Yes, a short cocktail dress in any color will work for a daytime party. The campus where I am an advisor has daytime pref parties and all houses where short cocktail dresses - our girls wear black. It works fine.
I definitely second that. Even though our Pref is in the afternoon, when the PNMs enter our house, it is very dark and looks like it is being held in the evening. So the mood we set is still perfectly appropriate for black dresses.
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