The literature on sex equality is shot through with accounts of this predicament, variously described as a “double bind,” a “Catch-22,” or a “tightrope.” In many workplaces, women are pressured to be “masculine” enough to be respected as workers, but also to be “feminine” enough to be respected as women. (I put the adjectives “masculine” and “feminine” in quotation marks when otherwise unmodified because I use them to describe perceptions rather than realities about traits held by men and women.) The sheer mass of evidence further persuades me that demands for conformity made of women are not generic, but target them as women. I also become convinced these contradictory demands mean the story of contemporary sex discrimination is more complex than a single narrative of forced conformity to the dominant group.

To see how distinctive this Catch-22 is to women, consider the absence of a gay equivalent. If gays were in the same position as women, straights would constantly ask me not only to cover but to reverse cover. If I dressed conservatively, I would be asked to wear edgier attire. If I “acted straight,” I would be urged to be more flamboyant. But I do not think gays occupy this position. With significant exceptions of the “queer eye for the straight guy” variety, straights generally only ask me to cover. In my experience, the reverse-covering demand is more likely to be made by gays themselves.

Racial minorities are more like gays than women in this regard. If I, as an Asian-American, “dress white” and speak “perfect unaccented English,” I will find safe harbor. Whites make occasional reverse-covering demands – “Speak Japanese so we can hear what it sounds like,” or, “No, tell us where you’re really from.” But again, I have fielded reverse-covering demands more often from other Asian Americans, who tell me to get as politicized about Asian American issues as I am about gay issues.

When gays or racial minorities are caught in the crossfire of covering and reverse-covering demands, it is often because we are caught between two communities. The majority community (straights or whites) makes the covering demand, and the minority community (gays or racial minorities) makes the reverse-covering demand. Recent literature on African-American “oppositional culture” illustrates this dynamic. In response to white demands that African-Americans “act white,” some African-Americans have developed a culture of “acting black.” An African-American could easily be caught in a Catch-22, but not one generated by whites alone. More generally, negative epithets for racial minorities who cover – such as “oreo,” “banana,” “coconut,” or “apple” – seem to come from minority groups rather than from whites.

What makes women distinctive is that the dominant group – men – regularly imposes both covering and reverse-covering demands on them. Women are uniquely situated in this way because their subordination has more generally taken a unique form.  Unlike gays and racial minorities, women have been cherished by their oppressors.  Men have long valued the “feminine” traits women are supposed to hold, such as warmth, empathy, and nurture.

The mind-set through which men limit women in the name of loving them is known as “separate spheres” – an ideology  under which men inhabit the public sphere of work, culture, and politics, while women inhabit the private sphere of hearth and home.  The two spheres ostensibly track the different characters of men and women – men are thought to be suited for the public sphere because of their “masculine” attributes, women for the private sphere because of their “feminine” ones.  This ideology permits men to cherish and to confine women at the same time – women are revered, but only in the home.  In Democracy in America, Alexis de Tocqueville describes this arrangement with the approval typical of his period: “I have no hesitation in saying that although the American woman never leaves her domestic sphere and is in some respects very dependent within it, nowhere does she enjoy a higher station. ”

For centuries, separate-spheres thinking barred women from the workplace.  In 1872, the Supreme Court upheld an Illinois statue 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 women 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 using 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 perceives as too “feminine,” but also to wear make up 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 or 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.’

— Kenji Yoshino, Covering, pp. 145-149