Texas Court Reviews CROWN Act as FDA Delays Straightener Ban

State Legislation and the CROWN Act Expansion

Over the past several years, the movement to dismantle hair-based discrimination in the United States has gained significant legislative momentum. Founded through a partnership involving Dove and the CROWN Coalition, the Creating a Respectful and Open World for Natural Hair (CROWN) Act was drafted to explicitly prohibit discrimination against natural hair textures and protective hairstyles, including braids, locs, twists, and knots. Before the enactment of these legislative measures, employer and school dress codes frequently penalized individuals wearing natural African American hair textures under the guise of professional appearance standards. The advocacy campaigns launched by civil rights organizations and industry partners have successfully established that hair texture and protective styling are intrinsically linked to racial identity and personal expression.

To date, more than 20 U.S. states and dozens of municipalities have successfully enacted versions of the CROWN Act into law. These state statutes modify existing anti-discrimination frameworks, such as state human rights laws and education codes, to mandate that public institutions and private employers cannot enforce grooming policies that disparately target natural hairstyles. State lawmakers who sponsored the bills pointed out that historic standards of grooming relied heavily on Western aesthetic norms, effectively requiring Black workers and students to use dangerous chemical straighteners or alter their natural features to comply with workplace and classroom standards. The CROWN Coalition continues to track state-level enactments while building public support for federal statutory protections.

Despite the widespread adoption of state-level CROWN Acts, statutory language and scope vary considerably across state borders. Some state statutes apply exclusively to public primary and secondary schools, whereas others extend comprehensive anti-discrimination mandates to private employers, housing, and public accommodations. Legal scholars note that while local adoption provides vital immediate relief to residents in progressive jurisdictions, the lack of a uniform national policy leaves millions of workers and students subject to conflicting standard requirements when moving between state lines or working for national enterprises.

The Texas Supreme Court and Barbers Hill School District Dispute

The legal boundary of state-level hair protection laws faces a major test in Texas, where the state Supreme Court agreed in September 2024 to hear a high-profile lawsuit concerning a Black high school student. Darryl George, a student at Barbers Hill High School in Mont Belvieu, Texas, was placed in in-school suspension for months due to the length of his locs. School administrators argued that their dress code policy did not violate the Texas CROWN Act, which took effect on September 1, 2023, because the school regulations governed hair length rather than hair texture or style. The district maintained that male students could wear locs or braids provided the hair did not fall below the top of a shirt collar, eyebrows, or earlobes when let down.

Darryl George and his family filed a lawsuit contending that the district's interpretation creates an artificial distinction designed to circumvent statutory protections. His defense team argued that locs and protective hairstyles cannot be separated from hair length without forcing students to cut their hair, thereby frustrating the legislative intent of the Texas CROWN Act. The controversy highlighted how school districts in conservative judicial circuits attempt to maintain long-standing grooming policies by narrowing the legal definitions of texture and protective styling. Lower state courts previously sided with the school district, prompting the appeal to the state's highest court.

The upcoming review by the Texas Supreme Court is expected to set a critical judicial precedent for how state courts interpret grooming codes under natural hair protection statutes. Civil rights attorneys argue that allowing educational institutions to enforce restrictive length requirements on male students wearing protective styles effectively nullifies CROWN Act protections for Black male youths. Conversely, school district representatives argue that courts must preserve local school board autonomy to set non-discriminatory dress code standards that promote classroom discipline. The judicial resolution will likely influence how other state courts address length restrictions in natural hair litigation nationwide.

Federal Delay on Formaldehyde Hair Straightener Bans

While state legislatures and courts examine civil rights protections surrounding hair styling, federal regulatory agencies face mounting scrutiny regarding the chemical safety of hair products sold across the nation. The U.S. Food and Drug Administration (FDA) initially announced plans to propose a nationwide ban on formaldehyde and formaldehyde-releasing chemicals in hair straightening and smoothing products by April 2024. However, the regulatory agency missed its target publication date, delaying the public notice of proposed rulemaking and drawing sharp criticism from public health advocates and federal lawmakers.

Formaldehyde is a known human carcinogen commonly found in chemical smoothing treatments and relaxers used in professional salons and home styling kits. During high-heat styling processes, such as blow-drying or flat-ironing, chemical relaxers containing formaldehyde release toxic gas into the air, posing severe respiratory and carcinogenic risks to both salon workers and consumers. Lawmakers, including members of the Congressional Black Caucus, have repeatedly written to FDA leadership urging immediate executive action to finalize the ban, pointing out that Black women are disproportionately exposed to these hazardous formulations due to targeted commercial marketing.

Regulatory officials at the FDA indicated that drafting comprehensive product bans requires rigorous economic impact assessments, toxicological reviews, and interagency consultations before issuing formal proposed rules in the Federal Register. Despite the administrative delay, health advocacy groups emphasize that prolonged regulatory inertia leaves millions of consumers vulnerable to toxic chemical exposures. Several European nations and international jurisdictions have already implemented stringent bans on formaldehyde in cosmetics, increasing pressure on U.S. regulators to align national standards with global public health norms.

Health Research Linking Chemical Relaxers to Cancer Risks

Scientific concern regarding hair relaxers extends beyond acute formaldehyde exposure to long-term systemic health consequences documented in large-scale epidemiological studies. Research published by the National Institutes of Health (NIH) through the Sister Study demonstrated a statistically significant association between frequent chemical hair straightener use and an increased risk of developing uterine cancer. Researchers monitored thousands of women over several years and discovered that participants who used chemical straightening products more than four times per year were more than twice as likely to develop uterine cancer compared to non-users.

The epidemiological findings from the NIH study also identified elevated risks for other hormone-sensitive conditions, including ovarian cancer and uterine fibroids. Researchers hypothesized that endocrine-disrupting chemicals found in relaxers, such as phthalates, parabens, and bisphenol A, penetrate the scalp during application and disrupt hormone regulation in the human body. Because chemical straighteners often cause micro-abrasions or scalp irritation during application, systemic absorption of these toxic substances is further accelerated, compounding biological exposure risks.

The public health data has ignited a wave of product liability litigation across the country, with thousands of women filing lawsuits against cosmetic manufacturers. Plaintiffs allege that manufacturers knew or should have known about the elevated cancer risks associated with endocrine-disrupting formulations yet failed to adequately warn consumers. The convergence of scientific evidence and legal liability has prompted growing consumer demand for safer, non-toxic hair care products, reshaping product development strategies across the multi-billion-dollar global beauty industry.

Consolidated Timeline of Hair Policy and Regulation

To provide a clear overview of how civil rights protections and public health regulations have evolved over recent years, a consolidated timeline reveals the interplay between state legislation, judicial appeals, federal regulatory delays, and medical research dispatches. The following consolidated timeline synthesizes key legislative, judicial, and regulatory developments compiled from official CROWN Coalition records, Texas Supreme Court filings reported by The Texas Tribune, National Institutes of Health research disclosures, and FDA rulemaking notices reported by NBC News.

In October 2022, the National Institutes of Health published landmark study results linking chemical hair straighteners to a doubled risk of uterine cancer among frequent users, establishing the primary scientific foundation for federal regulatory intervention. In September 2023, the Texas CROWN Act took effect, prohibiting race-based hair discrimination statewide; however, that same month, Barbers Hill High School placed student Darryl George in in-school suspension over his loc length. In October 2023, the FDA announced an intended target of April 2024 to publish a proposed rule banning formaldehyde in hair straighteners. In May 2024, NBC News reported that the FDA missed its April deadline, pushing back the proposed rule indefinitely. Subsequently, in September 2024, the Texas Supreme Court agreed to review Darryl George's legal challenge against the Barbers Hill Independent School District.

Analyzing this consolidated timeline demonstrates that while legislative efforts to protect natural hair textures have advanced rapidly across state legislatures, executive regulation of dangerous cosmetic chemicals faces chronic administrative delays. Furthermore, judicial resistance at the local school board level continues to challenge the practical scope of state non-discrimination laws, highlighting ongoing friction between local authority and state anti-discrimination mandates.

Economic, Social, and Legal Trajectories in Hair Governance

The ongoing debate over hair discrimination and chemical safety carries profound economic implications for the beauty and personal care sectors. For decades, Black consumers spent a disproportionate amount of disposable income on chemical straighteners and salon services due to societal pressure to conform to European beauty standards. However, as CROWN Act legislation proliferates and public awareness of chemical health risks grows, consumer spending is rapidly shifting toward natural hair products, organic styling tools, and clean beauty brands that avoid harmful preservatives.

On the corporate and institutional front, human resource departments and educational administrators are revising internal dress codes to avoid regulatory penalties and high-profile litigation. Companies operating across multiple states are increasingly adopting top-down policies that explicitly permit natural hairstyles and protective braids across all operational locations. This corporate shift not only minimizes legal exposure under state CROWN Acts but also aids talent acquisition and retention in competitive labor markets that value diversity and inclusive culture.

Looking ahead, the broader landscape of hair governance will depend on two critical federal vectors: judicial clarity on state law interpretation and executive action from federal health regulators. If the U.S. Congress passes a federal version of the CROWN Act, uniform legal protections would eliminate geographic disparities across all fifty states. Simultaneously, if the FDA finalizes its proposed formaldehyde ban, consumer product safety standards will catch up with decades of health research, reshaping both civil rights and public safety for millions of Americans.

What happens next

The Texas Supreme Court will hear arguments in the Barbers Hill ISD case, while public health groups urge the FDA to finalize its delayed formaldehyde ban.