Article Critique Assignment II February 23rd, 2018 Studen.docx

Article Critique: Assignment II
February 23rd, 2018
Student
Experiences of wake and light therapy in patients with
depression: A qualitative study.
International Journal of Mental Health Nursing
Kragh, M., Møller, D. N., Wihlborg, C. S., Martiny, K., Larsen,
E. R., Videbech, P., &
Lindhardt, T. (2017). Experiences of wake and light therapy in
patients with depression: A
qualitative study. International Journal Of Mental Health
Nursing, 26(2), 170-180.
Summary
Researcher’s for this study designed a qualitative methodology
approach. (Kragh et al.
2017) Thirteen participants diagnosed with moderate-to-severe
depression were used. Individual
interviews were done by a nurse who was previously known to
the patients. This particular nurse
happened to be the first author. Participants were asked to keep
up with a diary, which the first
author would read and use as notes to prompt individuals for
more discussion later. Interviews
would primary be done at the end of a 9-week period. These 17
individual interviews were
conducted in a familiar place to the participants. A guide was

devised to propose interview
questions. Open and closed ended questions were used. Data
was then recorded. (Kragh et al.
2017)
The data was collected and analyzed. (Figure 1) Several other
researchers worked with
the first author in this study by analyzing the data. The other
researcher’s challenged the first
author’s interpretation of the data. Together, the authors came
up with an interpretation.
Qualitative content analysis was used to evaluate the data.
(Kragh et al. 2017) The study
concluded that in general the participants benefited from the
therapies. One main theme was
identified, and that was that participants had an overall positive
encounter with the therapy and
intervention. (Kragh et al. 2017) Four sub themes were
identified as well, which related to this
positivism, however also reflected certain negative aspects.
(Figure 2)
Critique
Depression is a major issue that many people are dealing with
today. Depression is the
world’s leading disability. (Kragh et al. 2017) While this may
seem debilitating, there are many
treatments to help those with this illness. Wake therapy is a
sleeping treatment where patients are
kept awake for a whole night and then the following day as
well. Wake therapy is one of those
treatments that has been proven to reduce symptoms in a matter
of hours. Wake therapy tends to
be paired with chronotherapeutic interventions which helps

prevent depressive symptoms from
returning. (Kragh et al. 2017) This article discusses a
qualitative study done over wake therapy
paired with the specific chronotherapeutic intervention, light
therapy. This study is interesting to
me as an interior design major, because behavioral healthcare
design is becoming more and more
popular. This is most likely an effect of the increased research
that has been provided over these
subjects.
Since depression is seemingly becoming a bigger and bigger
issue, it must be taken into
account more. As an interior designer, I must always keep the
user in mind. Those who will be
using the space that I create for them will be affected by
whatever environment I design. I must
put myself in the shoes of those who I will be designing for. As
someone who has a mental
health condition themselves, this is an issue that is easy to
empathize with. Empathic design is
something I am very interested in, so this information could be
significant research information
keep in mind for my future designs.
The authors of this research study created a clear and definitive
need for this study. They
clearly defined what depression is, and how many people it
affects. The authors then provided
examples of statistics on depression. This build-up lead into a
detailed explanation of what wake
therapy and light therapy interventions is. The author’s also
described the research that is out
today on such topics. They critiqued the studies that have
already been done, and explained what

they wanted to achieve. The authors were clear and to the point.
The author’s also made sure to control for a wide range of
variables, which helped
upstand the validity of this study. Depression has many
uncontrollable variables, yet many
methods were used to help prevent a bias with those
uncontrollable variables. The authors were
very picky with who they chose as participants. They did not
allow those who had “severe
suicidal ideation, panic anxiety and personality disorder, drug
or alcohol abuse, psychotic
disorder, pregnancy, glaucoma, epilepsy, and electroconvulsive
therapy” to participate. (Kragh et
al. 2017) In addition, the author’s made sure to be as inclusive
as they could. They made sure
that even though they had patients who had a depressive order
as a part of a bipolar disorder,
their “high” moods were adjusted for with mood-stabilizing
therapy. (Kragh et al. 2017) The
authors thoroughness helps justify their study.
While this study was very thorough, a key part could be
portrayed as prejudiced. Since
the participants knew the main interviewer previously, there is
potential for those responses to
have been swayed for many reasons. Allowing the study to be
done by someone familiar was
meant to help participants open up, however, it could have also
made participants do the
complete opposite. The first author was a nurse of the hospital
ward chosen, so how participants
felt about that first author previously, could have affected their
responses. The first author could
have also had a bias in what they documented in relation to
their own preconceptions.

If I were to continue this study, I would do several things
differently to assist in
guaranteeing validity of the study. I would choose a site that is
impartial to me. This way my
results will not be seen as biased. To ensure that this study has
a distinct focus I would consider
more variables. I would not include patients with bipolar
disorder. I would also restrict the age
gap to be smaller, or to include several smaller studies with
specific age groups. I would also
consider using people who have had a shorter history of
depression. A major theme that was seen
was that the patients were nervous about this recovery option. If
that fear could be eliminated or
reduced, different results may have been reflected. Continuing
this study would be interesting to
me because I want to find out more specific information on how
these concepts can be included
in interior environments; questions related to the interior’s
elements would be used to conduct
my research.
Figures
Figure 1. Data collected and analyzed by this study. This table
provides background information
on participants and their emotional state. Kragh, M., Møller, D.
N., Wihlborg, C. S., Martiny, K.,
Larsen, E. R., Videbech, P., & Lindhardt, T. Experiences of
wake and light therapy in patients
with depression: A qualitative study. International Journal of
Mental Health Nursing, 2017. p.

172.
Figure 2. This picture shows the four sub-themes identified by
this study under the main theme.
Kragh, M., Møller, D. N., Wihlborg, C. S., Martiny, K., Larsen,
E. R., Videbech, P., &
Lindhardt, T. Experiences of wake and light therapy in patients
with depression: A qualitative
study. International Journal of Mental Health Nursing, 2017. p.
174.
case 1 chapter seven Garcia Vs Spun Steak
case 1 chapter 8 Wedow v. City of Kansas City, Missouri
case 2 chapter 11 Chalmers v. Tulon Company of Richmond
Please use this cases for the project
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Gender Discrimination
Source: National Archives and Records Administration
(NWDNS-44-PA-911)
Learning Objectives
When you finish this chapter, you should be able to:
1. LO1Recite Title VII and other laws relating to gender
discrimination.
2. LO2Understand the background of gender discrimination and
how we know it still exists.
3. LO3List the different ways in which gender discrimination is
manifested in the workplace.
4. LO4Analyze a situation and determine if there are gender
issues that may result in employer liability.
5. LO5Define fetal protection policies, gender-plus
discrimination, workplace lactation issues, and gender-
based logistical concerns.
6. LO6Differentiate between legal and illegal grooming
policies.
7. LO7List common gender realities at odds with common bases
for illegal workplace determinations.

8. LO8Distinguish between equal pay and comparable worth and
discuss proposed legislation.
page 371
Opening Scenarios
SCENARIO 1
A discount department store has a policy requiring that all male
clerks be attired in coats and ties and all
female clerks wear over their clothing a short loose top
provided by the store, with the store’s logo on the front.
A female clerk complains to her supervisor that making her
wear the garment is illegal gender discrimination. Is
it? Why or why not?
SCENARIO 2
A male applies for a position as a server for a restaurant in his
hometown. The restaurant is part of a well-
known regional chain named for an animal whose name is a
colloquial term for a popular part of the female
anatomy. Despite several years of experience as a server for
comparable establishments, the male is turned
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down for the position, which remains vacant. The applicant is
instead offered a position as a kitchen helper. The
applicant notices that all servers are female and most are
blonde. All servers are required to wear very tight and
very short shorts, with T-shirts with the restaurant logo on the
front, tied in a knot below their, usually ample,
breasts. All kitchen help and cooks are male. The applicant
feels he has been unlawfully discriminated against
because he is a male. Do you agree? Why or why not?
SCENARIO 3
An applicant for a position of secretary informs the employer
that she is pregnant. The employer accepts
her application but never seriously considers her for the
position because she is pregnant. Is this employment
discrimination?
Statutory Basis
LO1
It shall be an unlawful employment practice for an employer—
(1) to fail or refuse to hire or to discharge any individual, or

otherwise to discriminate against any
individual with respect to his compensation, terms, conditions,
or privileges of employment, because
of such individual’s . . . sex [gender] . . . [Title VII of the Civil
Rights Act of 1964, as amended. 42
U.S.C. § 2000e-2 (a).]
(1) No employer . . . shall discriminate between employees on
the basis of sex by paying wages to
employees . . . at a rate less than the rate at which he pays
wages to employees of the opposite sex
. . . for equal work on jobs the performance of which requires
equal skill, effort, and responsibility,
and which are performed under similar working conditions,
except where such payment is made
pursuant to (i) a seniority system; (ii) a merit system; (iii) a
system which measures earnings by
quantity or quality of production; or (iv) a differential based on
any other factor other than sex. . . .
[Equal Pay Act, 29 U.S.C.A. § 206(d).]
(k) The term “because of sex” or “on the basis of sex” includes,
but is not limited to, because of or
on the basis of pregnancy, childbirth, or related medical
conditions; and women affected by
pregnancy, childbirth, or related medical conditions shall be
treated the same for all employment-
related purposes, including receipt of benefits under fringe
benefit programs, as other persons not
so affected but similar in their ability or inability to work. . . .
[Pregnancy Discrimination Act, 42
U.S.C. § 2000e.]
Note: Reread the Preface regarding the use of gender
terminology before reading this chapter.

Does It Really Exist?
LO2
What does a group of 25 attorney-mediators have to do with a
swimsuit calendar? Good question.
The Miami-based Florida Mediation Group has probably been
asking itself that same question
ever since it received a good deal of flack for having its name
emblazoned across one of several
themed calendars given away as gifts to clients.
Of all the bases for employment discrimination we cover in
class and in consulting, gender
seems to be the one that is most difficult for students to believe
exists. This, despite the fact that
a 2010 Harris Poll of 2,227 adults surveyed online found that 7
in 10 Americans say women often
do not receive the same pay as men for doing exactly the same
job, 63 percent agreed the United
States still has a long way to go to reach complete gender
equality, and 74 percent believe there
are more pressing issues to fix first.1 As Stuart J. Ishimaru,
then-acting chairman of the EEOC
stated: “Sex discrimination against males and females alike
continues to be a problem in the 21st
century workplace.”2
In fact, as recently as January 2014, in his State of the Union
address, dismissing policies and
stereotypes that prevent women and men from getting the same
opportunities and salaries in the

workplace, President Obama said
Today, women make up about half our workforce. But they still
make 77 cents for every dollar a man
earns. That is wrong, and in 2014, it’s an embarrassment. A
woman deserves equal pay for equal
work. She deserves to have a baby without sacrificing her job.
A mother deserves a day off to care
for a sick child or sick parent without running into hardship—
and you know what, a father does, too.
It’s time to do away with workplace policies that belong in a
“Mad Men” episode. This year, let’s all
come together—Congress, the White House, and businesses
from Wall Street to Main Street—to
give every woman the opportunity she deserves. Because I
firmly believe when women succeed,
America succeeds.3
We understand that if you are not used to thinking that it exists,
sometimes it can be difficult to
recognize gender discrimination when it plays itself out in the
workplace. Gender is a part of our
everyday life and so much related to it is based on stereotypes,
customs, mores, and ideas that
we learn from birth. Gender discrimination comes in so many
different forms. That is why in this
chapter we will provide many different manifestations of gender
discrimination for you to examine
so you can gain exposure. As a manager, supervisor, or business
owner, we want you to be able
to analyze fact situations in the workplace as they occur in
order to determine if there is potential
liability.
Suppose a woman is required by her employer to wear two-inch
heels to work. Doing so causes

her to develop bunions, which can only be removed by surgery.
After surgery she is ordered by
her doctor to wear flat shoes for two months. Her employer
refuses to permit her to do so. Left
with no alternative, she quits. The employer imposes no such
requirement on male employees.
When you realize that the employer’s two-inch-heels policy cost
the woman her job and that had
she been male this would not have happened, it becomes more
obvious that the policy is
discriminatory on the basis of gender.
page 373
Remember the wires of the bird cage in Exhibit 3.5. Those wires
are probably what the
members of the executive board of the Miami-Dade chapter of
the Florida Association of Women
Lawyers were thinking of when they registered their objection
to the calendar. “We believe this
type of advertising, whether picturing men or women, does not
promote dignity in the law and is
inappropriate when circulated by an organization that serves the
legal community.”4
Perhaps you got some sense of how widespread the issues are
and how frustrating they can
be for those who operate under them when, on January 21, 2017,
you watched (or participated)
as hundreds of thousands of men and women around the globe
marched and demonstrated
because of their anger over what they viewed as the incoming
administration’s refusal to even
acknowledge their concerns about gender discrimination. Or
perhaps you watched on March 8,
2017, International Women’s Day, as again, people

demonstrated around the world the need to
address these pressing issues.
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One of the takeaways from the demonstrations and the wide-
ranging issues involved is how
many issues gender discrimination and disparities touch and
how ingrained they are. It is not
difficult to discriminate on the basis of gender if an employer is
not sensitive to the issues involved.
(See Exhibit 8.1, “Gender-Neutral Language?”) Once again, as
with race discrimination, vigilance
pays off. This chapter will address workplace gender
discrimination in general, including
pregnancy discrimination, lactation policies, fetal protection
policies, and equal pay. Sexual
harassment, sexual orientation, and gender identity
discrimination are three other types of gender
discrimination and will be considered in subsequent chapters.
Gender discrimination covers both
males and females, but because of the unique nature of the
history of gender in this country, it is
females who tend to feel the effects of gender discrimination in
the workplace more so than men,
and the vast majority of EEOC gender claims are filed by

women. Interestingly, however, during
the 2008–2009 economic recession, more men than women lost
their jobs,5 with 78 percent of
the jobs lost in the recession held by males.6 The reason given
page 374is that the jobs women
hold tend to be more stable, but lower paying, and the male-
dominated sectors such as
construction, investment banking, and manufacturing tended to
be hardest hit.7 However, by
March of 2011, the Bureau of Labor Statistics reported that 90
percent of the jobs gained in the
recovery had gone to men.8 By May 2012, three years after the
recovery began, women had
gained only 16 percent of the new jobs created and the
workforce participation rate of women
aged 45 to 54 had “dropped like a stone,” with married women
increasingly choosing not to work
because the low-paying jobs they could get in areas like
temporary help, health, leisure and
hospitality, or private education simply are not worth the cost
of daycare, commuting, and so on.9
Exhibit 8.1 Gender-Neutral Language?
Attorney Harry McCall, arguing before the U.S. Supreme Court,
stated, “I would like to remind you gentlemen” of
a legal point. Associate Supreme Court Justice Sandra Day
O’Connor asked, “Would you like to remind me, too?”
McCall later referred to the Court as “Justice O’Connor and
gentlemen.” Associate Justice Byron White told
McCall, “Just “Justices’ would be fine.”*
***
According to the National Conference of State Legislatures,
nearly half of states have moved to make the

language in their official documents gender-neutral. Changes
include replacements such
as handwriting for penmanship, first-year student for freshman,
and outdoor enthusiast for sportsman. The state
of Washington finds it more difficult to replace airman,
manhole, and manlock.†
Source: Newsweek, November 25, 1991, p. 17.
† Time, 2/18/13, p. 12.
Women are the single largest group of beneficiaries under
affirmative action. They seem to be
gaining in all facets of life. The latest presidential cycle saw the
first female selected as the
presidential candidate of a major political party. Janet Yellen
heads the U.S. Federal Reserve,
putting the world’s largest economy in the hands of a woman.
Three of the nine slots on the U.S.
Supreme Court are held by women. Nancy Pelosi was the first
female speaker of the U.S. House
of Representatives. Admiral Michele Howard, the first African-
American 4-star general,
commander of a ship in the U.S. Navy, and vice chief of the
Navy, commands the Naval forces in
Europe and Africa, captaining the USS Porter patrolling the
international waters off the Black Sea,
keeping an eye on Russian movements. Women head
corporations and states, own businesses,
and are members of the president’s cabinet. When Marissa
Mayer became CEO of Yahoo, it
made headlines when she was chosen and pregnant. Facebook’s
chief operating officer, Sheryl
Sandberg, was lauded for revealing she left work at 5:30 each
day after becoming a parent.
Beyonce signs a $50 million endorsement deal with Pepsi.

Walmart announced women-friendly
plans aimed at helping women-owned businesses and workers.
Women can now serve in combat
and even the Navy now permits women to serve on
submarines.10
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Things seem OK. You think to yourself, who would be dumb
enough to discriminate against
women these days? It can be hard to believe that gender
discrimination still exists when you go
to school and work with so many people of both genders; you
don’t feel like you view gender as
an issue, and it just seems like everything is OK. However, the
2016 EEOC statistics indicate that
gender still accounts for nearly one-third, 29.4 percent, of
substantive claims brought under Title

VII.
At the same time we see these strides made in the gender
sphere, we must keep in mind that
only 21 women, 4.2 percent, headed up Fortune 500 companies
as of March 2017, and 2016 saw
the number decline more than 12 percent, from 24 the year
before.11
When women account for nearly half the workforce, those
numbers may appear to seem
skewed.12 See Exhibit 8.2 “Catalyst Showing Female CEOs in
Fortune 500 Companies from 1995
to 2013.” One factor in the way of females’ progress is that,
even when women are imminently
qualified, “male leaders tend to feel comfortable around other
males, so they tend to network with,
and promote, those of the same gender.”13 Also, “female
leaders are caught in a Catch 22. If they
adopt a page 375command-and-control orientation, they are
viewed as inappropriately masculine.
If they act skillfully at solving disputes and settling conflicts,
they are viewed as too feminine to be
strong, directive leaders.”14
Exhibit 8.2 Catalyst Showing Female CEOs in Fortune 500
Companies from 1995 to
2013
“The Myth of the Ideal Worker: Does Doing All the Right
Things Really Get Women Ahead?”,
a 2011 major study by renowned women’s policy research group
Catalyst, found that regardless

of their career strategy, men seem to be paid for potential, while
women seem to be paid for
proven performance, and across all careers, men were more
likely to reach senior executive
positions than women. Men outpace women in rate of
advancement and compensation growth
from their first post–MBA job and it widens to $31,258 by mid-
career.15 The Harvard Business
School class of 2013 underwent an experiment for their two
years of study in which some of these
issues were directly confronted and attempts made to reverse
them. They noted that while all
students admitted to the MBA program were similarly qualified,
by the time they graduated, among
other things, men had spoken in class more (where participation
could be up to 50 percent of the
grade), had higher grades, won more awards, and landed more
prestigious jobs. By instituting
new policies and procedures, a dramatic impact was made, but it
remains to be seen whether it
will carry over into the workplace.16
As a reality check, one of our female graduate students was told
by an employer that if she
was a man with her qualifications, he would pay her 50 percent
more. Another was told she had
a full-time job upon graduation in a company in which she had
experienced a very successful
internship, but only if she allowed the president of the company
to set her up in an apartment so
she could be available to him whenever he wished to have sex
with her. She declined and started
her job hunt all over again, not finding another job in her field
until five months after she graduated.
Gender discrimination is real and is not just something that
happens to other people. It is real and

must be addressed in the workplace. But, first you have to be
able to recognize it.
page 376
Even professionals can be caught off guard. In 1999, a gender-
discrimination charge that
started with eight female stockbrokers at Merrill Lynch alleging
various forms of gender inequality,
particularly economic discrimination, ballooned to 900 women
and was still growing. “It’s been a
flood. I’ve been stunned. We were expecting 200–300 claims,
but the calls are still coming in,”
said one of the lawyers representing the women. In 2004,
arbitrators determined that it was
standard operating procedure at Merrill Lynch to discriminate
against women. It was the first time
a Wall Street firm had been found to have engaged in systematic
gender discrimination. Merrill

Lynch spent more than $100 million settling close to 95 percent
of the 900 or so claims. In
subsequent press releases, the firm said this is not an accurate
picture of the firm today.
Unfortunately, that was only the beginning of Wall Street’s
gender-based litigation. Cases
continue to be brought by female employees against several
Wall Street firms for the same types
of discrimination that cost Merrill Lynch so much. In 2010
women filed EEOC claims against
Goldman Sachs investment bank, alleging systematic
discrimination against women including pay
and promotions.17 At least 58 women have joined in a 2009 suit
filed by the EEOC against
financial services and media company Bloomberg, founded by
former New York mayor Michael
Bloomberg, claiming pregnancy discrimination.18 Women at
Citigroup, Inc., filed a class action for
gender discrimination alleging they were laid off in the 2008
recession as part of the firm’s “glass
ceiling,” and lesser qualified or underperforming males were
retained.19 Morgan Stanley settled a
gender-bias class action suit for $46 million; Putnam
Investments was sued for its “ingrained
culture of chauvinism,” leading to demotions and firings based
on gender, a claim that has been
made against many, many companies since; Smith Barney was
sued for a pattern and practice
of gender discrimination against its female financial
consultants; and Wall Street bank Dresdner
Kleinwort Wasserstein Securities, LLC, was sued for $1.4
billion by female employees who
alleged they were hired as “eye candy,” subjected to Animal
House–like antics, passed over for
promotions, and generally treated like second-class citizens.

Clearly, Merrill Lynch’s $100 million message was not heard by
all. In fact, it was not even
heard by Merrill Lynch. In 2009 another group of women sued
Bank of America, which acquired
Merrill Lynch, alleging Bank of America had paid them
substantially lower bonuses than men
based on information from Merrill Lynch that BOA knew was
discriminatory.20 The next year, three
female financial advisors filed a class action lawsuit against
BOA Merrill Lynch alleging a pattern
and practice of gender discrimination in account distributions,
partnership opportunities, up-front
money, pay-out rate, other benefits in its compensation plan,
and opportunities for brokers to
increase their income.21 The case involving roughly 4,800
women who worked for Bank of
America and its subsidiary Merrill Lynch from 2007 onward
was settled for $39 million in
2013.22 However, similar charges were made in 2016 when a
senior female fixed-income banker
sued BOA for $6M, alleging she was paid less than half the
salary of similarly situated men there
and made to feel unwelcome in their “subordinate ‘bro club’ of
all-male syncophants.”23
page 377
But Wall Street is hardly alone. A $100 million class action
lawsuit filed by a female partner at
the law firm of Chadbourne & Parke alleged an “all-male
dictatorship.”24 In 2015, EEOC contacted
female directors in Hollywood to investigate gender
discrimination in the television and film
industry.25 Silicon Valley and the technology industry have
been having a rough time of it for the

past few years as well, with several high profile cases that have
resulted in ugly publicity even
when the companies end up winning the case. Venture capitalist
Ellen Pao created a sensation
in 2015 as the first woman to challenge the “boys club” in open
court rather than settle. She
alleged she was passed over for promotions, kept out of
meetings, barred from work trips, and
not invited to important Kleiner Perkins events because “It was
said that if there were women
there, the conversation would be tempered and it was because
women kill the buzz.”26 Pao
eventually lost her lawsuit, but opened the door for other
women to challenge similar treatment in
other tech and other companies.
Recent cases have been filed for everything from a female
animal handler terminated for
refusing to expose her breasts to a 300-pound gorilla who had a
“nipple fetish”27; to a female

global transaction group director on track to become a managing
director who sued for being
terminated a month after she filed suit for gender discrimination
and sexual harassment alleging
she was Mommy-tracked after taking maternity leave28; to the
Clearwater, Florida, Fire & Rescue
chief being charged by the EEOC with gender discrimination for
ordering the department’s six
female firefighters to stay away from structure fires amid
reported threats that their male
colleagues might not protect them29; to a man suing in
California because there is no convenient,
easy, comparable way for him to take his wife’s name when
they marry as it is for her to take
his.30
Add race to the gender mix and it gets even worse. Known as
intersectionality, 2015
University of California at Hastings research found that while
the overwhelming majority of women
in STEM (science, technology, engineering, and math) fields
experience sexism, women of color
are put in “double jeopardy with a full 100 percent of the
interviewees reporting gender bias,
compared to 93 percent of white women.”31 An American Bar
Association study on women of
color in law firms, commissioned after a National Association

for Law Placement study found that
100 percent of female minority lawyers left their jobs in law
firms within eight years of being hired,
44 percent of the women reported being passed over for
desirable assignments (compared to 2
percent for white men), 62 percent said they had been excluded
from formal and informal
networking opportunities (compared to 4 percent of white men),
and 49 percent reported being
subjected to demeaning comments or other types of harassment
at their firms.32
intersectionality
Experiencing more than one type of discrimination at a time,
e.g., that of being black and female.
Gender equality in the workplace is an ever-evolving area and
does not occur in a vacuum.
The issues in the workplace are only one part of a much larger
environment of different, often
unequal, treatment of individuals based on gender. Imagine the
swimsuit calendar having bikini-
clad males instead of females. Do you think it would have been
received the same way?
Manifestations of gender differences in society are the basis for
differences in treatment in the
workplace. They can be as diverse and far-flung as the group of
Massachusetts teens suing
the page 378Selective Service System, arguing it is an
unconstitutional violation of the Fifth and
Fourteenth Amendments’ Equal Protection Clause for females
not to be subject to the draft just
as men are, asserting that “if people want women’s rights, they
should want it wholeheartedly,
including for women to have to fight in wars,”33 to the protest
over General Nutrition Center (GNC)

dropping women from its GNC Show of Strength bodybuilding
competition and replacing it with
the International Federation of Body Builders (IFBB) Pro Figure
competition34; from males suing
bars for offering “Ladies’ Night” discounts to women because
such promotions discriminate
against men,35 to the Congressional House Oversight and
Government Reform Committee
expressing support for the 2010 Restroom Gender Parity in
Federal Building Act (H.R. 4869)36;
from Playboy magazine running an article titled “Ten
Conservative Women I’d Like to F—,”
to Right Wing News compiling a list of the “hottest
conservative women in the news media”37; from
Lawry’s restaurant chain not allowing men to be servers
because of a 1938 policy,38 to a female
construction flag worker feeling compelled to wear a diaper to
work because she was not allowed
to find a bathroom in time at remote sites39; from female police
officers being called “overtime
whores,”40 to an athletic club charging men more than
women41; from female playwrights in New
York complaining at a standing-room-only town hall meeting
with producers that men’s plays in
the 2008–2009 season were produced at four times the rate
theirs were,42 to Club Med’s “Ladies
Fly Free” …
Chapter 7
National Origin Discrimination
©yesfoto/Getty Images RF

Learning Objectives
By the time you finish studying this chapter, you should be able
to:
1. LO1Describe the impact and implications of the changing
demographics of the American workforce.
2. LO2Define the prima facie case for national origin
discrimination under Title VII.
3. LO3Explain the legal status surrounding “English-only
policies” in the workplace.
4. LO4Describe a claim for harassment based on national origin
and discuss how it might be different from
one based on other protected classes.
5. LO5Identify the difference between citizenship and national
origin.
6. LO6Explain the extent of protection under the Immigration
Reform and Control Act.
page 324
Opening Scenarios
SCENARIO 1
Kayla, a supervisor, recently hired a new manager, Alex, but
has received complaints from customers that
they cannot understand him when they speak to him on the
telephone. Alex is a Romanian employee visiting

from the company’s Romanian office and is scheduled to remain
with the firm for two years. Kayla is concerned
that if she allows Alex to perform duties similar to other
managers, the firm will lose customers; however, she is
unsure about the firm’s liability for decreasing Alex’s
responsibilities as a result of his foreign accent.
SCENARIO 2
Mohammed, an Arab-American Muslim high school student, had
a job after school at a fast-food restaurant.
A few co-workers started asking him why his “cousins” bombed
the World Trade Center. Mohammed ignored
their taunts. Then a manager began to add comments such as
“Hey, Mohammed, we’re going to have to check
you for bombs.” Mohammed felt humiliated and angry. Soon
after, he was terminated for accidentally throwing
away a paper cup that the manager was using. Mohammed
suspects that his religious and ethnic background
was the reason he was fired.
Statutory Basis

The statutory basis for protection against national origin
discrimination is presented in Exhibit 7.1,
“Legislation Prohibiting National Origin Discrimination.” These
statutes include section 703(a) of
Title VII of the Civil Rights Act of 1964 and the Immigration
Reform and Control Act of 1986.
Additional direction can be found in the EEOC’s Enforcement
Guidance on National Origin
Discrimination.
Exhibit 7.1 Legislation Prohibiting National Origin
Discrimination
TITLE VII, CIVIL RIGHTS ACT OF 1964
Sec. 703(a)
It shall be an unlawful employment practice for an employer—
1. to fail or to refuse to hire or to discharge any individual, or
otherwise to discriminate against any individual with respect
to his compensation, terms, conditions, or privileges of
employment, because of such individual’s . . . national origin.
IMMIGRATION REFORM AND CONTROL ACT OF 1986
Sec. 274A(a)
1. It is unlawful for a person or other entity:
A. to hire or to recruit or refer for a fee for employment in the
United States an alien knowing the alien is an
unauthorized alien with respect to such employment, or
B. to hire for employment in the United States an individual
without [verification of employment eligibility].

2. It is unlawful for a person or other entity, after hiring an
alien for employment in accordance with paragraph (1), to
continue to employ the alien in the United States knowing the
alien is (or had become) an unauthorized alien with
respect to such employment.
3. A person or entity that establishes that it has complied in
good faith with the [verification of employment eligibility]
with respect to hiring, recruiting or referral for employment of
an alien in the United States has established an
affirmative defense that the person or entity has not violated
paragraph (1)(A).
Sec. 274(B)(a)
1. It is an unfair immigration-related practice for a person or
other entity to discriminate against any individual (other
than an unauthorized alien) with respect to the hiring, or
recruitment or referral for a fee, of the individual for
employment or the discharging of the individual from
employment—
A. because of such individual’s national origin, or
B. in the case of a protected individual [a citizen or authorized
alien], because of such individual’s citizenship status.
Chez/Casa/Fala/Wunderbar Uncle Sam
The United States of America has always considered itself to be

a melting pot. Under this theory,
different ethnic, cultural, and racial groups came together in the
United States, but differences
were melted into one homogeneous mass composed of all
cultures. Recently, this
characterization has been revisited and other, more accurate
terms have been proposed. They
include such terms as a salad bowl, in which all the ingredients
come together to make an
appetizing, nutritious whole but each ingredient maintains its
own identity, or a stew, in which the
ingredients are blended together but maintain their distinct
identity, with the common thread of
living in America acting as the stew base that binds the
ingredients together.
While the words on the Statue of Liberty—“Give me your tired,
your poor, your huddled masses
yearning to breathe free”—have always acted as a beacon to
citizens of other countries to find
solace on our shores, the reality once they get here, even
sometimes after being here for
generations, is that they are often discriminated against, rather
than consoled. National origin was
included in Title VII’s list of protected classes to ensure that
employers did not make employment
decisions based on preconceived notions about employees’ or
applicants’ country of origin. Note
that section 1981 of the Civil Rights Act of 1866, as amended
by the Civil Rights Act of 1991, also
may apply in those circumstances where national origin is a
proxy for or equivalent to race
(discussed later in this chapter).1
page 325Speaking of race, as was mentioned in the introduction
to the chapter on race

discrimination, recently there has been a sort of blending of the
race and national origin
categories, with employees bringing as race discrimination
cases those that had traditionally been
brought as national origin claims. The traditional distinctions in
the law are becoming blurred; but
the significant thing is that, for instance, whether being Latin is
considered race discrimination or
national origin discrimination, it is, in fact, illegal to make
workplace decisions on the basis of this
attribute. What is critical to understand is that a decision based
on either attribute is illegal; and
national origin is a distinct category in this textbook because it
is the way that such claims are
traditionally handled, and because we are reluctant to blend
completely the two areas when they
have quite different histories, implications, and analyses for
today’s employment arena.
The Changing Workforce
LO1
Over the past decade, we have seen a dramatic increase in the
number of immigrants to the
United States, particularly from Latin American and Asian
countries. In 2014 page 326alone, the
United States was home to a record 42.2 million immigrants
who, by 2016, comprised over 13.2
percent of the nation’s population. This number represents a
fourfold increase since 1960, when
there were 9.7 million immigrants living in the country. At that
time, immigrants made up only 5.4
percent of the U.S. population. The growth rate is expected to

continue and the number of
immigrants in the United States is expected to double by 2065.2
By 2016, the United States was
growing by one person every 8 seconds, and gaining one
international migrant every 29 seconds.3
In 1960, 84 percent of immigrants living in the United States
were born in Europe or Canada.
Since the passage of the 1965 Immigration and Naturalization
Act, this demographic has changed
dramatically. As of 2014, European and Canadian immigrants
made up only 13.6 percent of U.S.
immigrants. Mexicans made up the largest share—27.7
percent—while Asian immigrants
comprised 26.4 percent of U.S. immigrants. Immigrants from
Latin America comprised 23.9
percent and 8.3 percent of immigrants were born in other
regions.4 In 2015, there were 26.3
million foreign-born workers in the United States, comprising
16.7 percent of the total labor force.
Latinx5 accounted for 48.8 percent of the foreign-born labor
force, with Asians comprising a further
24.1 percent.6
From 2014 to 2015, unemployment rates for foreign-born

workers declined by 0.7 percent,
while dropping 0.9 percent for U.S.-born workers. In 2014, the
jobless rate among U.S.-born men
(5.6 percent) was higher than that for foreign-born men (4.5
percent). Despite having a slight edge
in employment, the median weekly earnings of foreign-born,
full-time workers were significantly
lower than their U.S.-born counterparts: $681 compared with
$837 (among women, a difference
of $626 to $740 and among men, a difference of $712 versus
$934). However, the earnings gap
narrows with higher levels of education: among those with a
bachelors degree or higher, earnings
were essentially identical.7
On its face, national origin discrimination appears to be
relatively simple to determine; however,
it has surprising complexities. Employers have always been
uncertain of the scope of Title VII’s
coverage in this area and what could be used as a defense
against decisions based on national
origin. (See Exhibit 7.2, “Realities about National Origin
Discrimination.”) Notwithstanding its
complexity, however, complaints to the EEOC based on alleged
national origin discrimination
have been on the rise since 1997. Between 1997 and 2015,
complaints of discrimination on the
basis of national origin grew from page 3276,712 to 9,438,
though the number of national origin
complaints being filed has declined a bit from its peak in 2011,
when it was 11,833.8 The link
between these two forms of complaint, particularly as they
pertain to Muslim and Arab-Americans
after the attacks of September 11, 2001, is discussed later in the
chapter.

Exhibit 7.2 Realities about National Origin Discrimination
1. “Citizenship” and “national origin” are not syn-onymous.
2. No matter the national origin of a restaurant, it likely will
still be required strictly to abide by Title VII non-
discrimination
principles in hiring its waitstaff.
3. The EEOC considers English-only rules applied at all times
presumptively discriminatory, although courts have not
always agreed.
Regulatory Overview
LO2
The national origin discrimination protection offered by Title
VII is similar to that of gender or
race and is used somewhat synonymously with ethnicity, though
they are distinguishable. That
is, it is an unlawful employment practice for an employer to
limit, segregate, or classify employees
in any way that would deprive them of employment
opportunities because of national origin. An
employer may not group its employees on the basis of national
origin, make employment
decisions on that basis, or implement policies or programs that,
though they appear not to be
based on an employee’s or applicant’s country of origin,
actually affect those of one national origin
differently than those of a different group.
national origin discrimination protection
It is unlawful for an employer to limit, segregate, or classify
employees in any way on the basis of national

origin that would deprive them of the privileges, benefits, or
opportunities of employment.
An employee may successfully claim discrimination on the basis
of national origin if it is shown
that
1. She or he is a member of a protected class (i.e., articulate the
employee’s national origin).
2. She or he was qualified for the position for which she or he
applied or in which she or he was
employed.
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PS/chapter07.xhtml?favre=brett#rch07_key1
3. The employer made an employment decision against this
employee or applicant.
4. The position was filled by someone who was not a member of
the protected class.

Each of the above will be discussed in turn.
Member of the Protected Class
In connection with the first requirement, what is meant by
national origin? While the term is not
defined in Title VII, the EEOC guidelines on discrimination
define national origin discrimination
as “including, but not limited to, the denial of equal
employment opportunity because of [an
applicant’s or employee’s] or his or her ancestor’s place of
origin; or because an applicant has
the physical, cultural, or linguistic characteristics of a national
origin group.”
national origin
Individual’s, or her or his ancestor’s, place of origin (as
opposed to citizenship), or physical, cultural, or
linguistic characteristics of an origin group.
Note that the law provides protection against discrimination
based only on country of origin, not
on country of citizenship.9 Title VII protects employees who
are not U.S. citizens from employment
discrimination based on the categories of the Act, but it does
not protect them from discrimination
based on their status as immigrants, rather than as U.S. citizens.
That is, it protects a Somali
woman from gender discrimination, but not from discrimination
on the basis of the fact that she is
a Somali citizen, rather than an American citizen. The issue of
citizenship as it relates to national
origin is discussed later in this chapter.
page 328Many national origin cases under Title VII involve
claims of discrimination by those
who were not born in America; however, American-born

employees also are protected against
discrimination on the basis of their American origin. For
example, a court has held that the
employer’s conscious decision about whom to dismiss on the
basis of the national origin of its
employees (in an effort to promote “affirmative action”) was
not acceptable because that method
tended to disfavor Americans, in favor of other nationalities.
In addition to national origin encompassing the employee’s
place of birth, it also includes ethnic
characteristics or origins, as well as physical, linguistic, or
cultural traits closely associated with a
national origin group. For instance, courts have held that Cajuns
and people of Romani descent
(sometimes referred to by the more derogatory term, “gypsy”10)
are protected under Title VII.11 In
addition, the EEOC confirms that other ethnic groups, such as
Latinx, Arabs, and Kurds, are also
protected national origin groups.12 It also may serve as the
basis for a national origin
discrimination claim if the employee
• Is identified with or connected to a person of a specific
national origin, such as when someone suffers
discrimination because he or she is married to a person of a
certain ethnic heritage.
• Is a member of an organization that is identified with a
national group.
• Is a participant in a school or religious organization that is
affiliated with a national origin group.
• Has a surname that is generally associated with a national
origin group.

• Is perceived by an employer to be a member of a particular
national origin group, whether or not the
individual is in fact of that origin.
Qualification/BFOQs
The second factor that must be present for an employee to claim
national origin discrimination is
that the applicant or employee is qualified for the position. That
is, the claimant must show that
he or she meets the job’s requirements.
Contrary to situations involving disability or religion, the
employee in a national origin case must
show that she or he is qualified for the position without the
benefit of accommodation. No
PS/chapter07.xhtml?favre=brett#ch07_key2
PS/chapter07.xhtml?favre=brett#rch07_key2
accommodation of one’s national origin is required of
employers. For example, while an employer
would be required to reasonably accommodate an employee’s
religious attire, there is no similar
responsibility to accommodate an employee’s attire of national

origin, such as traditional African
dress, unless it can be shown to overlap with his or her religion.
The employer may counter the employee’s claim that she or he
is otherwise qualified by
showing that national origin is actually a bona fide occupational
qualification (BFOQ) (discussed
in Chapter 3) for the job. In other words, the employer can
explain why a specific national origin
is necessary for the position applied for—why that national
origin is a legitimate job requirement
and is reasonably necessary for the employer’s particular
business.
page 329
It is important to note that customer, client, or co-worker
discomfort or preference in terms of
national origin may not be relied upon by the employer. But, as
you’ll see in the Espinoza v. Farah
Mfg. Co. case at the end of the chapter, citizenship is an
entirely different story.
English Fluency and Speaking Other Languages in the
Workplace
LO3
Some employers choose to maintain policies requiring all
employees either to be fluent in English
or to speak only English while in the workplace, even when

employees are speaking only among
themselves. Employers have also raised the question of what to
do if an employee’s accent
interferes with his or her job performance. Fluency
requirements, “English-only” policies, and
accent rules all raise slightly different issues, but all are
becoming increasingly relevant in today’s
diverse workforce. In 2014, 20.9 percent of the U.S. population
five years and older spoke a
language other than English in the home. Over 25 million
Americans, or nearly 9 percent of the
U.S. population aged five and over, spoke English less than
“very well.”13
Diversity in the workplace brings many benefits, including a
greater breadth of skills and life
experiences among the workforce. It also may present unique
challenges to employers,
particularly in the form of poor communication among those
who may prefer to speak in their
native tongue, which might be not English but Spanish, Hindi,
or Tagalog. While such
communication problems may cause confusion, fluency
requirements may not be appropriate for
some jobs, even within the same company, and severe English-
only restrictions may create
frustration and resentment among employees for whom English
is a second language. To avoid
alienating these employees, to ensure realistic and reasonable
job qualifications, and to decrease
the risk of litigation, employers should not permit managers to
arbitrarily impose language
restrictions.14
A job requirement that an employee must be fluent in English is
legal if fluency is required to

perform the work effectively. The EEOC has pointed out that
the degree of fluency required varies
from job to job, so blanket fluency requirements that apply
equally to the customer service
department and to warehouse workers might not be legal. To
best be protected from possible
Title VII liability, the employer must be able to show that
English fluency is required for the job
and that the requirement is necessary to maintain supervisory
control of the workplace. Perhaps
it may be required of an employee who has significant
communication with clients, or it may be
PS/chapter03.xhtml
justified as a BFOQ where the employee could not speak or
understand English sufficiently to
perform required duties.
Similarly, because an employee’s accent is often associated
with his or her national origin,
courts closely examine employment decisions based on accent
(since it may be used as a proxy
for national origin discrimination). However, an employer is
permitted to choose not to hire or
promote an employee to a position that requires clear oral
communication in English if the
employee’s accent substantially affects his or her ability to
communicate clearly. For example,
where a teacher was fluent in English but spoke with such a

thick accent that her students had a
difficult time understanding her, her discharge was upheld. On
the page 330other hand, if the
employee is in a job requiring little speaking and the employee
can understand English, the
requirement may be more difficult to defend—for instance,
requiring English fluency for a janitor
who talks little, has little reason to speak to carry out the duties
of the job, and who understands
what is said to him or her. In fact, in In re Rodriguez,15 the
court found that an employment
decision based on an employee’s accent and speech
characteristics (where due to the
employee’s national origin) was direct evidence of employment
discrimination sufficient to shift
the burden of proof to the employer to articulate a legitimate
non-discriminatory reason for the
decision that the employer “would have terminated the
[employee] had it not been motivated by
discrimination.” The court affirmed that “accent and national
origin are inextricably intertwined.”
Additionally, in Guimaraes v. SuperValu, Inc., the Court found
that even comments ridiculing
an employee’s accent could be relevant evidence of national
origin animus.16
Unlike the teacher above, in Scenario 1, Kayla is considering
decreasing Alex’s responsibilities
due to his foreign accent, rather than terminating him. However,
like the teacher, it is quite
possible in this scenario to show that speaking clear English is a
BFOQ, especially if it can be

shown that customers have been complaining that they cannot
understand him.
A closely related question is whether employers are permitted to
implement policies requiring
employees to speak only English in the workplace. These
policies may be based in well-
intentioned employer efforts aimed at decreasing workplace
tension where multiple languages
have segregated a workplace, improving employees’ English, or
promoting a safe and efficient
workplace. Though the U.S. Supreme Court has not yet ruled on
the lawfulness of English-only
policies in the workplace, lower courts have gone both ways on
this issue.17 Some have held the
policy to be discriminatory, excessively prohibitive, and a
violation of Title VII. Others have held
that it is not national origin discrimination if all employees,
regardless of ancestry, are prohibited
from speaking anything but English on the job and that there is
no statutory right to speak other
languages at work. It has been held that the right to speak one’s
native language when the
employee is bilingual is not an immutable characteristic that
Title VII protects.
Garcia v. Spun Steak Co., included at the end of the chapter, is
one of the most important
cases on the subject. In Garcia, the Ninth Circuit considered an
employer’s policy that required
bilingual workers to speak only English while on the job,
though it allowed other languages to be
spoken during breaks and employees’ personal time. Spanish-
speaking employees argued that
the policy was discriminatory because it denied them the ability
to express their cultural heritage,

denied them a privilege of employment enjoyed by speakers of
English as a first language, and
created an atmosphere of inferiority and intimidation. The court
rejected these arguments, stating
that Title VII “does not protect the ability of workers to express
their cultural heritage at the
workplace,” but is “concerned only with disparities in the
treatment of workers.” The court further
argued that “Title VII is not meant to protect against rules that
merely inconvenience some
employees, even if the inconvenience falls regularly on a
protected class.”
page 331In contrast, in EEOC v. Premier Operator Servs.,
Inc.,18 the district court struck down
an English-only policy that required all conversations on
workplace premises, including those
during breaks or personal time, to be in English. The court
found that the defendant presented
insufficient evidence to establish that there was any business
necessity for the policy as
implemented. The court noted that, even if it were “to assume
that office ‘harmony’ [was] properly
considered to be a business necessity that would justify an

English-only policy,” there was no
credible evidence on the record that there was any discord
among employees so as to necessitate
a language-restrictive policy. The court therefore concluded that
“the speak English-only policy
as implemented and enforced . . . was a tool by which
discrimination based on national origin was
effected.”
In general, though, English-only rules have been upheld. In
Pachero v. New York Presbyterian
Hospital,19 an English-only requirement was implemented in
response to complaints from patients
who believed that Spanish-speaking employees were talking
about them in a language that they
did not understand. An employee brought suit alleging national
origin discrimination under
theories of a hostile work environment, disparate treatment, and
disparate impact. The hospital
argued that its English-only requirement was both limited and a
business necessity: it helped
facilitate better staff-patient relationships and employees were
permitted to speak Spanish (or any
other language) when patients were not present. The court
agreed and dismissed the plaintiff’s
case. The courts have also summarized the types of business
necessity justifications that have
been upheld: In EEOC v. Sephora USA,20 an English-only
policy was justified as a means of
improving communication with customers; the court in Montes
v. Vail Clinic, Inc.,21 held an
English-only policy was necessary to ensure safety for hospital
patients; the court in Roman v.
Cornell University22 found an English-only rule was justified
to avoid or lessen interpersonal
conflicts between employees; the court in Long v. First Union

Corp. of Virginia23 held that an
English-only policy was justified to ensure the business runs
smoothly and efficiently; and the
court in Tuffa v. Flight Servs. & Sys. Inc.24 found that a policy
requiring employees to read in
English does not discriminate on its face and the requirement
that employees pass a written test
in English is not direct evidence of discrimination.
However, challenges to English-only rules are increasing, and
some have resulted in large
awards and settlements to affected employees. In 2001, a class-
action suit filed by eighteen
Latinx housekeepers against the University of Incarnate Word
for requiring them …
Student
23 February 18
Article critique #2
Vlaović, Zoran, et al. “Comfort Evaluation as the Example of
Anthropotechnical Furniture
Design.”
The purpose of the article was intended to portray the weight of
the issue based on the
comfort and discomfort of desk chairs. In order to find true
answers, the authors conducted a

study that tested multiple different chairs that had different size
seats. The purpose of the
study was to determine if size and composition of the seat
would change comfort levels of
individuals that spend large amounts of time sitting in them per
day.
One thing I really loved about the article was how descriptive
it was. It really looked
deep into things that I never really thought about as an issue. I
had never placed seat cushion
size and shape as something that I would use as a determining
factor to comfort over a long
period of time, but I guess it does make a lot of sense. I felt like
the diagrams really help a lot
too in understanding all of the information really well! Overall,
I thought the article was very
informative and portrayed the information in a really clear and
descriptive manner.
Article
Critique Rubric
GOOD
2 PTS

FAIR
1.5 PTS
POOR
1 PTS
BAD
0 PTS
SUMMARY Good
The article is clearly but
succinctly summarized - only
the key points of the article are
touched upon. The article
summary takes up no more than
one third of the total
assignment.
Fair
The article is clearly
summarized, but some sub
points are addressed along
with main points.
Poor
The article summary is
unclear or overly detailed.
Often well over half of the
assignment is taken up by
the summary.
No Effort

CRITIQUE Good
Strengths and weaknesses that
are central to the article are
addressed. The discussion of
strengths and weaknesses take
up the majority of the
assignment.
Fair
Strengths and weaknesses
that are peripheral to the
article are addressed. The
discussion of strengths and
weaknesses take up the
majority of the assignment
Poor
Strengths and weaknesses
are addressed peripherally,
weakly, or not at all. The
discussion of strengths and
weaknesses take up only a
small part of the
assignment
MECHANICS
Good

There are no grammatical
errors or typos.
Fair
There are few grammatical
errors or typos
Poor
There are many
grammatical errors and/or
typos
FORMAT Good
APA/MLA and page length
requirements are met
Fair
requirements are met
Poor
requirements are not met.

Article Critique
■ Reference
– APA format
■ Summary
– One paragraph (what the study was about primarily and what
were the key findings)
– Write in your own words
■ Do not just copy and paste the abstract
■ Critique
– Minimum three paragraphs
■ What was good?
– Subjects, study design etc.
■ Shortcomings of the article
– Pick apart the article
■ How you would take the study forward?
– Do not just go with their directions for future research

Article Critique Assignment II February 23rd, 2018 Studen.docx

Article Critique Assignment II February 23rd, 2018 Studen.docx

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