MI Civil Rights Commission Issues Ruling on Discrimination Case Against Traverse City Hair Salon

For Immediate Release

(Petoskey, MI) - The Michigan Civil Rights Commission (the Commission) issued a ruling today against Studio 8 Hair Lab, LLC (Studio 8) related to charges of both discrimination and retaliation stemming from a series of public social media posts on the business's Facebook page that were found to have discriminated against individuals based on gender identity and expression under Michigan's Elliott-Larsen Civil Rights Act (ELCRA).

Background

Between July and November 2023, the Michigan Department of Civil Rights (MDCR) received over 20 complaints of discrimination against Studio 8, located in Traverse City, Michigan. Three of those complaints are the basis of this case.

In July 2023, Studio 8's owner and operator, Christine Geiger, published a post to the business's Facebook page indicating that persons who identify "as anything other than a man/woman" are "not welcome at [the] salon," and should "seek services at a local pet groomer." Subsequent posts reaffirmed Geiger's firm stance that the hair salon is not welcoming to members of the transgender and queer communities.

Between July and September 2023, complaints of discrimination were submitted to the Michigan Department of Civil Rights (MDCR) by M. Harris, L. Maynard, and H. Spooner.

After the certified complaints were filed, Gieger, on behalf of Studio 8, filed a Circuit Court complaint against Harris, Maynard, and Spooner, which was dismissed and whose appeal is currently pending before the Michigan Court of Appeals. Following this, the MDCR complaint was amended to include retaliation against the three individuals named in this case.

Following the Rules of the Michigan Civil Rights Commission, a Rule 12 hearing was held on August 22, 2024, before Administrative Law Judge Robert J. Meade. Judge Meade received proofs, heard arguments, and made proposed Findings of Fact and Conclusions of Law regarding the issues involved in this case in a Proposal for Decision issued on September 26, 2024. It should be noted that Studio 8 filed exceptions to the Proposal for Decision on October 4, 2024.

Legal Significance

Michigan Courts have not previously addressed claims of discriminatory advertising based on Section 302(b) of ELCRA, which states that a person shall not:

Print, circulate, post, mail, or otherwise cause to be published a statement, advertisement, notice, or sign that indicates that the full and equal enjoyment of the goods, services, facilities, privileges, advantages, or accommodations of a place of public accommodation or public service will be refused, withheld from, or denied an individual because of religion, race, color, national origin, age, sex, sexual orientation, gender identity or expression, or marital status, or that an individual's patronage of or presence at a place of public accommodation is objectionable, unwelcome, unacceptable, or undesirable because of religion, race, color, national origin, age, sex, sexual orientation, gender identity or expression, or marital status.

However, courts in Michigan, as courts in other states with civil rights laws, have used federal civil rights laws for assistance when arriving at decisions regarding state civil rights statutes. Judge Meade found a provision within the federal Fair Housing Act to be very similar to Section 302(b).

Judge Meade proceeded to adapt federal court guidelines related to the provision to determine if the statements made intended to deny and refuse goods and services based on gender identity or expression and indicate such persons were unwelcome due to their gender identity or expression.

This ruling marks the first judicial interpretation of this provision of Michigan's civil rights law, serving as an important point of reference for future enforcement and interpretation of this section of ELCRA and other Michigan civil rights statutes.

Findings

Based on the facts presented to both the Michigan Department of Civil Rights and Administrative Law Judge Meade, the Michigan Civil Rights Commission finds that social media posts of Christine Geiger, owner and operator of Studio 8 Hair Lab, LLC, violated Section 302(b) of the Elliott-Larsen Civil Rights Act.

The Commission also finds that the act of Studio 8 filing a civil lawsuit against Harris, Maynard, and Spooner amounts to prohibited retaliation, and violated Section 701 of the Elliott-Larsen Civil Rights Act.

Order

Studio 8, including owner and operator Christine Geiger, as well as all those with authority to act on its behalf, are ordered to immediately cease and desist publishing and circulating any statement that discriminates against individuals based on the protected characteristics outlined under ELCRA. Studio 8 is also ordered to immediately cease and desist all retaliation against the individuals who filed a complaint with MDCR.

Studio 8 is ordered to pay any costs, including attorney fees, related to both this case and the related case brought to the Grand Traverse Circuit Court, on behalf of Harris, Maynard, and Spooner. The matter of costs will be calculated and recommended to the Commission at a later date by Judge Meade.

Christine Geiger, as the owner of Studio 8 Hair Lab, LLC, is ordered to take a Civil Rights and Anti-Discrimination Compliance training within the next 120 days, and report back to the Commission and MDCR once the training is complete.

Studio 8 is ordered to immediately remove the challenged discriminatory posts on its Facebook page, as well as update and post language on both social media and in the physical establishment, that the business complies with and will not refuse goods or services to prospective or current clients based on the protected characteristics outlined in ELCRA.

Finally, The Commission will provide a copy of all relevant information on this case to the Michigan Department of Licensing and Regulatory Affairs as well as the Board of Cosmetology.

Impact

Reflecting on today's ruling, Michigan Civil Rights Commission Chair and one of the Commissioners assigned to this case, Luke Londo said, "The Elliott-Larsen Civil Rights Act has no favorite children. Membership in one protected class under ELCRA does not entitle one to discriminate based on another. This ruling sets the precedent that no business can publicly discriminate without consequence, whether it occurs face-to-face or over social media."

Michigan Department of Civil Rights Executive Director John E. Johnson, Jr. also provided the following statement: "As the first ruling to be issued in Michigan directly related to discriminatory advertising under the Elliott-Larsen Civil Rights Act, this decision establishes meaningful guidance for businesses, individuals, and future cases. It reinforces that the protections guaranteed under Michigan law extend to the ways businesses communicate with and serve the public, helping ensure those protections are applied consistently across evolving forms of public engagement."

Complete copies of the Order and Opinion can be found on the Michigan Department of Civil Rights website at 5:00 p.m. on Tuesday, July 28, 2026.

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The Michigan Civil Rights Commission was created by the Michigan Constitution to safeguard constitutional and legal guarantees against discrimination. The Commission is charged with investigating alleged discrimination against any person because of religion, race (including hair texture and protective hairstyles), color, national origin, genetic information, sex, sexual orientation, gender identity or expression, age, marital status, familial status, height, weight, arrest record, disability, and source of income in housing cases. The Michigan Department of Civil Rights serves as the operational arm of the Commission. Find more information on the Michigan Department of Civil Rights at michigan.gov/mdcr.