is an example of such a case. In this instance, the court ruled the plaintiffs, five Black women including Emma DeGraffenreid, who were employees of General Motors, were not eligible to file a complaint on the grounds they, as black women, were not "a special class to be protected from discrimination". The ruling in DeGraffenreid against the plaintiff revealed the courts inability to understand intersectionality's role in discrimination. Moore v Hughes Helicopters, Inc. is another ruling, which serves to reify the persistent discrediting of intersectionality as a factor in discrimination. In the case of Moore, the plaintiff brought forth statistical evidence revealing a disparity in promotions to upper-level and supervisory jobs between men and women and, to a lesser extent, between Black and white men. Ultimately, the court denied the plaintiff the ability to represent all Blacks and all females. The decision dwindled the pool of statistical information the plaintiff could pull from and limited the evidence only to that of Black women, which is a ruling in direct contradiction to DeGraffenreid. Further, because the plaintiff originally claimed discrimination as a Black female rather than, more generally, as a female the court stated it had concerns whether the plaintiff could "adequately represent white female employees". Payne v Travenol serves as yet another example of the courts inconsistency when dealing with issues revolving around intersections of race and sex. The plaintiffs in Payne, two Black females, filed suit against Travenol on behalf of both Black men and women on the grounds the pharmaceutical plant practiced racial discrimination. The court ruled the plaintiffs could not adequately represent Black males; however, they did allow the admittance of statistical evidence, which was inclusive of all Black employees. Despite the more favorable outcome after it was found there was extensive racial discrimination, the courts decided the benefits of the ruling – back pay and constructive seniority – would not be extended to Black males employed by the company. Moore contends Black women cannot adequately represent white women on issues of sex discrimination, Payne suggests Black women cannot adequately represent Black men on issues of race discrimination, and DeGraffenreid argues Black women are not a special class to be protected. The rulings, when connected, display a deep-rooted problem in regards to addressing discrimination within the legal system. These cases, although they are outdated are used by feminists as evidence of their ideas and principles. Communication theory