7th Circuit: Rastafarian Failed To Inform Potential Employer That Dreadlocks Were Religious Requirement

In Xodus v. Wackenhut Corp., (7th Cir., Aug. 27, 2010), the 7th Circuit affirmed a trial court's holding that Wackenhut Corp. did not violate Title VII of the 1964 Civil Rights Act when it refused to hire plaintiff, a Rastafarian, as a security guard because plaintiff refused to cut his dreadlocks. The Court affirmed the trial court's finding that plaintiff (whose name is Lord Osunfarian Xodus) failed to bring his religious beliefs to Wackenhut's attention. The Wackenhut manager, Clarence McCuller, who interviewed Xodus testified that when he told plaintiff about the company's grooming policy, plaintiff said that cutting his dreadlocks is "against my belief."  But McCuller testified that he was not aware of the Rastafarian religion and did not equate the use of the term "belief" with "religion." The Court wrote:

Xodus claims that his use of the word "belief" and the dreadlocks themselves sufficed to notify McCuller of the religious nature of his hairstyle. But unlike race or sex, a person’s religion is not always readily apparent.... "[E]mployers are not charged with detailed knowledge of the beliefs and observances associated with particular sects." ....  Nor does the fact that Xodus' name begins with the word "Lord" persuade us that McCuller knew the dreadlocks were religious.

Courthouse News Service reports on the decision.