Tattoos And Piercings At Work. www.stapaw.com/#!tattoo-in-the-worklace-statistics/c1490. March 2015. Web. 21 March
2015.