In May 2010, Chastity Jones sought employment as a customer service representative at Catastrophe Management Solutions (“CMS”), a claims processing company located in Mobile, Alabama. When asked for an inperson interview, Jones, a Black woman, arrived in a suit and her hair in “short dreadlocks,” or locs, a type of natural hairstyle common in the Black community. Despite being qualified for the position, Jones would later have her offer rescinded because of her hair. CMS claimed that locs “tend to get messy” and violated the “neutral” dress code and hair policy requiring employees to be “professional and business-like.” Therefore, CMS refused to hire Ms. Jones unless she cut her locs off. When Jones sought redress in court because she was not hired based on the employer’s racial bias of Black hair, the Eleventh Circuit denied that CMS committed any form of proscribed discrimination because discrimination based on a mutable racial characteristic is not protected under Title VII.