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In exploring the Catch-22, I never found a woman who, like Eric Liu, made a list of her conforming behaviors. But I could easily imagine two such lists, arranged along the conventional axes of appearance, affiliation, activism, and association.

Here are some of the ways in which a woman could say she acts “masculine”:

I avoid pastels.

I avoid floral designs.

I do not wear my hair too long.

I do not cry.

I am aggressive.

I am ambitious.

I am analytical.

I am assertive.

I am athletic.

I am competitive.

I am individualistic.

I am self-reliant.

I work in a traditionally male-dominated field.

I am childless.

If I have children, I made my pregnancy “invisible.”

I built up stores of goodwill in anticipation of my pregnancy.

I never admit it when I leave work to take care of my children.

I do not have photographs of my children at the office.

I do not self-identify as a feminist.

I do not make women’s issues part of my work.

I am told I am exceptional, not like a typical woman.

I dissociate myself from other women.

Here are some of the ways in which a woman—and in many cases it could be the same woman—could say she acts “feminine”:

I wear earrings.

I wear makeup.

I do not wear my hair too short.

I am never unkempt.

I am affectionate.

I am cheerful.

I am compassionate.

I am gentle.

I am loyal.

I am sensitive.

I am soft-spoken.

I am sympathetic.

I am tender.

I am understanding.

I am warm.

I am yielding.

I listen.

I do not yell at work.

I express vulnerability.

I perform “nurture” functions at work, like counseling and mentoring.

I perform “housekeeping” functions at work, like arranging office events.

I work in a “pink-collar” ghetto.

Of course, many women behaving in these ways are not covering or reverse covering, but just being themselves. But women are often forced to adopt behaviors from both lists simply because they are women. I think of how prosecutor Marcia Clark started wearing pink during the O. J. Simpson trial, allegedly in response to jury consultants who thought she looked too “severe.” To do her job well, she had to exhibit “masculine” attributes. That display caused her to violate expectations about how women are supposed to behave. The allegations that she was too severe were reverse-covering demands pushing her toward “feminine” behavior. Presumably unwilling to act more “feminine” in her prosecutorial style, she did so with her attire. It need hardly be said that a male prosecutor would not have had to “tone down” his “masculine” attributes in this way. As law professor Susan Estrich observes: “This woman is in the business of prosecuting murderers, and the notion that she has to do it wearing pink is a stunning indictment of how far we’ve come in terms of equal rights.”

Given its pervasiveness in our culture, I was not surprised to find the Catch-22 surfacing in the Supreme Court case law. In 1982, when seven of the 662 partners at Price Waterhouse were women, Ann Hopkins was the sole woman among eighty-eight nominees for partnership. Of the nominees, Hopkins possessed the best record for generating new business, including a $25 million contract with the State Department. Nonetheless, the firm passed her over for partnership. When the partners refused to nominate her the next year, Hopkins sued under Title VII, alleging sex discrimination.

Price Waterhouse systematically asked Hopkins to cover and to reverse cover. The firm expected all partnership candidates to act “masculine”—to be aggressive, forceful, and so on. Hopkins had no trouble with these demands. The partners in her office praised her as “an outstanding professional” who had a “strong character, independence, and integrity.” At trial, one State Department official described her as “strong and forthright, very productive, energetic and creative,” while another praised her “decisiveness, broadmindedness, and intellectual clarity.”

Some partners, however, thought Hopkins’s aggression graded into abrasiveness. They imposed reverse-covering demands. One partner