42 U.S.C. § 2000e-2

Section 2000e-2(h) requires employment tests to be assessed under the standards articulated in Griggs v. Duke Power Company.

Miss Margie Delores Colbert v. H-K Corporation, Inc. · filed 1971-07-08(h)

The district court's decision, 295 F. Supp. 1091, was rendered prior to the Supreme Court's decision in Griggs v. Duke Power Company, 401 U.S. 424, 91 S.Ct. 849, 28 L.Ed.2d 158, wherein the standards governing an employer's use of testing and measuring procedures for employment purposes were articulated. The judgment herein must be vacated and the cause remanded to the district court for further consideration in light of Griggs v. Duke Power Company, supra.

Section 2000e-2(k)(1)(A)(i) makes a promotion test with a disparate racial impact unlawful when the employer fails to show that it is job related and consistent with business necessity.

Johnson v. City of Memphis · filed 2005-02-07(k)(1)(A)(i)

Because Plaintiffs have established a prima facie case of disparate impact, the burden of production shifts to Defendant to show that the test was job related or a business necessity. However, Defendant did not offer any proof that the written test was job related or a business necessity. Therefore, the Court grants Plaintiffs’ motion for summary judgment for the Title VII claim of disparate impact as to the 2000 promotional test.

A municipality’s neutral use of a state promotional exam eligibility list is not a separate discriminatory employment practice under Title VII.

Bishop v. New Jersey · filed 2005-07-22

Thus, Bishop II’s holding necessitates a finding that the City’s use of the exam results is not an act of discrimination.

An employer defending a standardized test with disparate impact must establish job relatedness under the Second Circuit's Guardians test validation standard.

Gulino v. New York State Education Department · filed 2006-08-17(k)(1)(A)(i)

In concluding that the LAST is "job related," the district court declined to apply the standard set forth in Guardians. Gulino II, 96-8414, slip op. at 32-33. Instead the district court found that "the Supreme Court lowered the bar for defendants in disparate impact suits" in Watson v. Fort Worth Bank & Trust, and that, under this allegedly lower standard, the LAST was properly validated. This conclusion was based upon "the coincidence of three factors: (1) the importance given to the ability to write an essay by those education professionals surveyed by NES; (2) the weight of the essay writing portion of the test; and (3) the fact that the majority of plaintiffs would have passed the LAST but for the essay writing portion." Id. (internal citations omitted). This holding was in error. Watson never lowered the bar for defendants; thus, Guardians is still the law in this Circuit.

An employer defending a physical skills test against a disparate impact claim need not conduct a formal validation study under the EEOC Guidelines to meet its burden of showing job relatedness and business necessity.

Livingston v. City of Chicago · filed 2022-04-06(k)(1)(A)(i)

Thus, because the law does not require the City to conduct a formal validation study pursuant to the Guidelines to meet its burden, Dr. Davis’ purported failure to conduct such a study cannot be a basis upon which to exclude his testimony.

Section 2000e-2(a) permits a religious accommodation claim to proceed when an employee plausibly alleges a bona fide religious belief, tells the employer how it conflicts with a job requirement, and suffers adverse treatment because of that conflict.

Ashcroft v. Southern California Permanente Medical Group · filed 2025-04-21(a)

Thus, at this stage in proceedings, Plaintiff sufficiently alleges a bona fide religious belief. ... This evinces a clear conflict between Plaintiff’s religious beliefs, which prohibit vaccination, and Defendant’s vaccine requirement, which mandates it. ... Finally, Plaintiff sufficiently alleges the third element of a failure to accommodate claim, namely that her request was denied and that she was terminated for failing to comply with Defendant’s vaccine requirement, a failure caused by her religious objection to vaccination.

Section 2000e-2(a)(1) requires an employer to reasonably accommodate an employee’s religious needs unless doing so would cause undue hardship to its business.

Dewey v. Reynolds Metals Co. · filed 1969-06-06(a)(1)

Those guidelines are a very reasonable interpretation of the statute, and are hereby adopted as defining the requirement of the statute that an employer not discriminate on the basis of religion. The test set forth is a twofold one: (1) the employer must make reasonable accommodations to the religious needs of its employees; (2) unless such accommodation will cause undue hardship on the conduct of the employer’s business.

Section 2000e-2(a)(1) prohibits discharge because of religion without requiring proof that the employer had a specific purpose to discriminate.

Dewey v. Reynolds Metals Company · filed 1969-07-25(a)(1)

Defendant argues that, in order to be subject to injunctive relief under 42 U.S.C.A. § 2000e-5(g), supra, page 1118, the court must find specific intent or purpose to discriminate against Mr. Dewey. This is not what the statute requires, either for the substantive violation or the imposition of injunctive relief. ... (1) to * * * discharge any individual * * * because of such individual’s * * * religion * 42 U.S.C.A. § 2000e-2(a) (1). ... By this action, defendant has intentionally engaged in an unlawful employment practice within the meaning of the above provision.

Section 2000e-2(a)(1) requires an employer to reasonably accommodate an applicant’s religious practice unless doing so would cause undue hardship.

Reid v. Memphis Publishing Company · filed 1972-10-18(a)(1)

The question then is not whether the Press-Scimitar's rules were intentionally discriminatory as to religion, but rather whether the Press-Scimitar could make "reasonable accommodation" to the religious practices of appellant Reid "without undue hardship." The answer to these questions should, of course, be first given by the District Court and the case will be remanded for that purpose.

Section 2000e-2(a)(1) requires an employer to make reasonable scheduling accommodations for an employee’s religious observances when reasonably practicable.

Shaffield v. Northrop Worldwide Aircraft Services, Inc. · filed 1974-03-21(a)(1)

It is now abundantly clear that the statutory duty of an employer not to discriminate upon grounds of religion includes a duty to make reasonable accommodations to the religious needs of an employee by allowing, whenever reasonably practicable, some latitude in the employee’s work schedule so as to free him for religious observances which his denomination is obliged to honor.

Section 2000e-2(h) indicates that employers and unions need not override a bona fide seniority system to accommodate an employee’s religious observance.

Hardison v. Trans World Airlines · filed 1974-05-15(h)

That section, as we stated in reference to the union’s duty to accommodate, indicates that Congress did not intend that unions or employers be required to take actions that would impinge upon bona fide seniority systems.

Section 2000e-2(a)(1) requires reasonable accommodation of an employee’s religious beliefs unless the accommodation would impose undue hardship.

Yott v. North American Rockwell Corp. · filed 1974-07-25(a)(1)

Thus, we agree with Reid and find that accommodation is required. The question is whether or not North American Rockwell and the Union could make a “reasonable accommodation” to appellant Yott’s religious beliefs “without undue hardship.”

Section 2000e-2(a)(1) prohibits discharging an employee for religious practice, including pastoral duties, when the employer could reasonably accommodate it without undue hardship.

Weitkenaut v. Goodyear Tire & Rubber Company · filed 1974-09-26(a)(1)

It does require employer accommodation where no undue hardship would result to the employer’s business. Absent any genuine hardship to Goodyear, the defendant’s termination of the plaintiff’s employment on June 23, 1969, without reasonable effort to accommodate the plaintiff’s religious commitment, constituted an unlawful employment practice within the proscription of 42 U.S.C. § 2000e-2(a)(1).

Section 2000e-2(a)(1) permits an employer to transfer an employee when accommodating his religious observance in his existing position would cause undue hardship and the employer provides reasonable alternative work.

Dixon v. Omaha Public Power District · filed 1974-10-30(a)(1)

The Court further concludes that the plaintiff was given every reasonable accommodation under the circumstances, both temporary and permanent. He, of course, was not discharged and the record clearly shows that every effort was made by defendant to find employment for plaintiff within the O.P.P.D. which would, without undue hardship, accommodate plaintiff in his religious beliefs.

Section 2000e-2(a)(1) required employers in 1970 to make reasonable efforts to accommodate a job applicant’s religious practices unless accommodation would cause undue hardship.

Jordan v. North Carolina National Bank · filed 1975-03-19(a)(1)

Thus, that part of Title VII passed in 1964 as interpreted by EEOC Regulation 1605.1(b) was in full force in May and June, 1970 when the plaintiff sought employment with NCNB, and the obligations of the parties must be measured by the standards set forth in the 1967 EEOC Regulation 1605.1(b) which were later adopted by Congress in 42 U.S.C. § 2000e(j).

Section 2000e-2(a)(1) requires an employer to make a reasonable accommodation for an employee’s religious observance unless the employer demonstrates undue hardship.

Larry G. HARDISON, Appellant, v. TRANS WORLD AIRLINES, INC., Et Al., Appellees · filed 1975-12-16(a)(1)

29 C.F.R. § 1605.1, which we hold to be consistent with the statute, defines the parameters of the employer’s duty. ... An effort to accommodate the employee’s religious observances must be made. Such accommodation need only be a reasonable one. An accommodation alternative which imposes undue hardship upon the employer’s business is unreasonable and not required. The burden of demonstrating its inability to reasonably accommodate falls upon the employer.

Section 2000e-2 requires an employer to accommodate an employee’s religious observances unless the employer shows that accommodation would cause undue hardship.

Blakely v. Chrysler Corp. · filed 1975-12-31

It is clear that Title VII has been violated by defendant Chrysler Corporation. 42 U.S.C. § 2000e-2. Chrysler Corporation has failed to establish that an accommodation of plaintiff's religious beliefs would have constituted an undue hardship so as to relieve defendant of the duty of accommodation.

Section 2000e-2(a) requires an employer to reasonably accommodate an employee’s religious practices unless doing so would cause undue hardship to its business.

Williams v. Southern Union Gas Co. · filed 1976-01-21(a)

42 U.S.C. § 2000e-2(a) provides that it is an unlawful employment practice for an employer to discriminate against an employee because of his religion. ... Under the applicable statute and regulations the question before the trial court was whether Southern Union demonstrated that it was unable to reasonably accommodate to Williams’ religious practice without undue hardship in the conduct of its business. ... The trial court’s findings in the instant case are not clearly erroneous and are supported by the record. It is on this basis that we affirm.

Section 2000e-2(a)(1) prohibits discharging an employee for religious observance when the employer fails to reasonably accommodate it and cannot prove undue hardship.

John H. DRAPER, Plaintiff-Appellant, v. UNITED STATES PIPE AND FOUNDRY COMPANY, Defendant-Appellee · filed 1976-01-27(a)(1)

We conclude that the Company failed to accommodate Draper’s religious beliefs and has not proved that any such accommodation would have imposed an undue hardship on the conduct of its business. Accordingly, by discharging Draper the Company has discriminated against him on the basis of religion in violation of Title VII.

Section 2000e-2 protects employees whose sincere religious beliefs bar them from financially supporting a union, subject to the duty of reasonable accommodation and the undue hardship limit.

Cooper v. General Dynamics · filed 1976-06-09

Instead, the definition is what may be termed an operative one: all forms and aspects of religion, however eccentric, are protected except those that cannot be, in practice and with honesteffort, reconciled with a businesslike operation. The Civil Rights Act extends to the religious doctrine implicated here.

Section 2000e-2 limits enforcement of union security agreements against employees whose sincere religious objections can be accommodated without undue hardship.

Cooper v. General Dynamics, Convair Aerospace Division · filed 1976-06-09(a)(1)

And indeed we think Congress rather plainly correct in this perception, for neither the passage of the health-care exemption nor the passage and amendment of Title VII precludes or trenches in any direct way upon any employer’s making a union security agreement. He and his union can make any they like and enforce it in the general run of cases — in all except the unusual one where compliance would run counter to a particular employee’s religious conviction, sincerely held, that can be accommodated without undue hardship.

Section 2000e-2 prohibits religious discrimination by employers and labor organizations, but an accommodation is not required when it would impose undue hardship on the union.

Anderson v. General Dynamics Convair Aerospace Division · filed 1977-02-15(a)(1), (c)(3)

It would be anomalous to compel an employer and union to accommodate an employee’s religious beliefs, regardless of hardship, simply because the employer failed to offer the employee any accommodations prior to his termination, regardless of whether, in fact, a reasonable accommodation is available. ... In consideration of the above authorities and the interests of the parties, the Court must conclude that anything less than payment of the equivalent of dues to the Union for charitable purposes would impose an undue hardship on the Union.

Section 2000e-2 permits an employee to seek religious accommodation from a union dues requirement, subject to a showing of undue hardship.

Nottelson v. A. O. Smith Corp. · filed 1976-12-20(a)(1), (a)(2), (c)(1), (c)(2), (c)(3)

This definition must be read in conjunction with 42 U.S.C. § 2000e-2(a)(l), (2), and (c)(1), (2), and (3) which prohibits employers and unions from discriminating against employees on the basis of religion, and prohibits unions from causing or attempting to cause an employer to discriminate against an employee on the basis of his religion. ... But to say that plaintiff has no right to seek an accommodation with respect to his payment of dues, that is to deny the clear import of the act.

Section 2000e-2(c) does not require a union to override employees’ contractual seniority rights to accommodate another employee’s religious observance.

Huston v. Local No. 93, International Union, United Automobile, Aerospace & Agricultural Implement Workers · filed 1977-07-19(c)

The Union had no duty to modify the seniority provisions of the collective bargaining agreement under the facts of this case and its refusal to do so neither constituted discrimination against Huston nor caused such discrimination by GM.

Section 2000e-2(a)(1) does not require an employer to guarantee that a prospective employee will never work on her Sabbath when that demand cannot reasonably be accommodated without undue hardship.

Perry JORDAN, Appellee, v. NORTH CAROLINA NATIONAL BANK, Appellant · filed 1977-12-21(a)(1)

It precludes a determination of fault on the bank's part for, in our view, this demand of Perry Jordan could not be "reasonably" accommodated by her prospective employer at all and certainly not "without undue hardship".

An employer and union must attempt to accommodate an employee’s religious objection to paying union dues and, if unsuccessful, show that reasonable accommodation would cause undue hardship.

McDaniel v. Essex International, Inc., A/K/A Essex Wire, and Lodge 982, International Association of MacHinists an · filed 1978-02-22(a), (c)(3)

The union security provisions of Taft-Hartley do not relieve an employer or a union of the duty of attempting to make reasonable accommodation to the individual religious needs of employees.

Section 2000e-2 requires employers and unions to make good faith efforts to accommodate an employee’s religious beliefs and to prove undue hardship if those efforts fail.

Anderson v. General Dynamics Convair Aerospace Division · filed 1978-09-07

The burden was thereafter upon General Dynamics and the Union to prove that they made good faith efforts to accommodate Anderson’s religious beliefs and, if those efforts were unsuccessful, to demonstrate that they were unable reasonably to accommodate his beliefs without undue hardship.

Section 2000e-2 requires an employer and union to make good faith efforts to accommodate an employee's religious objection to union membership and dues, then prove undue hardship if those efforts fail.

Anderson v. General Dynamics Convair Aerospace Division · filed 1979-01-16(a)(1)

The burden was thereafter upon General Dynamics and the Union to prove that they made good faith efforts to accommodate Anderson's religious beliefs and, if those efforts were unsuccessful, to demonstrate that they were unable reasonably to accommodate his beliefs without undue hardship.

Section 2000e-2(a)(1) prohibits discharging or demoting an employee for religious observance when the employer can reasonably accommodate it without undue hardship.

Padon v. White · filed 1979-02-14(a)(1)

The Supreme Court and the Courts of Appeal have made it clear that an employer has an affirmative obligation under Title VII to attempt to accommodate his operations to his employee’s religious beliefs. ... 1. RSS, in connection with the termination and demotion of Padon, did not make an effort to make reasonable accommodations to Padon’s religious beliefs and practices.

Section 703(a)(1) requires reasonable accommodation of an employee’s religious practices unless the accommodation would cause undue hardship; assigning a small number of applications to another reviewer did not meet that standard.

Haring v. Blumenthal · filed 1979-04-10(a)(1)

The applications for exemption which plaintiff refuses to handle could clearly be processed without undue hardship or burden to the Service, or any significant expense or loss of time, by another reviewer. On this basis, therefore, defendant cannot meet the “undue hardship” test of section 703(a)(1).

Section 2000e-2(a) can require an employer to reasonably accommodate a job applicant's religious observance unless doing so would cause undue hardship.

Minkus v. Metropolitan Sanitary District of Greater Chicago · filed 1979-06-06(a)

Although the Sanitary District's personnel rule requiring simultaneous exams may be a rational guideline for test administration, we are not convinced that it by itself can negate the District's duty to reasonably accommodate the religious practices of job applicants.

An employer cannot establish undue hardship from a religious accommodation by speculating about future costs when the accommodation has already been tried without hardship.

Lehman BROWN, Appellant, v. GENERAL MOTORS CORPORATION, Appellee · filed 1979-08-20(a)(1)

If an employer stands on weak ground when advancing hypothetical hardships in a factual vacuum, then surely his footing is even more precarious when the proposed accommodation has been tried and the postulated hardship did not arise. ... Such speculation is clearly not sufficient to discharge GM’s burden of proving undue hardship.

Section 2000e-2(c) imposes on labor unions the same duty not to discriminate based on religion that the section imposes on employers.

Yott v. North American Rockwell Corp. · filed 1979-08-21(c)

Although Section 701(j) as quoted above does not expressly allow consideration of the hardship a particular accommodation proposal would have on a labor union, Title VII clearly imposes the same duty not to discriminate on a union as it does the employer. Thus, it is not unreasonable to consider the burden on the union.

Section 2000e-2(a)(1) prohibits an employer from discharging employees for religious observance when it can accommodate that observance without undue hardship.

Willey v. Maben Mfg., Inc. · filed 1979-08-22(a)(1)

Although Linley dismissed the notice from his mind, Maben was under a duty to accommodate the religious beliefs of plaintiffs and Linley’s failure to recall the Pepper incident does not excuse Maben or relieve it of the obligation imposed by law.

Section 2000e-2(c) requires a union to make a good faith effort to accommodate an employee’s sincere religious objection to supporting it unless accommodation would cause undue hardship.

Tooley v. Martin-Marietta Corp. · filed 1979-09-27(c)

The union admits that plaintiffs refuse to support it because of their sincere religious beliefs. This establishes a prima facie case of employment discrimination. The union must therefore prove that it made a good faith effort to accommodate plaintiffs’ beliefs and that to accommodate plaintiffs’ beliefs would involve an undue hardship.

Section 2000e-2(a), read with § 2000e(j), requires reasonable accommodation of an employee’s religious practices unless accommodation would impose undue hardship.

Nottelson v. A. O. Smith Corp. · filed 1979-12-10(a)

Proceeding to an analysis of defendants’ attempts at accommodation, 42 U.S.C. § 2000e(j) and section 2000e-2(a) require defendant employer and defendant union to make reasonable accommodation for the religious observances of its employees short of incurring an undue hardship.

Section 2000e-2(a)(1) prohibits discharging an employee for a religious practice when the employer fails to prove that accommodating it would cause undue hardship.

Edwards v. School Bd. of City of Norton, Va. · filed 1980-01-18(a)(1)

Applying the above law to the facts at bar, this court is of the opinion that defendant failed to sustain its burden of proving undue hardship. While sympathetic to defendant’s fears of undue hardship suffered by the students, such a finding cannot be made on mere opinion and speculation. ... It follows that plaintiff was wrongfully discharged from her employment as stated in 42 U.S.C. § 2000e-2(a)(l).

Section 2000e-2(a)(1), together with § 2000e(j), prohibits discharging an employee for religious observance when the employer cannot show that reasonable accommodation would cause undue hardship.

Kendall v. United Air Lines, Inc. · filed 1980-08-25(a)(1)

Plaintiff has established a prima facie case of religious discrimination under Title VII of the Civil Rights Act of 1964, 42 U.S.C. §§ 2000e-2(a) and 2000e(j). ... We therefore conclude that United violated Title VII’s bar on religious discrimination when it discharged Kendall for failing to report to work on his Sabbath.

Section 2000e-2 prohibits a union from demanding, and an employer from carrying out, an employee’s discharge when accommodating her religious practice would cause no undue hardship.

McDaniel v. Essex International, Inc. · filed 1981-03-12

Here, the union’s demand and the company’s discharge clearly violated plaintiff’s rights under Title VII.

Section 2000e-2’s prohibition on religious discrimination requires reasonable accommodation of employees whose faith forbids paying union dues, unless the accommodation causes undue hardship.

Herman O. Tooley, Edward J. Helt and Arnold G. Bakke v. Martin-Marietta Corporation, a Corporation and United Steel Work · filed 1981-06-22(a), (c)

Title VII of the Civil Rights Act of 1964, 42 U.S.C. §§ 2000e-2(a) and 2000e-2(c) (1976), provides that it is an unlawful employment practice for either an employer or a union to discriminate against an individual because of that individual’s “religion.” ... The substituted charity accommodation does not result in preferential treatment between employees. The plaintiffs suffer the same economic loss as the union member employees. The accommodation is reasonable.

Section 2000e-2(a)(1) does not prohibit a discharge arising from a religious scheduling conflict when no reasonable accommodation is possible without undue hardship to the employer.

Rising v. Roadway Express, Inc. · filed 1981-07-15(a)(1)

Although Rising clearly was discharged because his religious practices conflicted with Roadway’s work schedule, I have determined that there was no reasonable manner by which those practices could have been accommodated, without working an undue hardship on Roadway. Consequently, I must conclude that Rising has failed to establish a violation of Title VII, 42 U.S.C. secs; ... 2000e-2(a)(l) and 2000e(j).

Section 2000e-2(a)(1) does not require an employer to accommodate an employee’s religious beliefs by surrendering control of the employee’s essential duties.

Ali v. Southeast Neighborhood House · filed 1981-07-17(a)(1)

Accommodation is not abdication. Title VII cannot and will not be so construed.

Section 2000e-2(a)(1) requires an employer to reasonably accommodate an employee’s religious observance unless doing so would cause undue hardship; the employee must make a good faith effort to use accommodations the employer offers.

Marvin BRENER, Plaintiff-Appellant, v. DIAGNOSTIC CENTER HOSPITAL, Defendant-Appellee · filed 1982-03-22(a)(1)

Although the statutory burden to accommodate rests with the employer, the employee has a correlative duty to make a good faith attempt to satisfy his needs through means offered by the employer. A reasonable accommodation need not be on the employee’s terms only.

Section 2000e-2(a)(1) prohibits discharging an employee for a religious practice when the employer can reasonably accommodate it without undue hardship.

Wangsness v. WATERTOWN SCHOOL DIST. NO. 14-4, ETC. · filed 1982-05-28(a)(1)

For the foregoing reasons, the Court concludes that defendant school district failed to demonstrate that accommodating the religious convictions of Wangsness would result in undue hardship. It follows that Wangsness was unlawfully discharged from his employment in violation of 42 U.S.C. § 2000e-2(a)(l).

An employer’s religious accommodation can violate Section 2000e-2(a)(1) when it imposes more than a de minimis cost and discriminates against other employees.

Kuan v. City of Chicago · filed 1983-05-13(a)(1)

The logical implication is that where plaintiff does allege that his employer’s accommodation involves more than a de minimis cost, that accommodation amounts to religious discrimination within the meaning of Title VII.

An employer may reasonably accommodate an employee’s religious observance without accepting the employee’s proposed alternatives.

Mann v. Milgram Food Stores, Inc. · filed 1984-05-02(a)(1)

Neither the fact that Mann made alternative accommodation suggestions ... nor that Milgram’s did not accept those suggestions establishes that the district court’s findings in this regard are clearly erroneous.

Section 2000e-2(a)(1) requires reasonable accommodation of religious practices, but an employer need not provide an employee's preferred accommodation or spare the employee every cost.

Pinsker v. Joint District Number 28j · filed 1984-05-30(a)(1)

Title VII requires reasonable accommodation. It does not require employers to accommodate the religious practices of an employee in exactly the way the employee would like to be accommodated. Nor does Title VII require employers to accommodate an employee's religious practices in a way that spares the employee any cost whatsoever. ... Defendant's policy, although it may require teachers to take occasional unpaid leave, is not an unreasonable accommodation of teachers' religious practices.

Section 2000e-2 does not require an employer to retain an employee in a position when accommodating the employee’s religious practice in that position would cause undue hardship.

Bhatia v. Chevron U.S.A., Inc. · filed 1984-06-12

We hold that on the facts before us, Chevron has established that retaining Bhatia as a machinist unable to use a respirator safely would cause undue hardship.

Section 2000e-2(a)(1) does not require an employer to violate an otherwise valid seniority agreement to accommodate an employee’s religious observance.

Krushinski v. Roadway Express, Inc. · filed 1985-05-30(a)(1)

Accordingly, since the duty to accommodate does not require an employer to take steps inconsistent with an otherwise valid agreement and in order to accommodate plaintiff the employer would have to violate the union contract, the decision to reject plaintiffs suggestions for accommodation was not improper.

A public employer does not violate § 2000e-2(a)(1) when it makes every reasonably available effort to accommodate an employee’s religious practices while protecting inmates’ religious rights.

Spratt v. County of Kent · filed 1985-11-12(a)(1)

Considering the facts of this case and the constitutional law in the area of religious practice in public institutions, the Court concludes that Sheriff Heffron had very limited flexibility with which to accommodate plaintiffs religious practices. ... The Court concludes that defendant County, acting through Sheriff Heffron, made every effort at accommodation reasonably available under the circumstances. ... Accordingly, plaintiff has not proven a violation of Title VII.

An employer and union reasonably accommodate a religious objection to union membership by allowing the employee to pay the equivalent of dues to a nonreligious charity.

Stern v. Teamsters "General" Local Union No. 200 · filed 1986-01-17

The court therefore finds that the defendants are entitled to summary judgment as a matter of law because even if plaintiff was discharged because of his religious convictions against union membership, the defendants offered him a reasonable accomodation which he refused to take.

Section 2000e-2(a)(1) prohibits firing an employee because of religion, but does not require an accommodation that would impose undue hardship on the employer.

Baz v. Walters · filed 1986-01-28(a)(1)

Title VII forbids an employer from firing an employee solely on the basis of his religion, 42 U.S.C. Sec. 2000e-2(a)(1), unless the employer can demonstrate that "he is unable to reasonably accommodate to an employee's ... religious observation or practice without undue hardship on the conduct of the employer's business," 42 U.S.C. Sec. 2000e(j). ... None of these is an accommodation required by Title VII.

Section 2000e-2(a)(1) does not require an employer to accommodate religious practices by changing its patient-care approach, continually supervising the employee, or allowing conduct it believes harms patients.

Baz v. Walters · filed 1986-01-28(a)(1)

To accommodate Reverend Baz’s religious practices, they would have to either adopt his philosophy of patient care, expend resources on continually checking up on what Reverend Baz was doing or stand by while he practices his (in their view, damaging) ministry in their facility. None of these is an accommodation required by Title VII.

Section 703(a)(1), read with Section 701(j), lets an employer satisfy its religious accommodation duty through an accommodation that eliminates the religious conflict and reasonably preserves the employee’s employment status.

American Postal Workers Union, San Francisco Local Alice Lindstrom Robert Davis v. Postmaster General · filed 1986-01-31(a)(1)

Section 701(j) of Title VII, in conjunction with Section 703(a)(1), requires an employer to accommodate the religious beliefs of an employee in a manner which will reasonably preserve that employee’s employment status, i.e., compensation, terms, conditions, or privileges of employment.

Section 2000e-2(a)(1) does not require an employer to offer a religious accommodation it reasonably believes the employee would refuse based on the employee’s actions.

Betty Lou WISNER, Plaintiff-Appellant, v. TRUCK CENTRAL, a SUBSIDIARY OF SAUNDERS LEASING SYSTEMS, Defendant-Appellee · filed 1986-03-26(a)(1)

Plaintiff suggests that as a matter of law defendant had a duty to demote her against her will rather than discharge her. No caselaw supports this proposition. The concept of accommodation does not require the employer to tender employment arrangements that, based on the employee’s own actions, it reasonably believes will be refused.

An employer’s later reasonable accommodation offer can cure an initially discriminatory refusal to hire when the applicant refuses to cooperate with the offer.

Toledo v. Nobel-Sysco, Inc. · filed 1986-07-02(a)

Nobel’s July 10 reasonable offer cured its March 13 discriminatory decision. Because Toledo refused to negotiate or try to cooperate with Nobel’s accommodation offer, I also conclude that the offer absolves Nobel of liability for that discriminatory decision.

Section 2000e-2(a)(1) prohibits an employer from discharging an employee for religious observance without attempting reasonable accommodation or showing undue hardship.

Boomsma v. Greyhound Food Management, Inc. · filed 1986-07-24(a)(1)

For the reasons discussed above, the Court finds that defendant failed to demonstrate a) that it made reasonable efforts to accommodate plaintiff’s religious beliefs, and/or b) that an accommodation acceptable to plaintiff would have caused it to suffer undue hardship. In sum, defendant failed to meet its statutory burden, and the Court will enter judgment for the plaintiff.

Section 2000e-2(a)(1) requires an employer to consider accommodating an employee’s request never to work on the Sabbath, subject to undue hardship.

Protos v. Volkswagen of America, Inc. · filed 1986-07-29(a)(1)

Consequently, we agree with the district court’s rejection of the argument that an employee’s request for a guarantee of never working on the Sabbath does not invoke the employer’s duty to accommodate.

Section 2000e-2(a) does not require an employer to offer overtime so an employee can preserve vacation leave when a neutral paid-leave policy reasonably accommodates the employee’s religious holidays.

Getz, Susan v. Commonwealth of Pennsylvania, Department of Public Welfare · filed 1986-09-23(a)

Moreover, we are satisfied that the defendant has established a neutral scheduling policy and that there is no conflict between appellant’s employment and the observation of her religious holidays. We are satisfied that under the scheduling system, the Commonwealth has “reasonably accommodated” Getz’s religious observance.

Section 2000e-2(a)(1) does not require an employer to excuse an employee from Sunday overtime when doing so would impose economic costs and affect other employees’ rights under a collective bargaining agreement.

Equal Employment Opportunity Commission v. Chrysler Corp. · filed 1987-02-13(a)(1)

Title VII was enacted by Congress to prohibit, among other things, discrimination by an employer against any individual employee “with respect to his compensation, terms, conditions, or privilege of employment, because of such individual’s ... religion.” 42 U.S.C. § 2000e-2(a)(l). ... In sum, Chrysler’s decision concerning Mr. Karanovich is not discriminatory.

Section 2000e-2(a)(1) prohibits an employer from denying paid leave for religious observance when it provides paid leave for all other purposes.

Ansonia Board of Education v. Philbrook · filed 1986-11-17(a)(1)

But unpaid leave is not a reasonable accommodation when paid leave is provided for all purposes except religious ones.

Section 2000e-2(c), together with Title VII’s definition of religion, requires unions to accommodate religious objections to union membership, including those of employees who do not belong to an organized religion.

Equal Employment Opportunity Commission v. Davey Tree Surgery Co. · filed 1987-04-16(c)

In conjunction with 42 U.S.C. § 2000e-2(c), therefore, it imposes a duty on unions to accommodate persons with religious objections to union membership. ... Thus, Mr. Davidson’s non-membership in the Seventh-Day Adventist Church in no way deprives him of the right to take advantage of the substituted charity accommodation under Title VII.

Section 2000e-2(a)(1) does not require an employer to grant religious leave when the available accommodations would impose undue hardship on its business.

Depriest v. Department of Human Services of the State of Tennessee · filed 1987-10-01(a)(1)

The plaintiff contends that the defendant employer has not shown that it could not reasonably accommodate her religious observances without suffering 'undue hardship' within the meaning of 42 U.S.C. Secs. 2000e-2(a)(1) and 2000e(j) (1976). Because we agree with the district court that the defendant did make the necessary showing of undue hardship, we shall affirm the district court's judgment.

Section 2000e-2(a)(1) requires an employer to reasonably accommodate an employee's religious practice unless the employer proves it cannot do so without undue hardship.

Smith v. Pyro Mining Company · filed 1987-11-18(a)(1)

Once the employee has established a prima facie case, the burden shifts to the employer to prove that it cannot reasonably accommodate the employee without incurring undue hardship.

Section 2000e-2(a)(1) does not require an employer to make other employees work in order to accommodate an employee's Sabbath observance.

Equal Employment Opportunity Commission v. Ithaca Industries, Inc. · filed 1987-11-25(a)(1)

The statute is not to be construed to require an employer to discriminate against some employees in order for others to observe their sabbath.

An employer can satisfy Title VII’s religious accommodation duty by offering a reasonable alternative position without warning that refusal to work the original schedule could lead to discharge.

Mathewson v. Florida Game & Fresh Water Fish Commission · filed 1988-03-24(a)(1)

Accordingly, it is the finding of the Court that the offer of the First Sergeant position to the Plaintiff was an offer of reasonable accommodation, and by this offer the Defendant satisfied the requirements of Title VII.

Section 2000e-2(a)(1) prohibits religious discrimination and requires employers to offer reasonable accommodation for an employee’s religious practice unless doing so would cause undue hardship.

Equal Employment Opportunity Commission v. Ithaca Industries, Inc. · filed 1988-06-08(a)(1)

Section 703(a)(1) of the Civil Rights Act of 1964, Title VII, 42 U.S.C. Sec. 2000e-2(a)(1), makes it an unlawful employment practice for an employer to discriminate against an employee on the basis of his or her religion. ... The Act thus requires that an employer, short of undue hardship, make reasonable accommodations to the religious needs of its employees. It is also clear that the burden is on the employer to offer this accommodation.

Section 2000e-2(a)(1) prohibits an employer from requiring employees to attend devotional services over their religious objections.

Equal Employment Opportunity Commission v. Townley Engineering & Manufacturing Company · filed 1988-09-19(a)(1)

We hold that Congress did clearly intend for Title VII to cover Townley's mandatory devotional services. Sections 701(j) and 703(a) of Title VII make clear that requiring employees over their objections to attend devotional services cannot be reconciled with Title VII's prohibition against religious discrimination.

An employer can reasonably accommodate an employee’s Sabbath observance through a voluntary shift swap program.

Moore v. A.E. Staley Manufacturing Co. · filed 1989-09-26(a)(1)

We agree and find that the system of voluntary swaps instituted by the defendants was a reasonable accommodation.

Section 2000e-2 prohibits refusing to hire an applicant because of a religious practice that the employer could accommodate without undue hardship; a later settlement offer does not cure the violation.

Wilbur Toledo, Plaintiff-Appellant/cross-Appellee v. Nobel-Sysco, Inc., Defendant-Appellee/cross-Appellant · filed 1989-12-29(a)(1)

When Nobel rejected Toledo based solely on his religious practices without an attempt to accommodate him, assuming it could have done so without undue hardship, it committed an illegal act. The settlement offer made in response to the administrative charge could not undo the completed act.

Section 2000e-2(a)(1) prohibits refusing to hire an applicant because of a sincere religious practice when the employer fails to show that accommodation would cause undue hardship.

Equal Employment Opportunity Commission v. Reads, Inc. · filed 1991-03-25(a)(1)

For the above-stated reasons, the Court holds that Moore has met her ultimate burden of proof that she was discriminated against because of her religion in violation of Title VII, 42 U.S.C. § 2000e-2(a)(l). In so holding, the Court finds that READS has not met its burden of producing evidence of undue hardship so as to relieve it of its duty to accommodate Moore.

Section 2000e-2(a) and (c) does not prohibit a limited paid-leave policy administered without discrimination against religious activities.

Philbrook v. Ansonia Board Of Education · filed 1991-01-25(a) and (c)

No showing was made on remand, however, that in doing so, there is any general animus towards activities that are religious in nature or purpose, or that leave is denied for such activities except as specifically provided by the Agreement. Accordingly, no case is made that religious discrimination violative of 42 U.S.C. Sec. 2000e-2(a) and (c) (1988) has occurred.

Section 2000e-2(a)(1) prohibits religious discrimination in discharge, but an employee who refuses to cooperate with an employer’s reasonable accommodation efforts may render accommodation impossible.

Riselay v. Secretary of Health and Human Services · filed 1991-04-02(a)(1)

Because Riselay did not cooperate with his employer in its attempt to accommodate his religious beliefs, he rendered an accommodation impossible. Therefore, the district court correctly concluded that Riselay was not terminated in violation of Title VII.

Section 2000e-2(a)(1) requires an employer to attempt a reasonable accommodation of an employee's religious practice before firing the employee over a scheduling conflict.

EEOC v. Arlington Transit Mix · filed 1991-12-27(a)(1)

At a minimum, Arlington had an obligation to explore a voluntary waiver of seniority rights before terminating Taylor.

An employer must make a reasonable attempt to accommodate an employee’s sincere religious practice, including exploring a voluntary waiver of seniority rights before termination.

Equal Employment Opportunity Commission v. Arlington Transit Mix, Inc. · filed 1991-12-27(a)(1)

At a minimum, Arlington had an obligation to explore a voluntary waiver of seniority rights before terminating Taylor. After failing to pursue this or any other reasonable accommodation, the company is in no position to argue that it was unable to accommodate reasonably his religious needs without undue hardship on the conduct of its business.

Section 2000e-2(c) does not require a union to waive seniority provisions to accommodate an employee's religious practice when doing so would harm other members' contractual rights.

Cook v. Chrysler Corp. · filed 1991-12-31(c)

The Union had no duty to waive or modify the seniority provisions of the local agreement to the detriment of its members. Its refusal to do so neither constituted unlawful discrimination against plaintiff or caused such discrimination by Chrysler.

An optional overtime list and seniority system can provide significant accommodations for employees whose religious observance conflicts with overtime work.

Mann v. Frank · filed 1992-06-10(a)(1)

In this case, I find that not only the seniority system, but the Overtime Desired list provision in the collective bargaining agreement, represent significant accommodations by the Postal Service to plaintiff’s religious needs. First, the option of signing the Overtime Desired list accommodates those employees who, for religious or secular reasons, do not wish to work overtime.

Section 2000e-2(a)(1) requires an employer to accommodate an employee’s religious practice unless accommodation would violate a valid collective bargaining agreement or cause undue hardship.

Carter v. Bruce Oakley, Inc. · filed 1993-03-05(a)(1)

Section 2000e-2(a)(1) requires an employer to accommodate the religious observances of its employees unless such accommodation would contravene the provisions of a valid collective bargaining agreement or would cause the employer undue hardship. ... In summary, the Court holds that the defendant has not demonstrated an undue burden it would have suffered had the plaintiff been allowed to wear his beard in his requested manner.

Section 2000e-2(a)(1) requires an employer to accommodate both an employee’s religious objection to working a shift and a religious objection to finding a replacement for that shift.

U.S. Equal Employment Opportunity Commission v. IBP, Inc. · filed 1993-05-07(a)(1)

The Court finds that IBP was obligated to accommodate Plaintiffs belief that he should not ask another employee to work in his place on Saturday. This additional obligation thus required IBP to “make further efforts” to accommodate Plaintiff, beyond merely “allowing” Plaintiff to seek his own replacement.

Section 2000e-2(a)(1) does not require a county to accommodate prayer and religious witnessing on County time when doing so would compromise its duty of religious neutrality.

Brown v. Polk County, Iowa · filed 1993-08-11(a)(1)

Allowing supervisors and employees to witness and pray on County time would work an undue hardship on the County’s duty of religious neutrality.

Section 2000e-2(a)(1) did not require an employer to accommodate Sabbath absences when doing so would disrupt a neutral seniority system and impose undue hardship.

Blair v. Graham Correctional Center · filed 1993-09-01(a)(1)

Hardison, as we set out above, makes clear that Graham need not abandon its seniority system in order to accommodate the religious preferences of an employee, and, in fact, holds that the seniority system itself represented a "significant accommodation" to the religious needs of employees. 432 U.S. at 78.

Section 2000e-2(a)(1) requires an employer to take an initial step toward reasonably accommodating a conflicting religious practice before the employee must suggest alternatives or compromise.

Jerrold S. HELLER, Plaintiff-Appellant, v. EBB AUTO CO., Dba Ron Tonkin Mitsubishi, Defendant-Appellee · filed 1993-11-05(a)(1)

EBB failed to show that it took an “initial step” towards accommodating Heller’s conflicting religious practice. Heller was therefore under no duty to suggest alternatives or compromise his beliefs. The district court’s conclusion that EBB reasonably accommodated Heller is clearly erroneous.

An employee who refuses to cooperate with an employer's reasonable effort to accommodate her religious beliefs may lose her religious accommodation claim.

Weeden v. Anthony M. Frank, Postmaster General · filed 1994-02-16(a)(1)

Because Weeden did not cooperate with the postal service's attempt to accommodate her religious beliefs by waiving her privacy rights, she rendered an accommodation impossible. Therefore, summary judgment was proper.

When an employer’s efforts do not resolve an employee’s religious conflict, the employer must show that accommodating the employee would cause undue hardship.

Equal Employment Opportunity Commission v. Hanson-Loran Co. · filed 1994-03-25(a)(1)

In this circuit, where the employer's efforts do not remove the employee's religious conflict, the employer must show that it could not have accommodated the employee without "undue hardship."

Section 2000e-2(a) prohibits religious discrimination in employment and requires an employer to explore accommodations for an employee’s religious practices before claiming undue hardship.

Rose M. Benton v. Carded Graphics, Incorporated · filed 1994-06-09(a)

The applicable portion of Title VII of the Civil Rights Act of 1964, 42 U.S.C. Sec. 2000e-2(a), makes it unlawful for an employer to discriminate against an employee on the basis of her religion. ... What the law does require is a thorough exploration of all the alternatives that would meet the employee's religious needs, and the fact-based determination of whether any of those programs could be implemented without a predictably certain undue hardship.

Section 2000e-2(a)(1) does not prohibit discharge for refusing Sabbath work when the employer reasonably accommodates the employee’s religious practice through a neutral rotating shift system and voluntary shift swaps.

Beadle v. Hillsborough County Sheriff's Department · filed 1994-08-23(a)(1)

We find that the Department's attempts to accommodate appellant Beadle's religious practices within the workings of its neutral rotating shift system were "reasonable" for purposes of Title VII. We, therefore, hold that Beadle's discharge from employment with the Department for refusing to work his sabbath was neither discriminatory nor unlawful.

Section 2000e-2(a)(1) prohibits an employer from firing employees for religious observance when it has made no effort to accommodate their practice and cannot show undue hardship.

Equal Employment Opportunity Commission v. Ilona of Hungary, Inc. · filed 1995-04-07(a)(1)

EEOC has demonstrated that Tomilina and Glukhovsky requested a day off for observance of a sincerely held religious practice, that defendant denied their requests without any effort to accommodate their religious practice, and that defendant fired them after they chose to miss work rather than forgo their religious observance.

Section 2000e-2(a)(1) does not require an employer to permit an employee to impose religious views on coworkers when the employer offers a reasonable accommodation.

Wilson v. U.S. West Communications · filed 1995-07-10(a)(1)

U.S. West's proposal allowed Wilson to comply with her vow to wear the button and respected the desire of co-workers not to look at the button. Hence, the district court did not err in holding that U.S. West reasonably accommodated Wilson's religious beliefs.

Section 2000e-2(a)(1) requires an employer’s proposed religious accommodation to resolve the employee’s religious conflict; an accommodation that leaves the conflict unresolved is insufficient.

Vetter v. Farmland Industries, Inc. · filed 1995-10-12(a)(1)

As a matter of law, a proposed accommodation that fails to resolve the employee’s religious conflict, or resolves only part of it while completely ignoring the rest, is insufficient.

An employee seeking religious accommodation must give the employer adequate notice of the conflict between a religious belief and an employment requirement.

Cary v. Carmichael · filed 1995-11-20(a)(1)

The Court holds, however, that the plaintiff has failed to establish the notice element of his prima facie case of religious discrimination under Title VII.

Section 2000e-2(a) imposes liability for religious discrimination when an employer cannot show that accommodating an employee's religious practice would cause undue hardship.

Rourke v. NY STATE DEPT. OF CORRECT. SERVICES · filed 1995-11-27(a)

The initial burden is on the plaintiff to make out a prima facie case of discrimination, and upon making such a showing, the burden shifts to the employer to show that there is no reasonable accommodation that the employer can make without undue hardship. ... For these reasons, the court will grant the plaintiff's motion for partial summary judgment as to liability on plaintiff's Title VII claim.

An employee who establishes a prima facie case of religious discrimination shifts the burden to the employer to show that reasonable accommodation would cause undue hardship.

Rourke v. New York State Department of Correctional Services · filed 1995-11-27(a)

The initial burden is on the plaintiff to make out a prima facie ease of discrimination, and upon making such a showing, the burden shifts to the employer to show that there is no reasonable accommodation that the employer can make without undue hardship. ... For these reasons, the court will grant the plaintiffs motion for partial summary judgment as to liability on plaintiffs Title VII claim.

Section 2000e-2(a) prohibits religious discrimination in discharge, and an employer defending such a claim must show that it offered a reasonable accommodation or that accommodation would cause undue hardship.

Shpargel v. Stage & Co. · filed 1996-01-31(a)

Accordingly, taking the plaintiff’s allegations as true, this court holds that defendants have not demonstrated that they offered a reasonable accommodation to plaintiff.

Once an employee establishes a prima facie claim of religious discrimination, the employer must show that it could not reasonably accommodate the employee without undue hardship.

Favero v. Huntsville Independent School District · filed 1996-08-09(a)(1)

Plaintiffs have shown a prima facie case of religious discrimination. The burden shifts to Huntsville ISD to show that it could not reasonably accommodate plaintiffs, without undue hardship.

Section 2000e-2 prohibits religious discrimination in employment; an alternative job offered as a religious accommodation must be available within a reasonable time.

Equal Employment Opportunity Commission v. United Parcel Service · filed 1996-08-23(a)(1)

If Patel was told there would be a long wait for a nonpublic-contact job, he was not offered a reasonable accommodation, whether or not such a waiting list actually existed.

Section 2000e-2(a)(1) prohibits religious discrimination in hiring when an employer cannot show that reasonable accommodation would cause undue hardship.

Opuku-Boateng v. California · filed 1996-09-19(a)(1)

We conclude that Opuku-Boateng established a prima facie case of religious discrimination and that the State failed to demonstrate that he could not be reasonably accommodated without undue hardship.

Section 2000e-2(a)(1) prohibits religious discrimination; an accommodation is not reasonable if it leaves the conflict between a work requirement and religious practice unresolved.

Equal Employment Opportunity Commission v. Ilona of Hungary, Incorporated · filed 1996-10-02(a)(1)

The only attempt at accommodation made by Ilona here was to offer Tomilina and Glukhovsky a day off from work other than Yom Kippur. The offered accommodation cannot be considered reasonable, however, because it does not eliminate the conflict between the employment requirement and the religious practice.

Section 2000e-2(a)(1) requires reasonable accommodation of an employee’s religious practice unless it would impose undue hardship on the employer’s business.

Banks v. Service America Corp. · filed 1996-11-21(a)(1)

Plaintiffs have demonstrated a triable issue of fact whether Service America, without undue hardship to its business operation and procedures, could reasonably accommodate their religious practice of greeting GM food service customers. Defendant has not shown that the evidence on this issue is so one-sided that Service America must prevail as a matter of law, or that a reasonable jury could not sustain plaintiffs’ claim.

A religious accommodation claim requires the employee to notify the employer that a religious need conflicts with a job requirement and to request accommodation.

Chalmers v. Tulon Co of Richmond · filed 1996-12-04(a)(1)

As Chalmers recognizes, a prima facie case under the accommoda- tion theory requires evidence that she informed her employer that her religious needs conflicted with an employment requirement and asked the employer to accommodate her religious needs.

Section 2000e-2(a)(1) requires a religious accommodation to resolve the conflict between an employee’s religious practice and a work requirement.

Equal Employment Opportunity Commission v. Ilona of Hungary, Incorporated · filed 1997-03-06(a)(1)

The offered accommodation cannot be considered reasonable, however, because it does not eliminate the conflict between the employment requirement and the religious practice.

Section 2000e-2(a)(1) requires a conflict between an employee’s religious belief and an employment requirement for a religious accommodation claim.

Foster v. Intimates · filed 1997-05-22(a)(1)

Foster's religious accommodation claim fails because there was no conflict between his religious belief and an employment requirement.

A religious accommodation claim requires a conflict between an employment requirement and a sincere religious practice; an employer need not accommodate a purely personal preference.

Vetter v. Farmland Ind. · filed 1997-07-16(a)(1)

The jury had the duty to determine whether Farmland's residence requirement interfered with the observance or practice of Vetter's religion or whether he chose to live elsewhere because of a purely personal preference.

An employer does not discriminate because of religion when an employee declines available reasonable accommodations that would eliminate the conflict between work and religious practice.

Rodriguez v. City of Chicago · filed 1997-08-11(a)(1)

The Court concludes that reasonable accommodations were available to Rodriguez that would have eliminated his religious conflict. Rodriguez was aware that these accommodations existed, but chose not to take full advantage of them. Under these circumstances, the Court does not believe that the City was required to formally reiterate these alternatives in response to Rodriguez’s memorandum in order to discharge its obligations under Title VII.

Section 2000e-2(a)(1) requires an employee seeking accommodation for a trip on particular dates to prove that its timing is part of a bona fide religious belief rather than a personal preference.

Tiano v. Dillard Department Stores, Inc. · filed 1998-03-18(a)(1)

In a case such as this, however, where an employee maintains that her religious beliefs require her to attend a particular pilgrimage, she must prove that the temporal mandate was part of the bona fide religious belief. Otherwise, the employer is forced to accommodate the personal preferences of the employee — the timing of the trip. Title VII does not protect secular preferences.

An employer may satisfy Title VII's religious accommodation duty by offering a transfer that resolves the conflict between an employee's duties and beliefs without reducing pay or benefits.

Angelo RODRIGUEZ, Plaintiff-Appellant, v. CITY OF CHICAGO, a Municipal Corporation, Defendant-Appellee · filed 1998-09-21(a)(1)

Because the CBA provided Officer Rodriguez with the option of transferring to a district without an abortion clinic and such a transfer would have eliminated the conflict between his job responsibilities and his religious beliefs, we conclude that the City has satisfied its duty of reasonable accommodation under Title VII.

Section 2000e-2 bars a union from requiring membership when an employee’s sincere religious beliefs prohibit joining and the union has not shown undue hardship from an exemption.

Equal Employment Opportunity Commission v. Union Independiente De La Autoridad De Acueductos Y Alcantarillados De Puerto · filed 1998-12-17(c)(1)

Title VII forbids labor organizations “to exclude or to expel from its membership, or otherwise to discriminate against, any individual because of his ... religion____”42 U.S.C. § 2000e-2(e)(l). ... Thus, UIA cannot insist that Cruz become a union member.

Section 2000e-2(a)(1) does not require an employer to provide a religious accommodation that violates a collective bargaining agreement.

Thomas v. Runyon · filed 1999-01-05(a)(1)

Clearly, nothing in the regulations alters Hardison’s rule that accommodation violative of a collective bargaining agreement constitutes an undue hardship upon the employer.

Section 2000e-2(a)(1) does not require a religious accommodation that would force an employer to violate federal law; that conflict establishes undue hardship.

Kenneth E. Sutton, Jr. v. Providence St. Joseph Medical Center, a California Non-Profit Corporation · filed 1999-09-16(a)(1)

Pursuant to Bhatia, we hold that Defendant established that accommodation would cause “undue hardship” as a matter of law.

An employer’s actual knowledge of an applicant’s religious restriction can satisfy the notice requirement for a religious accommodation claim, even when the applicant did not personally give notice.

Hellinger v. Eckerd Corp. · filed 1999-09-28(a)(1)

It would be hyper-technical, based on the facts of this case, to require notice of the Plaintiffs religious beliefs to come only from the Plaintiff. The notice requirement is meant in part to allow the company an opportunity to attempt to reasonably accommodate the Plaintiffs beliefs. The Defendant was not deprived of the opportunity to attempt to accommodate the Plaintiffs beliefs merely because the notice did not come from the Plaintiff. However, the Court does not place the burden of inquiry on the employer and this decision should not be interpreted to create such a duty.

Section 2000e-2(a)(1) does not require an employer to accommodate an employee’s religious beliefs by changing a neutral dispatch order when doing so may adversely affect coworkers.

Weber v. Roadway Express, Inc. · filed 2000-02-14(a)(1)

The mere possibility of an adverse impact on co-workers as a result of “skipping over” is sufficient to constitute an undue hardship.

Section 2000e-2(a)(1) does not require a religious accommodation that would adversely affect other employees’ schedules and preferences.

Weber v. Roadway Express, Inc · filed 2000-05-01(a)(1)

The mere possibility of an adverse impact on co-workers as a result of “skipping over” is sufficient to constitute an undue hardship.

Under § 2000e-2(a)(1), once an employee establishes a prima facie case of religious discrimination, the employer must show reasonable accommodation or undue hardship.

United States Equal Employment Opportunity Commission v. Bridgestone/Firestone, Inc. · filed 2000-05-17(a)(1)

Once the employee has established a prima facie case of discrimination, the burden shifts to the employer to show either that it reasonably accommodated the religious practice, or that any accommodation would have resulted in undue hardship.

Section 2000e-2(a)(1) requires reasonable accommodation of an employee’s religious beliefs but does not require an employer to displace other employees to provide it.

McIntyre-Handy v. West Telemarketing Corp. · filed 2000-05-19(a)(1)

Imposing on other employees to create an accommodation is not required by Title VII.

A religious accommodation claim requires evidence that an employment requirement conflicts with the employee’s religious beliefs and that the employee informed the employer of the conflict.

Swartzentruber v. Gunite Corp. · filed 2000-05-22(a)(1)

But Mr. Swartzentruber does not present admissible evidence, or even contend without evidence, that being required to cover up his tattoo at work conflicts with his religious beliefs, or that he told Gunite about any conflict with his beliefs and Gun-ite’s demand that he cover his tattoo. Mr. Swartzentruber doesn’t satisfy the first and second elements of a prima facie case.

Section 2000e-2(a)(1) requires a reasonable accommodation of an employee’s religious practice, but does not require the employer to offer the employee’s preferred accommodation.

Durant v. Nynex · filed 2000-06-21(a)(1)

This Court need not determine whether Durant’s proposed alternative accommodation is reasonable, since Title VII only requires that the employer propose a reasonable accommodation and does not require that the employer offer the specific accommodation the employee seeks.

Section 2000e-2(a)(1) permits an employer to satisfy its religious accommodation duty by offering any reasonable accommodation.

Shelton v. University of Medicine & Dentistry of New Jersey · filed 2000-08-10(a)(1)

In short, the employer satisfies its Title VII religious accommodation obligation when it offers any reasonable accommodation.

Section 2000e-2(a)(1) permits an employer to accommodate a religious practice through voluntary shift swaps without violating a valid collective bargaining agreement.

Thomas v. National Ass'n of Letter Carriers · filed 2000-08-30(a)(1)

In the interactive process between employer and employee, the employer here considered every accommodation requested by Thomas and rightfully rejected each as unduly burdensome. In addition, it remained sympathetic to Thomas’s religious requirements, approved all voluntary schedule swaps that Thomas was able to arrange, and imposed no restrictions or impediments on Thomas’s ability to attempt to arrange further voluntary schedule swaps with other employees. This is all that Title VII reasonably requires the Postal Service to do.

An employer need not allow officers to add religious symbols to police uniforms as a religious accommodation when doing so would cause undue hardship.

Daniels v. City of Arlington · filed 2001-04-09(a)(1)

The only accommodation Daniels proposes is unreasonable and an undue hardship for the city as a matter of law. A police department cannot be forced to let individual officers add religious symbols to their official uniforms.

Title VII permits a union to inquire into the sincerity and religious nature of a member’s objection to paying dues before providing a religious accommodation.

Bushouse v. Local Union 2209, United Automobile, Aerospace & Agricultural Implement Workers · filed 2001-10-02(a)(1)

In sum, the court concludes that Title VII does not prohibit the union from making an inquiry into the sincerity of its member’s claim that he or she holds sincere religious beliefs that preclude him or her from funding or participating in a union. Further, the Union’s requirement of independent corroboration as applied in this case did not violate Title VII.

An employer can reasonably accommodate a religious practice by permitting it with coworkers while restricting its use in customer communications after a customer objects.

Anderson, Elizabeth v. USF Logistics IMC · filed 2001-12-14(a)(1)

Thus, we hold that the district court did not err in finding that U.S.F.’s selective enforcement of its company policy was a reasonable accommodation of Anderson’s religious practice.

A labor organization must reasonably accommodate a sincerely held religious practice; evidence disputing sincerity can preclude summary judgment for the claimant.

Equal Employment Opportunity Commission v. Unión Independiente De La Autoridad De Acueductos Y Alcantarillados · filed 2002-02-04(c)(1)

The requirement that the employee have a "bona fide religious belief" is an essential element of a religious accommodation claim. ... We therefore conclude that UIA raised a triable issue of fact, making summary judgment inappropriate.

Section 2000e-2 prohibits refusing to hire someone because of religion, but religious accommodation does not require an employer to violate a valid collective bargaining agreement.

Graff v. Henderson · filed 2002-02-06(a)(1)

As the duty to accommodate does not require the employer to take steps inconsistent with a valid CBA, defendant was not required to provide Mr. Graff with a lateral transfer.

Section 2000e-2(a)(1) does not require a religious accommodation that could interfere with seniority rights under a collective bargaining agreement.

Virts v. Consolidated Freightways Corporation of Delaware · filed 2002-04-04(a)(1)

And so it goes that in the matter at hand, the district court properly found that where any of Plaintiffs proposed accommodations had the ability of violating the collective bargaining agreement by interfering with the seniority system, Defendant was not required to accommodate Plaintiff.

Under § 2000e-2(a), an employee seeking religious accommodation must make a good faith effort to use accommodations the employer proposes.

Equal Employment Opportunity Commission v. Autonation USA Corp. · filed 2002-11-22(a)

Title VII religious discrimination claims are analyzed under a two-part framework under 42 U.S.C. § 2000e-2(a). ... Thompson’s resignation, while discussions regarding potential accommodations were ongoing and in their early stages, violated his correlative duty to make a good faith attempt to satisfy his needs. Accordingly, AutoNation is entitled to summary judgment on the EEOC’s claims.

An employee seeking religious accommodation must bring the religious belief to the employer’s attention; no separate reasonable-notice requirement applies.

Velez-Sotomayor v. Progreso Cash and Carry, Inc. · filed 2003-05-07(a)

First Circuit case law required that Vélez inform Progreso or bring to Progreso’s attention her religious beliefs, but makes no mention of “reasonable notice.”

Section 2000e-2(a)(1) does not treat an employee’s acceptance of another position offered to accommodate his religious practice as a discriminatory demotion or discharge.

Vaughn v. WAFFELE HOUSE, INC. · filed 2003-03-05(a)(1)

Cessation of his position as a district manager and his subsequent acceptance of another position with Waffle House does not constitute either a demotion or discharge for failure to comply with an employment requirement which conflicted with his religious beliefs. As such, the same is not cognizable under Title VII.

A religious accommodation plaintiff establishes a prima facie case by showing a sincere religious belief that conflicts with an employment requirement, notice of the conflict, and an adverse employment decision resulting from it.

O'BRIEN v. City of Springfield · filed 2003-08-12(a)(1)

To establish a prima facie case that the defendants discriminated against the plaintiff on the basis of religion by failing to accommodate him, the plaintiff must show that (1) he sincerely possessed a bona fide religious belief that conflicted with an employment requirement, (2) he informed the defendants of the conflict, and (3) the defendants took an adverse employment decision against him for his failure to fulfill the employment requirement because of his conflicting religious belief.

Section 2000e-2(a) permits an employer to satisfy its duty to accommodate a religious practice by offering a reasonable accommodation, even if the employee rejects it.

Cloutier v. Costco Wholesale · filed 2004-03-30(a)

As will be seen, even if the belief system of the Church of Body Modification is accepted on its own terms, the undisputed facts of record demonstrate that the accommodation offered by Costco, and ultimately rejected by the plaintiff, was reasonable as a matter of law. Given this, the controlling authorities require entry of judgment in favor of the defendant.

Section 2000e-2(a)(1) supports a religious failure to accommodate claim when an employee shows a conflicting religious belief, notice to the employer, and discharge or discipline for failing to meet the conflicting work requirement.

Rice v. U.S.F. Holland, Inc. · filed 2005-07-05(a)(1)

To establish a prima facie case of failure to accommodate, a plaintiff must demonstrate that: (1) he had a bona fide religious belief that conflicted with an employment requirement; (2) he informed his employer about the belief and the conflict; and (3) he was discharged or disciplined for failing to comply with the conflicting employment requirement. ... Plaintiff Rice is able to establish a prima facie case.

An employer does not reasonably accommodate a religious practice that bars all Sunday work by offering a later Sunday shift.

Baker v. The Home Depot, Docket No. 05-1069-Cv · filed 2006-04-19(a)(1)

Although we are constrained to vacate the judgment of the District Court because of the inadequacy of the offer of shift change on Sundays as an accommodation, we express here no opinion as to whether Home Depot’s offer of part-time employment or its allowance of the exchange of shifts with other employees would constitute reasonable accommodations.

Section 2000e-2(a)(1) prohibits religious discrimination in discharge; an employer defending a failure to accommodate must show a reasonable accommodation or undue hardship.

Equal Employment Opportunity Commission v. Alamo Rent-A-Car LLC · filed 2006-05-26(a)(1)

Alamo has not presented genuine issues of material fact concerning either EEOC’s prima facie case of religious discrimination or Alamo’s burden to show that it offered to reasonably accommodate Ms. Nur’s religious beliefs or that it could not accommodate those beliefs without undue hardship. Summary judgment has been granted in favor of EEOC on the question of liability.