Federal Judge Tosses Suit Accusing Title Company of Age Discrimination

July 5, 2012

In a June 6 ruling, a federal judge dismissed a case alleging a title company in Texas fired a woman because she refused to dye her hair. In the U.S. District Court Southern District of Texas Houston Division, Judge Gray H. Miller approved Capital Title of Texas’ motion for summary judgment and threw out Sandra Rawline’s lawsuit alleging age discrimination. “The court finds absolutely no evidence that Rawline’s age was a motivating factor for her discharge,” Miller wrote in this ruling. “Any reference to Rawline’s hair color occurs only in the context of her overall disheveled appearance and offers no support for Rawline’s allegation that Capital Title intentionally discriminated against her because of her age.” Rawline served as branch manager for the title company for nearly six years from Oct. 7, 2003 until Aug. 18, 2009, when she was terminated. According to court documents, Rawline’s customers complained about her rudeness, tardiness, temper and use of “choice words” in their dealings with her. On Aug. 13, 2009, her supervisor had warned her about her lack of professionalism and once suggested she try “wearing clothes that are more appropriate for the workplace and maybe such as getting her hair trimmed and dyed,” the ruling said. A day after this conversation, Rawline came into work late, smelled like alcohol, wore inappropriate clothing and allegedly refused to close a transaction scheduled for that day. Rawline was terminated for refusing to conduct the closing, according to the lawsuit. After filing a complaint with the U.S. Equal Employment Opportunity Commission and obtaining a right to sue letter, Rawline filed her original complaint against Capital Title of Texas on June 23, 2011, alleging age discrimination due to her refusal to dye her hair gray and because she was allegedly replaced by a younger woman. Capital Title of Texas filed a counterclaim on Feb. 15, 2012, alleging defamation and business disparagement. The next day, the title company filed its motion for summary judgment, claiming Rawline was terminated for good cause. Ruling in favor of Capital Title of Texas, the judge said that Rawline’s “statement that she was discharged because of her age was false.”

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