Game, Set, Skirt?: Women's Tennis Attire at Play
By Laurel Stout*
With four days until the 2018 US Open was set to begin, the French Tennis Federation made a big statement. Serena Williams’ black “catsuit” would be banned from any future French Open competitions. The French Tennis Federation’s President, Bernard Giudicelli, explained the Federation’s decision by saying, “one must respect the game and place.”
Then, days into the US Open, a chair umpire sanctioned competitor Alizé Cornet for unsportsmanlike conduct because Cornet removed her shirt when she realized it was on backwards. The United States Tennis Association (“USTA”) later clarified that Cornet should not have received a code violation because “[a]ll players can change their shirts when sitting in the player chair.” The Women’s Tennis Association (“WTA”) also claimed the umpire’s decision “was unfair and was not based on a WTA rule.”
Williams might claim that she is not bothered by the ban, and the chair umpire may have made a mistake in handing Cornet a code violation, but these incidents are indicative of a broader historical trend. The sport of tennis has faced many issues regarding the attire of the players, especially the female players.
In 1949, Gertrude Moran played her first match at Wimbledon without a knee length skirt, which was considered the proper attire for female tennis players. At the time of Moran’s display, the All-England Club, the organization that runs Wimbledon, “decried [Moran’s] outfit and claimed [Moran] brought ‘vulgarity and sin into tennis.’”
Nearly a decade after Moran’s incident at Wimbledon, in 1958, Karol Fageros wore gold underpants underneath her skirt to the French Open. This display got Fageros immediately banned from playing in Wimbledon of that same year allegedly because of her opponent’s potentially adverse reaction to her visible underwear. The All-England Club allowed Fageros to compete at Wimbledon when she agreed “to cover the gold up with white lace.”
Next, in 1972, Wimbledon officials, “ordered [Rosemary Casals] to change out of the dress she” was wearing because, according to the officials, the dress violated the strict Wimbledon dress code due to the white dress having “purple letters stitched into it.”
The most similar situation to Williams’ black catsuit occurred in 1985 when Anne White wore “an all-white bodysuit with long sleeves” to Wimbledon. Careful analysis suggests that the dress may have met the dress code of Wimbledon, which stated, “competitors must wear all-white, conservative attire.” However, after the match, White’s competitor, Pam Shriver, complained to officials that White’s bodysuit “had distracted her.” Upon review, the Wimbledon officials determined the bodysuit was “unfit for competition.”
Organizations from the USTA and French Tennis Federation to your local tennis club have dress codes. The USTA requires “proper tennis attire . . . for all sanctioned USTA tournaments.” Wimbledon is even stricter with its guidelines, requiring players to “be dressed in suitable tennis attire that is almost entirely white and this applies from the point at which the player enter[s] the court . . ..”
In addition, the WTA has seven pages in its rulebook solely dedicated to dress guidelines all female tennis players must comply with. Broadly, the rules demand players “dress and present themselves in a professional manner.” However, the rules have very specific requirements for identification on clothing from headbands, dresses, shoes, and even socks. If a player does not comply with these regulations, a “Chair Umpire, Referee, or Supervisor [may order the player] to change her attire or equipment immediately.” A player who fails to comply with an order to change can be fined or defaulted from a tournament.
Currently, the players seem quite unbothered by the recent developments, especially compared to the general public. The players have, to a certain extent, accepted the current guidelines and play in accordance with them. Some people perceive tennis to have an elitist culture and issues with attire further add to those notions.
In the end, the tennis organizations have the right to create whatever dress guidelines they see fit. It could be argued sex discrimination is at play; however, the written guidelines are generally uniform across gender. The WTA has specific guidelines for women, but the WTA is the governing tennis association for female players. Problems arise at the grand slam events because there seems to be different standards in enforcing the uniform rules on female and male players.
Eventually, stricter dress codes may affect the number of people who subject themselves to playing tennis. Within the last few decades, fewer American children are participating in sports due to the extremely high prices of youth sports. With stricter dress codes, tennis establishments could be making it more difficult for players of lower economic backgrounds to afford proper tennis attire.
In addition, fewer parents may be willing to allow their children to participate in tennis because of the perceived detrimental effect of officials criticizing their children about attire, even when they are following the letter of the dress codes. Over the years, the media has called out players as young as fifteen years old for their “outrageous tennis outfits.” Photographs show some of these outfits are labeled as outrageous simply due to the young teenagers’ choice of hair style.
The organizations claim the dress codes are all about respecting the game. However, isn’t winning twenty-three major championships and making tennis relevant in the world of dominant spectator heavy organizations such as the National Football League, National Basketball League, Major League Baseball, and the Champions League more important to the survival of the game than the outfit the player wears?
Ultimately, dress codes are required, and current players must follow them. But, the sport of tennis needs to be prepared for dress codes and judgemental attitudes to push future athletes into different sports. All it takes is one father from Compton to decide the dress codes are too much for his budget or his two daughters to handle, and the sport of tennis could be changed forever.
* Staff Writer, Jeffrey S. Moorad Sports Law Journal, J.D. Candidate, May 2020, Villanova University Charles Widger School of Law
 See Laurel Wamsley, ‘One Must Respect the Game’: French Open Bans Serena Williams’ Catsuit, NPR (Aug. 24, 2018), https://www.npr.org/2018/08/24/641549735/one-must-respect-the-game-french-open-bans-serena-williams-catsuit (quoting French Tennis Federation President’s meeting with Tennis Magazine).
 See id. (reporting ban not official but French Tennis Federation would implement dress code in near future).
 Alex Schroeder, Serena Williams and the Inherent Politics of Tennis, WBUR (Aug. 29, 2018), http://www.wbur.org/onpoint/2018/08/29/serena-williams-tennis-racism-sexism-politics (discussing politics of tennis and how tennis is a traditionally “country club sport” influences decision making).
 See Scott Gleeson, French Tennis Player Alize Cornet Gets Violation After Shirt Change, Sparking Sexism Chatter, CNBC (Aug. 29, 2018) https://www.cnbc.com/2018/08/29/french-tennis-player-alize-cornet-gets-violation-after-shirt-change-sparking-sexism-chatter.html (reporting Cornet had only removed her top for ten seconds after realizing her shirt was on backwards).
 See Simon Briggs, US Open Forced to Clarify Rules After Alize Cornet Is Punished for Removing Shirt on Court, Telegraph UK (Aug. 29, 2018), https://www.telegraph.co.uk/tennis/2018/08/29/us-open-accused-double-standards-alize-cornet-punished-removing/ (discussing how umpire’s snap decision seemed “absurdly petty” because Cornet’s sports bra was only seen for a couple of seconds and how incident is embarrassing for USTA given that “chief executive Katrina Adams is outspoken in her views about gender equality”).
 See id. (“Crucially, though, the handbook never says that an official ‘change of attire’ break is required for any player who wants to adjust their clothing.”).
 See id. (acknowledging potential mistake due to “vague nature of the WTA’s rules”); Lisa Ryan, A Brief (and Frustrating) History of People Policing Women’s Tennis Outfits, The Cut (Aug. 28, 2018), https://www.thecut.com/2018/08/womens-tennis-outfits-convtroversy-history.html (reporting issues with tennis attire at different points in history); see also Opehli Garcia Lawler, Serena Williams was Unfazed by the French Ban on Her CatSuit, The Cut (Aug. 26, 2018) https://www.thecut.com/2018/08/serena-williams-not-bothered-by-french-ban-on-nike-catsuit.html (“Everything’s fine, guys . . . when it comes to fashion, you don’t want to be a repeat offender”).
 See Nadra Nittle, The Serena Williams Catsuit Ban Shows That Tennis Can’t Get Past its Elitist Roots, Vox (Aug. 28, 2018), https://www.vox.com/2018/8/28/17791518/serena-williams-catsuit-ban-french-open-tennis-racist-sexist-country-club-sport (discussing clothing issues throughout history of tennis); see also Ryan, supra note 7 (listing specific instances of officials policing women’s tennis outfits).
 See Gertrude ‘Gussie’ Moran, Whose Short Tennis Skirt Shocked Wimbledon, Is Dead at 89, NY Daily News (Jan. 19, 2013), http://www.nydailynews.com/news/world/gussie-moran-tennis-pioneer-dead-89-article-1.1243097 (discussing Moran’s refusal to wear knee length skirts and defiant pairing of shorter skirt with ruffled underwear).
 Ryan, supra note 7 (reporting that not only was Moran’s skirt shorter than the norm but her underwear was also showing).
 See id. (discussing reaction from Wimbledon).
 See id. (“[Fageros’] underwear might put opponents off.”).
 Id. (providing a photo that shows bodysuit’s striking similarity to Williams’ bodysuit).
 Id. (finding presumption bodysuit met dress code incorrect).
 Id. (reporting Shriver lost match to White).
 See Chicago USTA, USTA Midwest Chicago Dress Code, http://www.chicago.usta.com/Tournaments/Dress_Code/ (last visited Sept. 7, 2018) (showing an example of a dress code for USTA); Wimbledon, Clothing and Equipment, https://www.wimbledon.com/en_GB/about_wimbledon/clothing_and_equipment.html (last visited Sept. 7, 2018) (listing dress code of Wimbledon All-England Club); Newfield Club, Club Dress Code, https://www.newfieldclub.org/member-resources/dress-code/ (last visited Sept. 8, 2018) (explaining dress code for local tennis club).
 Chicago USTA, supra note 22 (citing USTA regulations).
 Wimbledon, Clothing and Equipment (finding everything must be white including soles of player’s shoes).
 See Women’s Tennis Ass’n, 2018 Official Rule Book, http://wtafiles.wtatennis.com/pdf/publications/2018WTARulebook.pdf (last visited Sept. 7, 2018) (listing rules ranging from proper dress to creation of top ten player list).
 Id.at 103.
 See id. at 103-09 (listing two millimeter spike measurements on shoes for specific tennis courts).
 Id.at 109 (stating players risk penalty for noncompliance with clothing rules).
 See id. (providing fines can be “appealed within 21 days from the date of notice.”).
 See Lawler, supra note 7 (reporting former tennis player Andy Roddick felt bothered by ban).
 See id. (“[O]bviously, the Grand Slams have a right to do what they want to do.”).
 See Nittle, supra note 9 (discussing how Williams and her sister have been criticized since beginning of careers for outfits and hairstyles).
 See Lawler, supra note 7 (explaining that tennis organizations have right to enact dress codes).
 See Wimbledon, supra note 24 (providing the same guidelines for male and female players)
 See Women’s Tennis Ass’n, supra note 26 (“The . . . WTA is an international award competition open to all women tennis players.”).
 See Christina Capatides, U.S. Open Accused of Sexism After Alize Cornet Penalized for Taking off Her Shirt While Male Players Sit Shirtless, CBS News (Aug. 29, 2018) https://www.cbsnews.com/news/us-open-accused-sexism-after-alize-cornet-penalized-for-taking-off-shirt-while-federer-djokovic-sit-shirtless/ (discussing how male players consistently take their shirts off to stay cool and never receive penalties for their actions).
 See id. (posting tweet from Andy Roddick suggesting tennis is hurting itself with strict dress codes).
 See Emily Barone, The Astronomical Cost of Kids’ Sports, Time (Aug. 24, 2017), http://time.com/4913284/kids-sports-cost/ (discussing the rising cost of youth sports in America).
 See generally Dick’s Sporting Goods, Tennis Skirts & Skorts, https://www.dickssportinggoods.com/f/tennis-skirts-skorts#facet:ads_f55165_ntk_cs%3A%22Girls%26%2339%3B%22 (listing the starting price of a youth girls tennis skirt as $24.99).
 See generally Venus and Serena Williams in Pictures: Their Outrageous Tennis Outfits Through the Years,The Telegraph UK (last visited Sept. 18, 2018), https://www.telegraph.co.uk/sport/picturegalleries/8268556/Venus-and-Serena-Williams-in-pictures-their-outrageous-tennis-outfits-through-the-years.html?image=8 (judging Serena and Venus for their attire since they arrived onto the tennis scene in the 1990s).
 See id. (describing the attire of a fifteen year old Serena Williams and a sixteen old year Venus Williams as “outrageous”).
 See id. (posting photos of Serena and Venus Williams wearing beads in their hair).
 See Nittle, supra note 9 (“You have to respect the game and the place.”).
 See generally Alyssa Roenigk, Road to 23: The Story of Serena’s Path to Greatness, ESPNW (Jan. 30, 2017), http://www.espn.com/espnw/culture/feature/article/17494146/road-23-story-serena-path-greatness (chronicling Williams years as tennis professional and road to becoming one of game’s all-time greats).
 See Women’s Tennis Ass’n, supra note 25 (stating imperative nature of dress code and warning of penalties for noncompliance).
 See generally Lawler, supra note 7 (suggesting tennis may be getting in its own way).
 See generally Jim Caple, Back in Compton, “They Love Their Venus and Serena”, ESPNW (Feb. 13, 2017) http://www.espn.com/espnw/news-commentary/article/13524355/back-compton-love-their-venus-serena (commenting on influence Williams sisters have had on tennis especially in hometown of Compton).