Covering_ The Hidden Assault on American Civil Rights - Kenji Yoshino [64]
For centuries, separate-spheres thinking barred women from the workplace. In 1872, the Supreme Court upheld an Illinois statute prohibiting women from practicing law. Concurring in that judgment, Justice Joseph Bradley observed women were unfit to be lawyers because of their “natural and proper timidity and delicacy.” He concluded: “The paramount destiny and mission of woman are to fulfill the noble and benign offices of wife and mother. This is the law of the Creator.”
Notice how Bradley does not exclude women by devaluing them. Instead, he underscores how much he admires women—their attributes of “timidity and delicacy” are “natural and proper” and the offices of wife and mother are “noble and benign.” “I really like women,” Justice Bradley seems to say. “And I really like wives, and mothers. It’s because I like women and wives and mothers so much that I don’t want women to be lawyers.” It’s hard to imagine a justice denying the rights of any other group with such affirming language. I would be more reconciled to my exclusion from the military if the courts would admit my “natural and proper” sodomitical tendencies better suit me for the “noble and benign” office of law professor.
A century later, the Court changed its thinking. In the 1973 opinion that began the Court’s sex-equality revolution, a plurality of the Court observed that the tradition of cherishing women so long as they remained in the home put them “not on a pedestal, but in a cage.” That recognition gradually swept away the most obvious barriers to women’s equality in the public sphere. Today, few places exist where the state or employers can post a “No Women Allowed” sign.
Nonetheless, separate-spheres ideology has contemporary traces. Men often require women who enter traditionally male workplaces to display the attributes of both spheres. If women are not “masculine” enough to be respected as workers, they will be asked to cover. If they are not “feminine” enough to be respected as women, they will be asked to reverse cover. Separate-spheres ideology has modern life in the Catch-22.
A cottage industry of advice manuals has sprung up to address this generation of sex discrimination. Grooming manuals for professional women—blazoned with titles like New Women’s Dress for Success—promise to help women satisfy both demands. They instruct women to avoid pastels or floral prints lest they be perceived as too “feminine,” but also to wear makeup lest they be perceived as too “masculine.” They recommend shoulder pads, but not “shoulder pads on steroids”; earrings, but not earrings that dangle; and hair that is neither too long nor too short.
Work-style manuals similarly tutor women in the art of acceptable androgyny. Consultant Gail Evans’s bestseller Play Like a Man, Win Like a Woman begins with the premise that to work in corporate America is to play a game whose rules have been written by men. She encourages women to assimilate by following rules of “masculine” behavior, such as “Speak out,” “Speak up,” “Don’t expect to make friends,” and “Be an imposter.” At the same time, Evans stresses “things men can do at work that women can’t,” such as sexualizing their work demeanor, behaving rudely, or looking unkempt.
A generation ago, such manuals emphasized covering. Recent manuals like Evans’s, however, increasingly underscore reverse covering. In her book Same Game, Different Rules, executive coach Jean Hollands describes a program she runs for “Bully Broads”—“aggressive and driven women who are completely misunderstood by their friends and colleagues.” She cautions that working women “need to be aware of the typical response to the very behaviors we learned from men.” “Women,” she observes, “are expected to be fair, nurturing, and caring. When we don’t appear so, the shock