Generally, courts have upheld employer requirements that male employees maintain short hair (while not requiring the same from female employees) on the grounds that such requirements are not indicative of gender discrimination but rather only reflect “grooming standards.” Courts have also not been hesitant to invalidate gender-based differences in required workplace dress, such as when the required dress for females tends to indicate (based on stereotypical standards) that the females in a position are of lower status than males in the same position or when the female dress code exposes female employees to lewd attention because it is revealing.