Likability in the Business Workplace: an Obstacle for Women Then and Now

By: Julia Elmaleh-Sachs

In 1983, Ms. Ann Hopkins sued her employer, the accounting firm Price Waterhouse, under Title VII of the Civil Rights Act of 1964.[1]  She claimed she had been denied the position of  partner primarily on the basis of her gender.  Hopkins went on to win her case in both the District and Circuit Courts.  After it was heard by the Supreme Court in 1988,  Price Waterhouse v. Hopkins became the gender discrimination case on the books.  Not only did the Court establish an altered burden of proof —namely that the employer had to show that the decision regarding employment would have been the same if sex discrimination had not occurred— but it also introduced the  legal relevance of sex stereotyping as a subset of sex-discrimination in the workplace.[2]  Twenty years after Hopkins sued the business-oriented firm she worked for, the New York Times this past Sunday published an article about gender inequity in business school and beyond.[3]

What is it about the business world that makes it so difficult for women to succeed at the same level as men?  Sheryl Sandberg, renowned COO of Facebook and author of Lean In submits that one tremendous problem for women is that they often must choose between the possibility of being liked and that of being promoted.[4]  Women who take leadership roles, research has shown, are “violating the feminine stereotype of being ‘nurturing’ and ‘supportive’ and ‘helping other people succeed.’”[5] This leads to a tradeoff. “Women who are perceived as highly competent are evaluated as less warm and less nice.”[6]  Thus, whereas likability and success in the workplace correlate for men, Sandberg asserts, the opposite is true for women: the more a woman is thriving professionally, the less her peers and colleagues like her.[7]  The Price Waterhouse Court made a similar observation about the options women face in this type of work environment: “an employer who objects to aggressiveness in women but whose positions require this trait places women in an intolerable and impermissible Catch-22: out of a job if they behave aggressively and out of a job if they do not.”[8]  Though perhaps the standard is not quite as rigid today, its legacy is still palpable.

Women may not realize this unfortunate nexus openly, but the numbers illustrate that they have most  likely internalized it.  In early 2013, women made up only one fifth of the tenured faculty at Harvard Business School.[9]  “Female teachers, especially untenured ones, had faced various troubles over the years: uncertainty over maternity leave, a lack of opportunities to write papers with senior professors, and students who destroyed their confidence by pelting them with math questions they could not answer on the spot or commenting on what they wore.”[10] A quote by a potential employer at an extracurricular presentation sums up the industry’s view towards women quite blatantly: when  a female student asked the man, a co-founder of a venture capital firm for advice for women who wanted to go into his field, he simply answered “don’t.”[11]  Male partners did not want them there, he continued, and he was doing them a favor by warning them.[12]

Those female professors at Harvard Business School who were strong enough to last past their “welcome” were publicly less popular than their male counterparts.  Students openly favored male professors over female professors.  One female student was quoted saying, that “the female profs I had were clearly weaker than the male ones. They weren’t able to really run the classroom the way the male ones could.”  Why are women weaker and less authoritative than their male counterparts?  Are they merely perceived this way by their students or is their classroom presence really lacking in command? For how long have women been conditioned to act in such a manner?

When Hopkins was denied partnership in 1983, her colleague and friend Thomas Beyer advised her that all she had to do next time around was to  “walk more femininely, talk more femininely, dress more femininely, wear make-up, have her hair styled, and wear jewelry.”[13]  In fact, the District Court Judge in Hopkins’ trial found that, as a general matter, female candidates for partnership were viewed most favorably if partners believed they maintained their femininity while becoming effective professional managers.[14]

It is 2013 and the norm for women has barely shifted.  The Catch-22 the Court warned about in Price Waterhouse remains alive and pervasive, though it has taken on a slightly altered form:  if you want to succeed as a woman in the business world, recognize now that you will be critiqued twice as harshly, you will be liked half as much, even though your work-product will be just as good, if not better than that of your male counterparts.   I’m not sure what the solution entails but at the very least, by acknowledging that this disparity exists, women and men can work together to diminish the significance of sex-stereotypes in the business world.

[1] Price Waterhouse v. Hopkins, 490 U.S. 228 (1989).

[2] Id. at 250.

[3] Jodi Kantor, Harvard Business School Case Study: Gender Equity, N.Y. Times, (Sept. 7, 2013),

[4]Ken Auletta, A Woman’s Place, The New Yorker, (July 11, 2011),

[5] Id.

[6] Id.

[7] Id.

[8] Price Waterhouse, 490 U.S. at 251.

[9] Jodi Kantor, Harvard Business School Case Study: Gender Equity, N.Y. Times, (Sept. 7, 2013),

[10] Id.

[11] Id.

[12] Id.

[13] Price Waterhouse, 490 U.S. at 235.

[14] Id. at 236.

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