Research suggests that light-skinned African American women have higher salaries and greater job satisfaction than dark-skinned women. Being "too black" has recently been acknowledged by the U.S. Federal courts in an employment discrimination case under Title VII of the Civil Rights Act of 1964. In "Etienne v. Spanish Lake Truck & Casino Plaza, LLC" the United States Court of Appeals for the Fifth Circuit, determined that an employee who was told on several occasions that her manager thought she was "too black" to do various tasks, found that the issue of the employee's skin color rather than race itself, played a key role in an employer's decision to keep the employee from advancing. A 2018 study uncovered evidence which suggests that immigrants with darker skin colors are discriminated against.