Jean Denny Seandria Denny v. Elizabeth Arden Salons, Incorporated

WILKINSON, Circuit Judge:

In this case an African American woman bought her mother a gift package from a beauty salon and day spa. Upon visiting the salon to check on her mother and to add a hair coloring to the package, a receptionist told her that there was “a problem” because the salon did not “do black people’s hair.” The mother and daughter brought this suit against the salon under Title II of the Civil Rights Act of 1964, 42 U.S.C. § 2000a et seq. (2000), which prohibits racial discrimination in a “place of public accommodation,” and under 42 U.S.C. § 1981, which disallows such…