Without a word to describe the behavior he was seeing Yoshino turned to sociologist Erving Goffman's book Stigma which talks about how different groups try to manage their "spoiled" identities. Through Goffman, Yoshino learns two important words that he to uses throughout the rest of the article: these words are "passing" and "covering", passing relates to the visibility of a characteristic, while covering refers to the act of hiding a characteristic of one's identity from the mainstream and conforming to seem "normal." (34) After talking about the difference between passing and covering, Goffman talks about the great F.D.R. and how, before a meeting with his advisers, he would be behind his desk. He states that Roosevelt wasn't passing but rather covering because everyone knew he used a wheelchair but he wanted to play down his disability. Roosevelt thought if he played down his disability people would focus on his presidential qualities (34). After learning about covering Yoshino started to notice covering everywhere, Helen Keller replaced her natural eyes with blue glass ones, actors changing their names if it sounds religious. .
Yoshino says that covering is the civil rights issue of our time, and he describes five civil law court cases to support his argument. The first case is about Renee Rogers, an African- American employee at American Airlines. She wore cornrows to work and American had a policy that prohibited employees from wearing all-braided hairstyles. The airline enforced the policy against Rogers; she sued them alleging race discrimination in 1981. The federal court rejected her argument, saying hairstyle is a mutable characteristic so discrimination on the basis grooming was not the same as skin color, and it wasn't discrimination against her race. That idea made the courts favor American Airlines and Rogers lost her case.
The next case Yoshino brought up was Lydia Mikus and Ismael Gonzalez; they were called for jury service.