42 U.S.C. § 2000e-2

Section 2000e-2(a)(1) requires facts supporting a plausible inference that an employer treated an employee adversely because of race; allegations of unfair treatment without a connection to race are insufficient.

Washington v. Sodecia Automotive · filed 2025-10-21(a)(1)

That speculation without supporting factual allegations is insufficient to state a race discrimination claim that is plausible on its face, so the district court properly dismissed Washington’s Title VII and ELCRA claims.

Section 2000e-2(a) permits a race discrimination claim to proceed when the alleged circumstances of an employee’s termination support an inference of unlawful discrimination.

Hooks · filed 2025-10-21(a)

These facts, albeit not robust, are sufficient to state a prima facie race discrimination claim. Thus, Plaintiff’s race discrimination claim may proceed.

Section 2000e-2(a)(1) requires facts supporting a reasonable inference that the employer discriminated against the employee because of race.

Rodgers · filed 2025-10-22(a)(1)

That is, Rodgers must allege sufficient facts from which the Court can draw a reasonable inference that his employer “discriminate[d] against [him] . . . because of [his] race.” 42 U.S.C. § 2000e–2(a)(1).

Section 2000e-2 permits a race discrimination claim when an employee alleges satisfactory performance and less favorable treatment than a similarly situated employee outside her protected class.

Watkins · filed 2025-10-24

In other words, Watkins has alleged she performed her job satisfactorily and the SVA treated her differently than a similarly situated employee who did not belong to the same protected class (race) as Watkins.

Section 2000e-2 requires an employee alleging racial discrimination to show that the employer’s stated reason for termination was a pretext for discrimination once the employer gives a legitimate reason.

Ceasar III v. City of Lake Charles · filed 2025-11-03(a)(1)

Plaintiff therefore fails to carry his burden and defendants are entitled to summary judgment on this claim.

Section 2000e-2(a)(1) prohibits race discrimination in the terms and conditions of employment; a discrimination claim requires evidence linking the challenged action to race.

Sherman v. Collins · filed 2025-11-06(a)(1)

Under Title VII, for example, employers are prohibited from discriminating against an employee with respect to compensation and terms, conditions, or privileges of employment because of the employee’s race. See 42 U.S.C. § 2000e–2(a)(1). ... In short, Sherman hasn’t come forward with sufficient evidence for a reasonable jury to find a Title VII violation.

Section 2000e-2(a)(1) prohibits firing an employee because of race; a claim fails when the evidence would not permit a reasonable jury to find that race caused the firing.

Graham · filed 2025-11-12(a)(1)

Because no evidence of a discriminatory purpose exists here, a reasonable jury therefore could not conclude that Graham’s firing was discriminatory. Thus, her Title VII claim fails as a matter of law.

A race discrimination claim under § 2000e-2(a) requires facts supporting a plausible inference that the employer acted because of the employee’s race.

Richardson v. CSL Plasma · filed 2025-11-18(a)

In other words, Richardson’s conclusory allegations to support his Title VII claim are not sufficient to state a race discrimination claim.

In a reduction in workforce, a Title VII race discrimination plaintiff can establish the fourth element of a prima facie case by showing that the employer retained similarly situated workers outside the protected class.

GAMBILL · filed 2025-11-19(a)(1)

In short, neither Plaintiff is able to establish that CDC “retained similarly situated...employees who were not within the protected class” and, thus, neither can satisfy the fourth...element of her prima facie case of race discrimination under either Title VII or section 1981.

Section 2000e-2(c)(1) prohibits racial discrimination by labor unions; a race discrimination claim against a union requires facts supporting less favorable treatment than employees of another race.

Grays · filed 2025-11-20(c)(1)

Plaintiff’s failure to provide this Court with any comparator of another race warrants this claim’s dismissal against Local 891.

Section 2000e-2(a) requires enough evidence for a reasonable jury to infer intentional race discrimination when a claim rests on circumstantial evidence.

Adams · filed 2025-12-05(a)

Because Deputy Adams has not put forth evidence of discrimination sufficient to satisfy the McDonnell Douglas test or the convincing mosaic analysis, his Title VII discrimination claim fails as a matter of law.

Section 2000e-2(a) permits a race discrimination claim to proceed when the circumstances of a firing could allow a reasonable jury to infer discrimination.

TUOHEY · filed 2025-12-15(a)

A reasonable jury could infer race discrimination on these facts.

Section 2000e-2(a)(1) requires evidence that race caused an adverse employment action; different treatment alone does not establish discrimination.

Jones · filed 2025-12-19(a)(1)

Ms. Jones might be able to demonstrate that Zimmer treated Ms. Tabb differently in both Ms. Jones’s suspension pre-investigation and termination post-investigation of the altercation, but a reasonable jury could not find the company did so because of racial animus. The court grants summary judgment on the Title VII discrimination claim accordingly.

Section 2000e-2(a)(1) permits a race discrimination claim to proceed when the alleged employment action and surrounding circumstances plausibly support an inference of discrimination.

Collier · filed 2025-12-22(a)(1)

Viewing Plaintiff’s allegations in the light most favorable to her, the Court finds that Plaintiff has stated a plausible disparate-treatment claim based on her race.

Section 2000e-2(a) permits a race discrimination claim to proceed when the complaint plausibly alleges discriminatory treatment in employment.

Johnson v. Baltimore City, Maryland: Baltimore Police Dept. · filed 2026-01-06(a)

We agree as to the race discrimination claim, but we conclude the district court did not err in dismissing the retaliation and Monell claims. ... To survive a motion to dismiss a Title VII race discrimination claim, the complaint must allege facts “that plausibly state a violation of Title VII above a speculative level.” Bing v. Brivo Sys., LLC, 959 F.3d 605, 617 (4th Cir. 2020) (quoting Coleman, 626 F.3d at 190) (internal quotation marks omitted).

Section 2000e-2(a)(1) allows a race discrimination claim to proceed when the employee plausibly alleges inferior assignments and unequal treatment because of race.

Samah · filed 2026-01-08(a)(1)

These allegations are sufficient to state claims of race discrimination under Title VII and Chapter 151B.

A race discrimination claim requires facts suggesting intentional discrimination; different treatment of employees with different records of errors does not, by itself, support that inference.

Lowery v. Jefferson County Racing Association · filed 2026-01-15(a)(1)

To state a race-discrimination claim under Title VII, Lowery must have alleged enough facts to suggest intentional racial discrimina- tion. Surtain v. Hamlin Terrace Found., 789 F.3d 1239, 1246 (11th Cir. 2015). Her complaint does not meet that standard.

Section 2000e-2(a) prohibits firing an employee because of race; when an employer offers a legitimate reason for the firing, a plaintiff relying on circumstantial evidence must show that reason was pretextual.

Davis v. Univ. of Toledo · filed 2026-01-22(a)

Title VII of the Civil Rights Act makes it unlawful for an employer “to fail or refuse to hire or to discharge any individual, or otherwise to discriminate against any individual with respect to his compensation, terms, conditions, or privileges of employment, because of” that individual’s “race.” 42 U.S.C. § 2000e-2(a). ... But there’s plenty of evidence that she failed in her responsibilities on her own. So her termination wasn’t pretextual.

Section 2000e-2(a)(1) prohibits employers from making employment decisions because of an individual's race.

Slaughter · filed 2026-01-28(a)(1)

Title VII of the Civil Rights Act of 1964 prohibits employers from discriminating against any individual with respect to compensation, terms, conditions, or privileges of employment because of the individual's race.

A school supported, controlled, or managed by a particular religion may employ people based on religion without espousing a narrow religious doctrine.

Killinger v. Samford University · filed 1996-02-14(e)(2)

In order to constitute a “religious corporation” or an “educational institution,” as those terms are used in the Title VII exemption statutes, it is not necessary that a narrow spectrum of Christian or of Baptist doctrine be espoused. Furthermore, Dr. Kil-linger’s complaint itself virtually proves that Samford is an institution “supported,” “controlled” and/or “managed” by a particular religion as those terms are used in the exemption statutes.

Section 2000e-2(e)(2) permits religious schools to consider teachers’ religious practice when making employment decisions.

Larsen v. Kirkham · filed 1980-09-26(e)(2)

First, her notion that the religious school exemption permits no more than a religious school’s preference for those ostensibly affiliated with the religion operating it ignores both reason and policy. It implies that the practice of religion is something separate from what is meant by the term “religion” as it appears in § 703(e).

Section 2000e-2(e)(2) permits religiously affiliated schools to favor employees of a particular religion, but does not exempt them from Title VII’s prohibition on sex discrimination.

Ritter v. Mount St. Mary's College · filed 1980-08-08(e)(2)

Unless this Court were to regard these statutes as mere surplusage, it is thus clear that Congress exempted religiously affiliated schools only from religious discrimination.

The former educational institution exemption in § 2000e-2 covered employees whose work was connected with an institution’s activities, and the 1972 amendments ending that exemption do not apply retroactively.

Mattye Faye FAULKNER, Appellant, v. FEDERATION OF PRESCHOOL AND COMMUNITY EDUCATION CENTERS, INC., Appellee · filed 1977-11-10

Educational institutions were originally exempted from Title VII coverage. 42 U.S.C. § 2000e-2. ... In the absence of statutory definition and of any evidence of legislative intent, the district court’s finding that the Federation is an “educational institution” and that appellant’s work was “connected with” the activities of the Federation is correct. ... Nor are the 1972 Amendments subjecting educational institutions to the requirements of Title VII to be applied retroactively.

Section 2000e-2(e)(2) gives a religiously controlled college broad latitude to choose theology faculty on religious grounds, including when an applicant disputes the college’s assessment of her beliefs.

Maguire v. Marquette University · filed 1986-02-12(e)(2)

Because the First Amendment prevents the Court from involving itself in the area, the Court finds that the exception to Title VII created by 42 U.S.C. § 2000e-2(e)(2) should be read to allow the hiring committee of a theology department in a college controlled by a religious society broad latitude when it makes a decision to hire “employees of a particular religion.”

Section 2000e-2(e)(2) permits qualifying religious schools to favor employees of a particular religion but does not exempt them from liability for sex discrimination.

Vigars v. Valley Christian Center of Dublin, Cal. · filed 1992-05-20(e)(2)

The legislative history of these statutory exemptions indicates that Congress intended Title VII to apply to sex-based employment decisions by religious entities. The exemptions do not simply exempt religious organizations from Title VII.

Section 2000e-2(e)(2) permits qualifying religious educational institutions to prefer employees of a particular religion, but does not permit discrimination based on sex, race, or national origin.

Elbaz v. Congregation Beth Judea, Inc. · filed 1992-07-06(e)(2)

Again, though, it is religious discrimination that (in proper situations) is not prohibited; .§ 2000e-2(e)(2) does not permit discrimination on the basis of sex, race, or national origin.

A school’s curriculum qualifies for the religious curriculum exemption only if its coursework or required activities spread or instill particular religious values.

Equal Employment Opportunity Commission v. Kamehameha Schools/bishop Estate · filed 1993-05-10(e)(2)

The statute does not define “propagate” or “curriculum,” but in the context of § 2000e-2(e)(2) and in light of their ordinary meanings, “propagate” carries at least the general meaning of spreading or instilling particular religious values, while “curriculum” is limited to coursework and required school activities.

Section 2000e-2(e) exempts a qualifying religious college from a religious discrimination claim based on its choice to employ people whose beliefs align with the college’s.

Wirth v. College of the Ozarks · filed 1998-08-26(e)

Therefore, the College of the Ozarks is exempt from Plaintiffs Title VII and MHRA claims for religious discrimination. Count IV must be dismissed.

Section 2000e-2(e)(2) exempts a college from Title VII’s prohibition on religious discrimination when a religious corporation substantially owns, supports, controls, or manages it.

Hall v. Baptist Mem Health · filed 2000-06-13(e)(2)

The College qualifies for the exemption under the plain language of § 2000e-2(e)(2) because it is a “school, college, university, or other educational institution or institution of learning . . . [that] . . . is, in whole, or in substantial part, owned, supported, controlled, or managed by a . . . religious corporation.”

Section 2000e-2(a)(1) prohibits an employer from denying health coverage for medically necessary surgery because of an employee’s sex.

Fletcher v. The State of Alaska · filed 2020-03-06(a)(1)

That is discrimination because of sex and makes defendant’s formal policy, as expressed in the provisions of AlaskaCare, facially discriminatory.

Section 2000e-2(a)(1) prohibits sex discrimination in employer-paid medical insurance premiums.

Taylor v. Franklin Drapery Co., Inc. · filed 1977-12-01(a)(1)

Based upon all the evidence, it is the Court’s finding that defendant corporation, in determining whether to pay the employee portion of a given employee’s medical insurance premium, did in fact discriminate on the basis of sex.

Section 2000e-2(a)(1) prohibits an employer from giving male employees less comprehensive spousal health coverage by limiting pregnancy benefits for their wives.

Newport News Shipbuilding & Dry Dock Co. v. Equal Employment Opportunity Commission · filed 1983-06-20(a)(1)

The 1978 Act makes clear that it is discriminatory to treat pregnancy-related conditions less favorably than other medical conditions. Thus petitioner's plan unlawfully gives married male employees a benefit package for their dependents that is less inclusive than the dependency coverage provided to married female employees.

Section 2000e-2(a)(1) permits different pregnancy coverage for an employee and an employee’s spouse when the difference follows gender-neutral coverage terms.

Hillesland v. Paccar, Inc. · filed 1986-07-16(a)(1)

We read that note to state that an employer's health plan may treat the pregnancy of a male employe's spouse differently from the pregnancy of a female employe only if the disparity results from a gender-neutral difference in the terms of coverages.

Section 2000e-2(a)(1) prohibits sex discrimination in health insurance benefits offered because of a former employee’s employment, including a conversion policy that excludes pregnancy coverage.

Equal Employment Opportunity Commission v. South Dakota Wheat Growers Ass'n · filed 1988-03-11(a)(1)

Therefore, even though Jungers had been discharged, the conversion policy was offered as a result of his employee status, and any discrimination resulting from the policy is an unlawful employment practice.

Section 2000e-2(a)(1) does not require an employer to cover contraception when its health plan excludes contraception used by both men and women.

Standridge v. Union Pacific Railroad · filed 2007-03-15(a)(1)

The proper comparator is the provision of the medical benefit in question, contraception. Union Pacific’s health plans do not cover any contraception used by women such as birth control, sponges, diaphragms, intrauterine devices or tubal ligations or any contraception used by men such as condoms and vasectomies. Therefore, the coverage provided to women is not less favorable than that provided to men. Thus, there is no violation of Title VII.

Section 2000e-2 covers discrimination in employee health insurance benefits.

Boyden v. Conlin · filed 2018-09-18(a)(1)

Employee-sponsored benefits, like health insurance at issue in this case, are part of an employee's wages and benefits for purposes of asserting an anti-discrimination claim.

Section 2000e-2(a)(1) covers health insurance benefits as employment compensation, and federal law determines whether a benefit qualifies.

KADEL v. FOLWELL · filed 2022-06-10(a)(1)

Whether a benefit is “compensation” under Title VII is a question of federal law, not state law.

Section 2000e-2(a)(1) bars an employer from denying health benefits because of transgender status, even when the exclusion affects only some treatments.

LANGE v. HOUSTON COUNTY, GEORGIA · filed 2022-06-02(a)(1)

Denying healthcare coverage “because of” sex unquestionably violates Title VII because those benefits are “compensation, terms, conditions, or privileges of employment” under the Act. ... Title VII does not exempt “partial” violations.

Federal law determines whether an employee benefit counts as compensation under Title VII.

KADEL v. FOLWELL · filed 2022-08-10(a)(1)

Whether a benefit is “compensation” under Title VII is a question of federal law, not state law.

Section 2000e-2(a) and (d) do not cover post-discharge blacklisting that is neither discriminatory nor an employment practice.

Ferguson v. Mobil Oil Corp. · filed 1978-01-24(a), (d)

Plaintiff here does not allege in his complaint that the “blacklisting” is itself an act of discrimination against him on the part of Mobil. Nor can such activity fit within the terms of Section 703(a) or (d) of Title VII, 42 U.S.C. 2000e-2(a), (d); see note 5 in the margin.

Section 2000e-2(a)(1) does not apply to claims brought by federal-sector employees.

HILDEBRAND v. UNITED STATES DEPARTMENT OF DEFENSE · filed 2025-06-12(a)(1)

Accordingly, § 2000e-2(a)(1) does not apply to claims brought by federal-sector employees.

Section 2000e-2(a) does not govern sex discrimination claims against the United States because the United States is excluded from Title VII’s definition of employer.

Byer v. Wilkie · filed 2019-10-02(a)

Although both parties refer the court to 42 U.S.C. § 2000e-2(a), which declares that “[i]t shall be unlawful for an employer ... to ... discriminate against any individual with respect to his compensation, terms, conditions, or privileges of employment, because of such individual’s ... sex,” the United States is not an ... “employer” as defined by the Act.

Section 2000e-2(a) supplies the discrimination standards for federal employees’ Title VII claims.

Hill v. United States Postal Service · filed 1981-09-03(a)

The standards applicable to section 717 claims are found in 42 U.S.C. § 2000e-2(a), which provides in pertinent part: ... Upon consideration of the merits of plaintiff’s claims, however, the Court concludes that plaintiff has failed to prove a discreet violation of Title VII much less the continuing violation he has alleged.

Section 2000e-2 does not provide a separate remedy for alleged discrimination in federal employment because section 2000e-16 is the exclusive remedy.

Benjamin SCOTT, Plaintiff-Appellant, v. Lowell W. PERRY, Director Equal Employment Opportunity Commission, Defendant-App · filed 1978-02-03

He claimed to be the victim of discrimination in favor of Mexican-American and American-Indian applicants, and he sought relief pursuant to the Fifth Amendment; 42 U.S.C. §§ 1981, 1982, and 1983; 42 U.S.C. § 2000e-2(a) and (j); and 42 U.S.C. § 2000e-16. ... The district judge dismissed the complaint insofar as it rested upon any basis other than 42 U.S.C. § 2000e-16 because of the decision in Brown v. General Services Administration, 425 U.S. 820, 96 S.Ct. 1961, 48 L.Ed.2d 402 (1976), which held that section 2000e-16 is the exclusive remedy for discriminatory federal employment practices. This ruling was unquestionably correct and we affirm it.

Section 2000e-2(a)(1) does not apply to federal agencies.

George, Diane v. Leavitt, Michael · filed 2005-05-17(a)(1)

Title VII makes it “an unlawful employment practice for an employer . . . to discharge any individual, or otherwise to discriminate against any individual with respect to his compensation, terms, conditions, or privileges of employment, because of such individual’s race, color, religion, sex, or national origin.” 42 U.S.C. § 2000e-2(a)(1). Although this provision does not apply to federal agencies, see id. § 2000e(b) (defining “employer”), Title VII contains a separate provision that does.

Section 2000e-2(a) does not support a Title VII interference claim against the federal government.

Eghbali v. Department of Energy at Savannah River National Lab · filed 2015-03-02(a)

Accordingly, the court ACCEPTS the Magistrate Judge’s Report and Recommendation and incorporates it by reference. ... Moreover, the basis for an interference claim is 42 U.S.C. § 2000e-2(a), which does not apply to the federal government.

Section 2000e-2 does not cover employment discrimination claims by federal employees; they must bring Title VII claims under § 2000e-16.

Moore v. Nielsen · filed 2019-07-03

However, the United States is excluded from the definition of “employer” for purposes of Section 2000e-2. 42 U.S.C. § 2000e(b). Former federal employees such as plaintiff must bring Title VII claims pursuant to 42 U.S.C. § 2000e-16, not 42 U.S.C. § 2000e-2.

Section 2000e-2 is a private-sector provision that does not apply to federal employees.

Huff v. Buttigieg · filed 2022-07-28

Compare 42 U.S.C. §§ 2000e-2, 2000e-3, with id. § 2000e-16. By express design, the private-sector provisions do not apply to federal employees; rather, they govern “employer[s],” a term that “does not include … the United States.” Id. § 2000e.

A claim under § 2000e-2 for religious discrimination in federal employment does not permit a parallel RFRA claim because Title VII supplies the exclusive remedy.

Maki v. Federal Reserve Bank of Minneapolis · filed 2025-05-21

It makes no difference whether Mr. Maki seeks recovery under the 1964 Civil Rights Act or the 1972 amendment—either way, he seeks relief under Title VII for his federal employment discrimination claim. Like the action in Harrell, Mr. Maki’s “claims under RFRA are barred because Title VII provides the exclusive remedy for his claims of religious discrimination.” Harrell, 638 F.3d at 984.

Section 2000e-2 requires a court to decide whether a hiring decision was discriminatory without deferring to a college’s finding merely because substantial evidence supports it.

Lightfoot v. Board of Trustees of Prince George's Community College · filed 1978-07-28(a)(1)

For these reasons, the defendant community college’s argument that in Title VII cases the findings and decision of academic administrative bodies are to be upheld if supported by substantial evidence is rejected.

Section 2000e-2(a)(1) permits an employer to choose the better-qualified applicant when the decision is made without regard to sex.

Danzl v. North St. Paul-Maplewood-Oakdale Independent School District No. 622 · filed 1983-05-04(a)(1)

Unremarkably, the school district hired the candidate with superior experience and superior references. Although this may not comport with the district court's view of how hiring practices should compensate for years of underrepresentation of women in educational administration, it does not violate Title VII. The employer is free to choose the best candidate for the position without regard to sex.

Section 2000e-2(a)(1) covers race-based changes to job duties and other conditions of employment even without an ultimate employment decision.

Brown v. Rio Petroleum Inc · filed 2001-04-16(a)(1)

Brown’s allegations that her job duties were reassigned in a discriminatory manner and that she was denied the same use of the telephone for personal calls allowed to non-African-American employees, taken as a whole, state a viable Title VII claim of discrimination with regard to the conditions of her employment.

Section 2000e-2(a)(1) covers race-based differences in discipline and leave even when the resulting harm is minimal.

Nealey v. University Health Services, Inc. · filed 2000-06-21(a)(1)

Even if the harm she suffered from such conduct was, as Defendant asserts, de minimis, that does not negate the fact that an employer’s decisions to discipline and grant leave clearly implicate an employee’s “terms, conditions, or privileges of employment.”

Section 2000e-2(a)(1) covers sex-based changes to an employee’s conditions or privileges of employment beyond termination.

Hott v. VDO Yazaki Corp. · filed 1996-04-02(a)(1)

The court notes that the plain language of § 2000e-2(a)(l) speaks in terms of “compensation, terms, conditions, or privileges of employment.” Thus, a Title VII claim requires the court to consider a broad spectrum of circumstances to determine whether the plaintiffs “conditions” or “privileges” of employment were affected by the alleged sexual harassment.

Denial of severance pay is not an adverse employment action under § 2000e-2(a)(1) unless severance is a benefit normally offered to employees.

Zelewski v. American Federal Savings Bank · filed 1993-01-26(a)(1)

Plaintiff’s failure to receive severance payments does not constitute an adverse employment action unless such payments were a benefit normally offered to bank employees.

Section 2000e-2(a)(1) prohibits requiring a female employee to wear a revealing uniform when the employer knows it subjects her to sexual harassment at work.

Equal Employment Opportunity Commission v. Sage Realty Corp. · filed 1981-01-29(a)(1)

Sage and Monahan Cleaners required Hasselman to wear, as a condition of her employment, a uniform that was revealing and sexually provocative and could reasonably be expected to subject her to sexual harassment when worn on the job — and a uniform that Sage and Monahan Cleaners knew did subject her to such harassment.

Section 2000e-2(a) permits a claim based on discriminatory reinstatement after Title VII began covering state employers, even when the earlier pregnancy-related discharge was outside its coverage.

Stacy v. Michigan Employment Security Commission · filed 1980-11-13(a)

When plaintiff resumed employment after having given birth, and after the amendment to Title VII making its provisions applicable to her employer, the original discriminatory termination although not itself a violation of Title VII at the time of the discharge, was in a sense revived and was incorporated in the employer’s allegedly discriminatory reinstatement policy or practice in August of 1972. ... Consequently, based on the reasons set forth above, defendant MCSC’s motion to dismiss is denied.

Section 2000e-2(a) prohibits an employer from imposing harsher discipline on employees because of race than on similarly situated employees of other races.

Mosley v. General Motors Corp. · filed 1980-09-30(a)

Plaintiffs initially assert that the discipline imposed was much harsher than that imposed upon similarly situated whites, in violation of § 703(a) of Title VII, 42 U.S.C. § 2000e-2(a). ... In the instant situation, therefore, to dispel this inference, General Motors must articulate a legitimate, non-discriminatory reason as to why the discipline imposed was harsher than that imposed on similarly situated whites, not just as to why discipline was imposed.

Section 2000e-2(a) permits a sex discrimination claim when an employer imposes a term or condition of employment because of sex.

Equal Employment Opportunity Commission v. Sage Realty Corp. · filed 1980-06-06(a)

In order to state a claim under section 703, 42 U.S.C. § 2000e-2(a), a plaintiff must establish that a term or condition of employment had been imposed and that this term or condition was imposed by the employer on the basis of sex. ... Plaintiffs here have either established the elements required to make a prima facie showing of a section 703 violation or, at a minimum, raised factual questions with respect to these elements which preclude summary judgment.

Section 2000e-2(a) prohibits excluding employees from work assignments because of sex when privacy can be protected without that exclusion.

Forts v. Ward · filed 1980-05-08(a)

We simply conclude that in the circumstances of this case the remedy proposed by the State will accord adequate protection to the privacy interests of the inmates by means that will avoid any denial of the guards’ rights to equal employment opportunities. Since that is so, it is important for the employment opportunities of both sexes that the portion of the District Court’s remedy requiring unjustified gender-based discrimination be set aside.

Section 2000e-2(a) covers a sex-based transfer that substantially changes an employee’s work and adversely affects employment status, even without a loss of pay or benefits.

Rodriguez v. Board of Education of Eastchester Union Free School District · filed 1980-05-02(a)

This radical change in the nature of the work Dr. Rodriguez was called upon to perform constitutes interference with a condition or privilege of employment adversely affecting her status within the meaning of the statute.

Section 2000e-2(a)(1) prohibits sex discrimination in physical working conditions, including access to offices, toilets, and showers.

Harrington v. Vandalia-Butler Board of Education · filed 1978-10-27(a)(1)

We reject the Board’s claim that Section 703(a)(1) of Title VII and its reference to “terms, conditions, or privileges of employment” was not intended to reach the actual working conditions of employees but rather was intended to be confined to the obligation to provide an equal opportunity for employment apart from the physical conditions thereof.

Section 2000e-2(a)(1) prohibits sex discrimination through unequal enforcement of workplace rules.

Chescheir v. Liberty Mutual Insurance Company · filed 1983-09-06(a)(1)

This provision applies not only to the more blatant forms of discrimination, but also to subtler forms, such as discriminatory enforcement of work rules.

Section 2000e-2(a)(2) covers account assignments that affect employment opportunities when they are made on the basis of gender.

Rossini v. Ogilvy & Mather, Inc. · filed 1984-11-13(a)(2)

Since account assignments in the account management department unquestionably were related to employment opportunity, the court must look at .the challenged assignments not to determine why they were made, but rather to determine whether they were made on the basis of gender.

Section 2000e-2(a)(1) prohibits removing an employee from a work shift primarily because of her sex.

Ahia v. Hawaii Protective Ass'n · filed 1984-12-12(a)(1)

For the foregoing reasons, the Court finds that HPA’s removal of plaintiff from the night shift primarily on the basis of sex constitutes a violation of § 703(a)(1).

An isolated difference in work assignments does not necessarily establish sex discrimination in employment conditions under Title VII.

O'COnnOr v. Peru State College · filed 1986-01-02

We cannot find that the district court clearly erred in failing to characterize this one possible isolated incident as a sexually discriminatory employment condition.

Section 2000e-2(a)(1) protects teachers’ seniority rights in school assignments as privileges of employment.

Vaughns v. Board of Education of Prince George's County · filed 1990-07-13(a)(1)

Under the employment system in Prince George’s County, teachers acquire greater privileges as they gain seniority within the school system, including a superior right to remain at a school at which the teacher is assigned against that of a less senior teacher. Those provisions are among the “terms, conditions, or privileges of employment” protected by Title VII.

Section 2000e-2(a)(1) applies the same standard of proof to sex discrimination in working conditions as to discrimination in hiring.

Sischo-Nownejad v. Merced Community College District · filed 1991-06-13(a)(1)

We reject this premise. Title VII and the Age Discrimination in Employment Act do not suggest that different standards exist for proving discrimination in hiring versus proving discrimination on the job.

Section 2000e-2(a)(1) prohibits denying an employee a privilege of employment for discriminatory reasons even if the employee’s salary remains unchanged.

Brady v. DiBiaggio · filed 1992-05-06(a)(1)

However, notwithstanding that her reappointment to the position may have been nothing more than a privilege of which she could have been deprived for no reason at all, she could not be deprived of the privilege for prohibited, discriminatory reasons. This is true even though her salary may have remained the same after she was denied reappointment.

Section 2000e-2(a)(1) covers discriminatory employment conditions that cause psychological harm, even without economic or tangible harm.

Villines v. United Brotherhood of Carpenters & Joiners of America · filed 1998-03-31(a)(1)

As made clear in Meritor, the language "terms, conditions, or privilege” is not limited to economic or tangible discrimination and may include psychological harm.

Section 2000e-2(a)(1) covers discriminatory denial of overtime pay and staffing assistance as discrimination in the terms and conditions of employment.

Austin v. Ford Models, Inc. · filed 1998-07-16(a)(1)

Title VII and the ADEA protect against discrimination with respect to the “terms” and “conditions” of employment. 42 U.S.C. § 2000e-2(a)(1); 29 U.S.C. § 623(a)(1). Austin’s allegations that discrimination motivated Ford’s denial to her of overtime pay and of additional staffing are cognizable under these statutes.

A substantially heavier workload assigned because of sex can support a discrimination claim under § 2000e-2(a)(1).

Taylor v. Metropolitan Water Reclamation District of Greater Chicago · filed 2020-03-30(a)(1)

However, it is unnecessary for the Court to consider each action independently, because the first action identified by Plaintiff—being given a substantially heavier workload than her male co-workers because she was a woman—is sufficient to allow Plaintiff’s Title VII discrimination claim to go forward.

Section 2000e-2(a)(1) covers discriminatory employment references about former employees because they affect conditions of past employment and privileges of prospective employment.

Shehadeh v. Chesapeake and Potomac Telephone Company of Maryland · filed 1978-11-08(a)(1)

When that benefit is denied on grounds of sex or national origin, the employee has been “aggrieved” within the contemplation of Title VII. Discriminatory treatment in employment referencing thus implicates “conditions” of past employment as well as “privileges of [prospective] employment.”

Section 2000e-2(a) can cover discriminatory negative references given after employment when they deny a former employee a privilege of employment.

Soni v. Wespiser · filed 2017-03-03(a)

Considering the general scope of the legislative intent of Title VII to secure equal access to the workplace, the provision of negative information by Dr. Counihan to CMC and Baystate concerning Dr. Soni can reasonably be inferred from the facts in the complaint to be discriminatory acts that denied her a privilege of employment.

Section 2000e-2(a)(1) does not treat discrimination by a co-worker acting in an individual capacity as an unlawful employment practice.

Silver v. Kca, Inc. · filed 1978-11-13(a)(1)

A co-employee, acting in an individual capacity, is incapable of committing an unlawful employment practice.

Section 2000e-2(a)(1) does not impose Title VII liability on a non-supervisory employee for harassing a coworker.

Guyette v. Stauffer Chemical Co. · filed 1981-07-23(a)(1)

Nevertheless, while a non-supervisory employee who harasses a fellow employee may effectively block access to employment, it would stretch the meaning of the term “employer” too far to bring such an employee within its coverage. I conclude, therefore, that if defendant Meszaros is a non-supervisory employee of Stauffer, he is not subject to liability under Title VII.

Section 2000e-2(b) does not cover a state employment agency’s denial of unemployment compensation benefits.

Greene v. Johns Hopkins University · filed 1979-04-11(b)

Secondly, the Employment Security Administration, a state agency, cannot be sued under Title VII for its decision to deny the plaintiff unemployment compensation benefits. ... Therefore, the Court dismisses the plaintiff’s Title VII claim as improperly brought against all the defendants because of his failure to satisfy jurisdictional prerequisites and improvidently brought against the ESA because his claim is not cognizable under the language of the statute.

Section 2000e-2 applies the same employment discrimination standards to public and private employers.

Price v. Civil Service Commission · filed 1980-01-25

Furthermore, the suggestion that title VII imposes different standards on public employers than on private employers clearly lacks merit.

Section 2000e-2(a) applies to discriminatory employment practices by governmental agencies.

Snow v. Nevada Department of Prisons · filed 1984-01-30(a)

Governmental agencies are included within the definition of “person” against whom remedies may be imposed for unlawful (discriminatory) employment practices. 42 U.S.C. § 2000e-2(a).

Section 2000e-2 prohibits employers and unions from religious discrimination, including when enforcing a union security agreement despite the NLRA.

Nottelson v. A.O. Smith Corp. · filed 1980-04-18

Consequently, this Court must conclude that Title VII applies in the present case. ... Under 42 U.S.C. §§ 2000e-2(a) and (b), (c), it is unlawful for a union or an employer to discriminate against an employee on the basis of religion.

Section 2000e-2(c) prohibits a union from causing an employer to discriminate against an employee because of religion, including by seeking discharge without attempting reasonable accommodation.

McDaniel v. Essex International, Inc. · filed 1982-12-14(c)

The union was in violation of Title VII in seeking “to cause or attempt to cause an employer to discriminate against an individual” employee on account of her religious beliefs. 42 U.S.C. § 2000e-2(c).

A union discrimination claim requires some evidence that discriminatory animus motivated the union’s failure to pursue a grievance.

Johnson v. Teamsters Local 653 · filed 2020-08-17

To plead a discrimination claim against a Union, Mr. Johnson must establish a prima facie case asserting that 1) he is a member of a protected class; 2) the Union failed to pursue a grievance on his behalf, and 3) there is some evidence that the Union was motivated by discriminatory animus.

Section 2000e-2(a) does not prohibit an English-only workplace rule as national-origin discrimination when a fully bilingual employee can comply with it but deliberately chooses not to.

Hector GARCIA, Etc., Plaintiff-Appellant, v. Alton v. W. GLOOR Et Al., Defendants-Appellees · filed 1980-05-22(a)

We hold only that an employer’s rule forbidding a bilingual employee to speak anything but English in public areas while on the job is not discrimination based on national origin as applied to a person who is fully capable of speaking English and chooses not to do so in deliberate disregard of his employer’s rule.

Section 2000e-2(a) requires close scrutiny of English-only workplace rules because they generally have an adverse impact on protected groups.

Gutierrez v. Municipal Court of the Southeast Judicial District · filed 1988-01-27(a)

We agree that English-only rules generally have an adverse impact on protected groups and that they should be closely scrutinized.

Section 2000e-2(a) requires an employer to justify a limited English-only workplace rule that adversely affects a protected group by business necessity.

Gutierrez v. Municipal Court of the Southeast Judicial District · filed 1988-04-22(a)

The business necessity requirement prevents an employer from imposing a rule that has a disparate impact on groups protected by the national origin provision of Title VII unless there is a sufficient justification under the Civil Rights Act of 1964 for doing so. Accordingly we adopt the EEOC's business necessity test as the proper standard for determining the validity of limited English-only rules.

Section 2000e-2(a) does not prohibit a workplace English-only rule as national origin discrimination against a bilingual employee who can readily comply with it.

Kania v. Archdiocese of Philadelphia · filed 1998-07-28(a)

Because she could have readily complied with the English-only rule, it did not cause a legally cognizable adverse impact upon the terms and conditions of her employment.

Section 2000e-2(a)(1) prohibits a blanket rule barring employees from speaking languages other than English on an employer’s premises, except when speaking to a non-English speaking customer.

Equal Employment Opportunity Commission v. Premier Operator Services, Inc. · filed 2000-09-13(a)(1)

A blanket policy or practice prohibiting the speaking of a language other than English on an employer’s premises at all times, except when speaking to a non-English speaking customer, violates Title VII’s prohibition against discrimination based on national origin.

An English-only workplace rule does not establish a prima facie national-origin disparate-impact claim without evidence that it adversely affected employees.

EEOC v. Wynell Inc · filed 2004-03-24(a)(1)

... we must conclude after a review of the record in this case that the E.E.O.C. failed to make a prima facie showing of disparate impact because A & B's English-only rule did not have any adverse impact, significant or otherwise, on the Hispanic employees who spoke Spanish, in spite of the sign's mandate to only speak English.

Section 2000e-2 requires a plaintiff challenging an English-only workplace rule as national-origin discrimination to show a connection between language and national origin.

Equal Employment Opportunity Commission v. Beauty Enterprises, Inc. · filed 2005-03-23(a)(1)

Also, because language-based discrimination is not per se unlawful, EEOC must prove that language is connected to national origin.

Section 2000e-2(k)(1)(A)(i) permits a rule requiring sales employees to speak English in customers’ presence when the rule is job related and justified by business necessity.

Equal Employment Opportunity Commission v. Sephora USA, LLC · filed 2005-09-13(k)(1)(A)(i)

Furthermore, just as courts have upheld a business necessity for a rule mandating that bilingual employees speak English in the workplace to stem hostility between employees, promoting politeness to customers is a valid business necessity for requiring sales employees to speak English in their presence. ... We therefore conclude that the English language policy set forth in the Recap is job related for Sephora consultants and cashiers, and is consistent with business necessity.

A rule requiring employees to speak English while working does not, by itself, establish discrimination under § 2000e-2.

Navarrete v. Nike, Inc. · filed 2009-06-10

Her claim that Nike’s policy requiring employees to speak English while working cannot alone establish discrimination, see Garcia v. Spun Steak Co., 998 F.2d 1480, 1488-89 (9th Cir.1993), and her other allegations of harassment based on race, color, and national origin are unsupported by the record.

Section 2000e-2(k)(1)(A)(i) requires evidence of disparate impact; an English-only policy alone does not necessarily establish a prima facie claim.

Reyes v. Pharma Chemie, Inc. · filed 2012-09-11(k)(1)(A)(i)

This Court agrees with the Ninth Circuit’s conclusion that the guidelines contravene the text of Title VII and are not owed deference as an interpretation of the statute. But the Court also agrees with the position of the Tenth Circuit, and finds that the language policy itself, and the circumstances of its adoption, are relevant in assessing whether Reyes has created an issue of fact on her discrimination claim. To summarize: plaintiffs challenging an English-only policy under Title VII will not necessarily be able to make out a prima facie case (under any theory) based solely on the presence of an English-only policy.

Unequal enforcement of an English-only workplace rule can support a disparate treatment claim under § 2000e-2(a)(1) when it plausibly suggests discriminatory intent.

Killeen v. Braithwaite · filed 2020-07-14(a)(1)

Therefore, accepting all these factual allegations as true, and drawing all reasonable inferences in favor of Plaintiff, Plaintiff has stated a claim for disparate treatment under Title VII.

Section 2000e-2(a)(1) requires religious workplace harassment to be based on the employee’s religion; an unpleasant workplace alone is insufficient.

Cook v. Cub Foods, Inc. · filed 2000-06-16(a)(1)

Cook’s workplace may have been unpleasant to him, but unpleasantness does not equate with discrimination. Cook cannot show that he was subjected to discrimination based on religion. He therefore has no Title VII claim.

Section 2000e-2(a)(1) does not treat an employer’s preference for an ordained Methodist minister over a Methodist layperson as discrimination based on religion.

Fike v. United Methodist Children's Home of Va., Inc. · filed 1980-07-07(a)(1)

Though a Methodist layman is, or may be assumed to be, a religious person, and a Methodist minister is, or may be assumed to be, a religious person, the difference between their respective status as layman or minister is not a religious difference. Hence, discrimination based on such difference in status is not discrimination based on religion.

Section 2000e-2(c) prohibits religious discrimination by a union even when it has no collective bargaining agreement with an employer.

Lutcher v. Musicians Union Local 47 · filed 1980-12-08(c)

Title VII imposes the same duty not to discriminate on a union as it does on an employer. ... The addition of a requirement that there be a collective bargaining agreement for the duty to apply to a union would be inconsistent with the liberal construction to be given to a broad, remedial statute.

Section 2000e-2(a)(1) does not treat scheduling a meeting on a religious holiday, by itself, as religious discrimination.

Reichman v. Bureau of Affirmative Action · filed 1982-03-29(a)(1)

Second, scheduling of a meeting on Yom Kippur does not itself constitute religious discrimination.

Section 2000e-2(a)(1) does not prohibit an employer from preferring a minister over a layperson for the minister's administrative experience and church contacts under these circumstances.

Fike v. United Methodist Children's Home of Virginia · filed 1983-06-16(a)(1)

We are not prepared to say that such factor could never give rise to a claim of religious discrimination in violation of Title VII. Under the facts of the immediate case, however, the Home's consideration of Ward's status as a minister as compared to Fike's status as a layman does not present a claim.

Section 2000e-2(a) prohibits firing employees for failing to meet a religious qualification unless an exemption applies.

Amos v. Corporation of the Presiding Bishop of the Church of Jesus Christ of Latter-day Saints · filed 1984-01-11(a)

It is undisputed that the plaintiffs were fired from their employment because they failed to meet religious qualifications imposed by the defendants. Thus, under both federal and state law, the defendants engaged in unlawful discriminatory conduct unless they are exempt from those antidiscrimination provisions.

Section 2000e-2(a) governs claims of discharge from private employment because of religious beliefs.

Stoltzfus v. Ulrich · filed 1984-05-01(a)

In the case at bar, plaintiff’s claim can properly be described as one for unlawful discharge from employment by reason of religious beliefs. Such claims are clearly controlled by 42 U.S.C. § 2000e-2(a), which is directed against unlawful employment practices by private employers.

Section 2000e-2(a)(1) covers religious discrimination in compensation; an employee need not lose a job to make a prima facie case.

Philbrook v. Ansonia Board Of Education · filed 1985-03-07(a)(1)

The district court placed much reliance on the fact that appellant was not forced into a choice between his job and his religious beliefs, but we hold that such a choice cannot be distinguished from the choice here between giving up a portion of his salary and his religious beliefs. While we acknowledge that some courts have stated that discharge was required to make a prima facie showing of discrimination, see, e.g., Brown, 601 F.2d at 959, Title VII prohibits not only discrimination in hiring and firing but also discrimination "with respect to compensation, terms, conditions or privileges."

Section 2000e-2(a)(1) protects an employee’s own religious beliefs; an employer’s religious objection to the employee’s conduct alone does not establish a claim.

McCrory v. Rapides Regional Medical Center · filed 1986-01-27(a)(1)

42 U.S.C. § 2000e-2(a)(l) is couched in terms of an imposition on an individual plaintiff’s religious beliefs, not the employer’s beliefs.

Section 2000e-2(a)(1) requires an employee claiming religious discrimination to show that a bona fide religious belief conflicts with an employment requirement; a leave policy that permits observance of all religious holidays does not create that conflict.

Getz v. Pennsylvania, Department of Public Welfare · filed 1985-12-27(a)(1)

To establish a prima facie case of religious discrimination under § 2000e-2(a)(1), an employee must demonstrate that: 1) he has a bona fide religious belief that conflicts with an employment requirement; 2) he informed his employer about the conflict; 3) that he was discharged or otherwise penalized for failing to comply with the conflicting employment requirement. ... Thus, we conclude that plaintiff has not satisfied the very first requirement in the three part test for establishing a prima facie case of religious discrimination.

A sex discrimination claimant does not establish a prima facie failure-to-hire claim when the available positions are reserved under an EEOC settlement for previously affected applicants and she is outside that group.

Welborn v. Reynolds Metals Co. · filed 1986-02-12(a)

While the evidence clearly shows that she was qualified for the job sought in one sense of the word (that is qualified to do the actual work) the evidence also shows without dispute that in another sense of the word she was not qualified because these job positions at Reynolds Metals Reclamation Plant in March and April 1982 and in subsequent 1982 months were only available to designated and identified females who had previously applied for work there and had been rejected.

Section 2000e-2 prohibits an employer from intentionally excluding employees from a beneficial work opportunity because of their religion.

Abrams v. Baylor College of Medicine · filed 1986-12-08

In light of the record, and the District Court's findings, we must conclude that the college intentionally excluded Jews from its beneficial and educational rotation program at Faisal Hospital. The District Court's finding of intentional discrimination is not clearly erroneous and we uphold it.

Section 2000e-2(a)(1) prohibits firing an employee because of religion, subject to the employer’s duty to reasonably accommodate religious practices without undue hardship.

Drazewski v. Waukegan Development Center · filed 1986-12-12(a)(1)

Title VII prohibits an employer from firing an employee solely on the basis of his religion, 42 U.S.C. § 2000e-2(a)(l), unless the employer can show that “he is unable to reasonably accommodate an employee’s or prospective employee’s religious observation or practice without undue hardship on the conduct of the employer’s business”. 42 U.S.C. § 2000e(j). ... Accordingly, the court finds that both plaintiffs have established a prima facie case of religious discrimination.

A plaintiff alleging religious discrimination in pay retains the burden of persuasion when the employer rebuts weak, equivocal statistical evidence with statistics, other evidence, or both.

Tagatz v. Marquette University · filed 1988-11-16

Certainly in a case such as this where the plaintiff's statistical evidence is weak and equivocal, the defendant can rebut it by casual statistical evidence of its own, by nonstatistical evidence, or by a combination of the two types. Then it is up to the district judge to decide whether the plaintiff has carried his burden of persuasion.

Section 2000e-2(a)(1) permits a religious discrimination claim without a discharge, but the employee must show an adverse effect on employment.

Equal Employment Opportunity Commission v. Patrick Henry Education Ass'n · filed 1990-03-13(a)(1)

Plaintiffs have not been discharged, threatened with discharge, nor suffered any loss of privilege in regards to employment. Union dues were deducted from their paychecks, as it is from all employees. Therefore, they have not been the subject of any discipline for failure to comply with conflicting employment requirements.

Section 2000e-2(a)(1) prohibits discharge because of religion; a religious discrimination claim can survive summary judgment when evidence supports a sincere belief, notice to the employer, and discharge for refusing a conflicting work requirement.

Lambert v. Condor Manufacturing, Inc. · filed 1991-06-20(a)(1)

Title VII forbids the discharge of any employee on the basis of religion. 42 U.S.C. § 2000e-2(a)(l). ... Plaintiff, in this Court’s opinion, has set out a sufficient prima facie case to withstand this motion for summary judgment. He has alleged that his refusal to work on the machine by the pictures was based on a sincere religious belief. He has stated that he informed management that he objected to the pictures on religious grounds, and that he was terminated for refusing to work on the machine.

Section 2000e-2(a) prohibits discrimination in employment privileges when an employer requires an employee to use accrued vacation to avoid mandatory Sabbath work while other employees retain that benefit.

Gwendolyn I. Cooper v. Oak Rubber Company and John Doe, Supervisor · filed 1994-02-09(a)

An employer who permits an employee to avoid mandatory Sabbath work only by using accrued vacation does not “reasonably accommodate” the employee’s religious beliefs. Such an employee stands to lose a benefit, vacation time, enjoyed by all other employees who do not share the same religious conflict, and is thus discriminated against with respect to a privilege of employment.

For a prima facie claim of religious discriminatory termination, the plaintiff must show that someone outside her protected class replaced her or that a comparable employee outside it was retained.

Klein v. Derwinski · filed 1994-10-28(a)

In plaintiffs complaint, she alleges religious discrimination in violation of Title VII of the Civil Rights Act, as amended. 42 U.S.C. §§ 2000e-2(a), 2000e-16(a). ... Lacking this fourth element, plaintiffs complaint does not meet the criteria for a prima facie case of employment discrimination based on religion.

Section 2000e-2(e)(2) exempts a college substantially supported, controlled, or managed by a religion from Title VII’s prohibition on religious discrimination in employment.

Siegel v. Truett-McConnell College, Inc. · filed 1994-11-03(e)(2)

For the above stated reasons, the court finds that Truett-McConnell College qualifies for the religious exemption found in 42 U.S.C. § 2000e-2(e)(2). Truett-McConnell College is in substantial part supported, controlled and managed by the Georgia Baptist Convention and other Baptist religious organizations.

Section 2000e-2(a)(1) prohibits discharge because of religion; a worker establishes a prima facie case by showing a sincere belief that conflicts with a work requirement, notice of the conflict, and discipline or discharge for failing to comply.

Cowan v. A.C. Gilless, Sheriff · filed 1996-03-29(a)(1)

Title VII makes it unlawful for an employer to discharge an employee because of the employee's religion. 42 U.S.C. § 2000e-2(a)(1). Cowan established a prima facie case of discrimination by showing that: (1) she holds a sincere religious belief that conflicts with an employment requirement; (2) she informed the employee about this conflict; and (3) she was discharged or disciplined for failing to comply with the conflicting employment requirement.

Section 2000e-2(a)(1) prohibits an employer from discharging an employee because of her religion; evidence that the employer’s stated reason was pretextual can support a verdict for the employee.

Tincher v. Wal-Mart · filed 1996-05-31(a)(1)

While there is no evidence upon which a jury could find that defendant Wal-Mart failed to reasonably accommodate the religious preferences of the plaintiff, there is sufficient evidence to prove that defendant Wal-Mart Stores, . Inc., was guilty of violating Title VII by terminating the plaintiff because, of her religious practices.

Section 2000e-2(a) requires an adverse employment action for a religious discrimination claim; an employee who resigns must show constructive discharge.

Johnson v. Kmart Corp. · filed 1996-09-11(a)

Section 2000e-2(a) of Title VII prohibits covered employers from taking adverse employment decisions against employees based on their religious views. ... Because plaintiff cannot show constructive discharge and, consequently, cannot establish a prima facie case of religious discrimination under Title VII, Defendants Kmart, Lewis, and Kuhlman are entitled to summary judgment under Fed.R.Civ.P. 56(c).

Section 2000e-2 prohibits refusing to hire someone because of religion; an applicant’s choice to send her children to parochial school does not, by itself, establish religious discrimination.

Joyce Brooks Janes v. Bardstown City Schools Board of Education · filed 1996-09-20(a)(1)

Title VII makes it unlawful for an employer "to fail or refuse to hire ... any individual ... because of such individual's ... religion...." 42 U.S.C. § 2000e-2. ... Nor is there any evidence that Mrs. Janes individually was discriminated against because of her Catholic faith. Accepting the affidavits presented by Mrs. Janes at face value, they tend to show only that Bardstown school system excluded her from consideration because she sent her children to school elsewhere--not because she is a Catholic.

A religious discharge claim requires proof that the employer knew of the employee’s religious beliefs.

Van Koten v. Family Health Management, Inc. · filed 1997-01-10(a)(1)

Therefore, there is no genuine issue of material fact regarding Defendants’ knowledge of Plaintiffs Wiccian religion. The knowledge requirement is an essential element of Plaintiffs prima facie case.

A religious discrimination claim requires the employee to inform the employer that a religious belief conflicts with an employment requirement.

Spencer v. North American Salt · filed 1997-01-15(a)(1)

However, Mr. Spencer failed to show that he informed the company of a connection between his religious beliefs and his failure to wear goggles during the work day. The district court properly entered summary judgment on the religious discrimination claim.

Section 2000e-2(a)(1) permits a religious discrimination claim when an employee is fired for not sharing an employer’s religious beliefs, without requiring the employee to request an accommodation.

Venters v. City of Delphi and Larry Ives · filed 1997-08-19(a)(1)

We agree with our colleagues in the Tenth Circuit that the accommodation framework on which the district court relied has no application when the employee alleges that he was fired because he did not share or follow his employer’s religious beliefs.

Section 2000e-2(a) prohibits religious discrimination in employment, but an employer’s response to an employee’s agitated behavior is not religious discrimination merely because the behavior included religious language.

Miller v. Champaign Community Unit School District · filed 1997-12-22(a)

The fact that Miller at times manifested agitation and paranoia through mutterings about God and the devil is not enough to make a religious discrimination claim under Title VII. Title VII prohibits employment discrimination based on an employee’s “race, color, religion, sex, or national origin.” 42 U.S.C. § 2000e-2(a). Miller alleges that the decision to require him to undergo a psychiatric examination was improperly motivated by his religion. The uncontested facts listed above show that Miller intertwined religious rhetoric into his agitated and paranoid behavior. The uncontested facts do not show that the school district reacted to Miller’s religious expressions in a discriminatory manner.

Section 2000e-2(a) prohibits religious discrimination in employment, but an employer is entitled to summary judgment when the employee cannot raise a genuine dispute that its nondiscriminatory reason was pretextual.

Lee v. Wise Cnty School Bd · filed 1998-01-12(a)

We hold that the school board has provided an adequate reason for its failure to rehire and that Lee has failed to create a triable dispute over whether that reason is pretextual.

A religious discrimination claim cannot survive summary judgment when the employee fails to raise a genuine factual dispute that the employer's legitimate reason for discharge was a pretext for discrimination.

Van Koten v. Family Health Management, Inc., and Chiromed Physicians, P.C. · filed 1998-02-06(a)(1)

The record contains sufficient information for this court to assume that a prima facie case had been made, and affirm the district court's judgment because Van Koten failed to raise a genuine issue of material fact that the legitimate nondiscriminatory reason given for his discharge was a pretext for religious discrimination.

Section 2000e-2(a)(1) requires evidence connecting an employee’s religion to her discharge; her belief alone cannot defeat summary judgment.

Skorup v. Modern Door Corporation · filed 1998-08-26(a)(1)

Skorup has not presented evidence to create a genuine issue of material fact regarding her religious termination claim; the district court properly granted Modern Door’s motion for summary judgment on this claim.

A Title VII religious disparate treatment claim requires facts supporting an inference of discrimination; unsupported allegations cannot survive summary judgment.

Horvath v. Savage Manufacturing, Inc. · filed 1998-09-03

Horvath’s claim is deficient under the third criteria because he has not presented sufficient facts to give rise to an inference of discrimination.

Section 2000e-2(a)(1) prohibits discharge because of religion; an employee cannot prevail on a religious discrimination claim when the employer gives a legitimate, nondiscriminatory reason and the employee fails to prove pretext.

Hall v. Baptist Memorial Health Care Corp. · filed 1998-11-23(a)(1)

Where the Defendant has asserted a legitimate, nondiscriminatory reason for Plaintiffs discharge and Plaintiff has failed to prove pretext, this court must grant Defendant’s motion for summary judgment.

Section 2000e-2(c)(1), read with § 2000e(j), requires a religious discrimination claimant to show a bona fide belief conflicting with an employment requirement, notice of that belief, and discipline for failing to comply.

Eeoc v. Uia · filed 1998-12-17(c)(1)

Section 2000e-2(c)(1) and subsection (j) have established a three-pronged test to determine whether a prima facie case of religious discrimination has been fulfilled: "(1) he or she has a bona fide religious belief that conflicts with an employment requirement; (2) he or she informed the employer of this belief; (3) he or she was disciplined for failure to comply with the conflicting employment requirement." Turpen v. Missouri-Kansas-Texas R.R. Co., 736 F.2d 1022, 1026 (5th Cir.1984). ... All of the elements necessary to establish a prima facie case of discrimination based on religion have been demonstrated by the undisputed facts of the case at bar.

Section 2000e-2(a)(1) requires a plaintiff alleging religious disparate treatment to show circumstances supporting an inference of discrimination; termination alone does not establish that inference.

Kalsi v. New York City Transit Authority · filed 1998-12-22(a)(1)

Notwithstanding the low threshold described above, I agree that plaintiff has failed to cross it and that his disparate treatment claim must therefore be dismissed. ... Rather, he must point to facts that suggest the termination was motivated, at least in part, by religious animus.

A religious discrimination claim under § 2000e-2(a) fails when the employee shows no adverse employment action related to religion.

Speedone v. Revco DS Inc · filed 1999-01-04(a)

We agree with the district court that Speedone failed to establish any adverse employment action taken by Revco that was in any way related to his religious beliefs.

Section 2000e-2(a)(1) permits a religious discrimination claim when an employee alleges that a work requirement conflicts with a religious practice, the employer knew of the conflict, and the employee was penalized for noncompliance.

Sadruddin v. City of Newark · filed 1999-02-11(a)(1)

Haqq has plead allegations which, with their inferences, support a claim of violation of Title VII. He insists that compliance with Order D-5 is contrary to his religion, that he informed Kossup of this conflict and that he was both penalized and discharged for failing to comply with the employment requirement.

Section 2000e-2(a)(1) prohibits denying an employment privilege because an employee’s request is religious; evidence of that motive can defeat summary judgment.

Weilert v. Health Midwest Development Group · filed 2000-04-13(a)(1)

There is a question of fact whether Midwest’s decision not to allow Ms. Weilert to leave early was motivated by discriminatory animus based upon the religious nature of the request. Therefore, summary judgment is not proper.

Section 2000e-2 requires a religious discrimination claimant to show a bona fide religious belief that conflicts with an employment requirement, notice to the employer, and discrimination for failing to comply with the requirement.

Mullen v. Topper's Salon and Health Spa, Inc. · filed 2000-05-12

A prima facie case of religious discrimination consists of: 1) plaintiffs bona fide religious belief in conflict with an employment requirement; 2) plaintiffs informing defendant of the belief; and 3) discrimination for failing to comply with the requirement. ... It does not specify that she advised her employer of the religious nature of the alleged discrimination.

Section 2000e-2(a) requires a religious discrimination plaintiff to allege an adverse employment action to survive a motion to dismiss.

Ali v. Alamo Rent-A-Car, Inc. · filed 2001-03-06(a)

In conclusion, a Title VII plaintiff claiming discrimination on the basis of religion must allege adverse employment action in order to survive a motion to dismiss under Rule 12(b)(6).

Section 2000e-2(a)(1) prohibits discharge because of religion; evidence of supervisors’ religious animus and unequal treatment can create a triable issue of discriminatory motive.

Abraham v. DIAGNOSTIC CENTER HOSP. CORP. OF TEXAS · filed 2001-03-14(a)(1)

The summary judgment record presents genuine issues of disputed fact material to determining whether two supervisors, who allegedly made multiple comments showing religious animus to Abraham, were motivated by this discriminatory animus in deciding to discharge Abraham.

Section 2000e-2(a)(1) does not treat a religiously motivated conduct policy as religious discrimination when the policy neither requires nor inhibits employees’ religious beliefs or practices.

Pedreira v. Kentucky Baptist Homes for Children, Inc. · filed 2001-07-23(a)(1)

The civil rights statutes protect religious freedom, not personal lifestyle choices. There is no religious discrimination in an employment policy which does not require and does not inhibit the practice of or belief in any faith.

Section 2000e-2 prohibits discharge because of religion; the timing of a discharge alone does not establish discrimination without evidence connecting the employee’s religious beliefs to the decision.

Equal Employment Opportunity Commission v. News & Observer Publishing Co. · filed 2001-08-10(a)(1)

The temporal proximity of Wilkins’ firing to the publication of the article is not sufficient to establish pretext without showing some causal connection between the two events. That Wilkins expressed a religious viewpoint and subsequently was terminated is immaterial without evidence that Wilkins’ religious beliefs in some way affected his employment status.

Section 2000e-2(a) protects employees from discrimination for failing to conform to an employer’s religious beliefs or practices, regardless of their own religious affiliation.

Equal Employment Opportunity Commission v. Preferred Management Corp. · filed 2002-09-20(a)

In Instruction No. 4 we informed the jury that “based on religion” and “because of such individual’s religion” included “discriminating against an employee because of the employee’s religion or because the employee’s religious beliefs or practices fail to conform to the employer’s religious beliefs or practices.”

Section 2000e-2(a)(1) requires evidence that an employee was fired because of religious beliefs, identity, observances, or aversion to religion.

Reed, Melvin D. v. Great Lakes Co Inc · filed 2003-05-30(a)(1)

But there is no indication that Reed was fired because of his religious beliefs, identity, or observances or because of his aversion to religion, to Christianity, or to the Gideons, whatever the case may be (remember that we don’t know anything about his religion or lack of religion).

Section 2000e-2(a)(1) prohibits discharge because of religion; a religious discrimination claim fails without evidence that the employee’s religion caused the discharge.

Frick v. Wells Fargo & Co. · filed 2003-06-23(a)(1)

Title VII of the Civil Rights Act of 1964 makes it an “unlawful employment practice for an employer . . . to discharge any individual, or otherwise to discriminate against any individual with respect to his compensation, terms, conditions, or privileges of employment, because of such individual’s . . . religion.” 42 U.S.C. § 2000e-2(a)(1). ... After reviewing the record, we find no evidence that Mr. Frick’s termination was the result of his religious beliefs.

Section 2000e-2(a)(1) prohibits firing an employee because of religious belief or aversion to religion; an intentional discrimination claim requires evidence that religion motivated the firing.

Reed v. The Great Lakes Companies, Inc. · filed 2003-06-24(a)(1)

But there is no indication that Reed was fired because of his religious beliefs, identity, or observances or because of his aversion to religion, to Christianity, or to the Gideons, whatever the case may be (remember that we don't know anything about his religion or lack of religion). ... Reed has utterly failed to make a prima facie case of intentional religious discrimination.

Section 2000e-2(c) requires a religious disparate treatment claimant suing a labor organization to show more favorable treatment of similarly situated employees or other circumstances supporting an inference of discrimination.

Madsen v. Associated Chino Teachers · filed 2004-04-19(c)

Ms. Madsen’s analysis is flawed for three reasons. (1) it disregards the purpose of the union security laws which guide ACT’s policy, (2) Ms. Madsen has declared that she is not similarly situated to agency fee payers and has requested that she be treated differently, and (3) if Ms. Madsen were allowed to pay only $484.74 to a charity, she would be treated more favorably than other school district employees.

Section 2000e-2(a)(1) prohibits religious discrimination in employment; a claimant must connect her religion to the challenged employment action.

Stover v. Martinez · filed 2004-08-30(a)(1)

Title VII also prohibits an employer from discharging “any individual . . . because of such individual’s . . . religion.” 42 U.S.C. § 2000e-2(a)(1). ... We accept Stover’s assertion that she is Jewish; however, we are unable to conclude that Stover has shown a causal connection between her being Jewish and these adverse employment actions, namely her reassignment to Managing Attorney and her nonassignment to Assistant General Counsel.

Section 2000e-2(a)(1) does not prohibit an employer from denying affinity group status to all groups organized around religious positions when it treats every religious position alike.

Moranski, John W. v. General Motors Inc · filed 2005-12-29(a)(1)

The company’s decision to treat all religious positions alike in its Affinity Group program does not constitute impermissible “discrimination” under Title VII.

Section 2000e-2(a) prohibits religious discrimination in employment; an employee cannot defeat summary judgment after the employer offers a legitimate, nondiscriminatory reason for discharge without raising a genuine factual dispute about pretext.

Barcikowski v. Sun Microsystems, Inc. · filed 2006-02-24(a)

Consequently, Plaintiff has failed to raise a genuine issue of material fact as to pretext, and Defendant is entitled to summary judgment on Plaintiffs second claim for religious discrimination under Title VII.