42 U.S.C. § 2000e-2

A religious accommodation claim against a labor union fails when the employee shows no materially adverse employment action from the challenged accommodation.

Reed v. International Union · filed 2009-05-07(c)(1)

Because Reed has not shown any material adverse employment action, much less discharge or discipline, his religious accommodation claim fails.

A religious accommodation claim against a union fails when the employee shows no materially adverse employment action; a greater charity payment under the accommodation alone does not suffice.

Reed v. International Union, United Automobile, Aerospace & Agricultural Implement Workers · filed 2009-06-23(c)(1)

Because Reed has not shown any material adverse employment action, much less discharge or discipline, his religious accommodation claim fails.

Section 2000e-2(a) requires an employee seeking a religious accommodation to inform the employer that a work requirement conflicts with her religious practice.

Laney v. Ohio Department of Youth Services · filed 2010-06-10(a)

Because Laney cannot show that she informed ODYS that she needed an accommodation in order to be permitted to wear her head scarf, she cannot establish a prima facie case of religious discrimination.

Section 2000e-2(a) does not allow an employer to treat a proposed substitute for an employee’s sincere religious practice as a reasonable accommodation without evidence that it would meet the employee’s religious need.

Equal Employment Opportunity Commission v. Geo Group, Inc. · filed 2010-08-02(a)

We are unwilling to delve into any matters of theology, and will therefore decline GEO’s invitation to decide on our own what might constitute a reasonable substitute for a khimar under the Islamic faith.

An employer does not reasonably accommodate a religious practice that prohibits Saturday work by merely offering fewer Saturday shifts.

Crider v. University of Tennessee · filed 2012-07-23(a)(1)

Offering Crider fewer Saturday shifts is not a reasonable accommodation to religious beliefs which prohibit working on Saturdays.

Section 2000e-2(a)(1) does not require an employer to accommodate an employee’s religious practice when the accommodation would impose undue hardship on its business.

Equal Employment Opportunity Commission v. Rent-A-Center, Inc. · filed 2013-01-18(a)(1)

The Court will not require RAC to undertake the accommodation. Leaving the store without a Store Manager on Saturdays would cause an “undue hardship” to RAC by “impair[ing] [critical] functions”—it would deprive the store of the significant supervisory, managerial, customer-care and other functions that RAC Store Managers are charged with at the very time when these functions are most needed.

Employers must reasonably accommodate employees’ religious beliefs and practices unless doing so would cause undue hardship.

Wareham v. Dollar Bank · filed 2013-03-29(a)(1)

Under Title VII, employers are required to make reasonable accommodations for the religious beliefs and practices of their employees, unless doing so would result in “undue hardship” to the employer.

Once an employee makes a prima facie religious accommodation claim, the employer must show that it reasonably accommodated the employee or could not do so without undue hardship.

Antoine v. First Student, Incorporated · filed 2013-04-10(a)(1)

If the plaintiff can satisfy the prima facie showing, the burden shifts to the defendant to demonstrate either that it reasonably accommodated the employee, or that it was unable to reasonably accommodate the employee’s needs without undue hardship.

Section 2000e-2(a)(1) does not require an employer to grant a religious accommodation that would impose an undue hardship.

Slocum v. Devezin · filed 2013-06-03(a)(1)

For the reasons stated above, Plaintiff has failed to make allegations to sustain a cause of action for religious discrimination under Title VII of the Civil Rights Act of 1964, because there is no reasonable accommodation Defendants’ could afford Plaintiff that would not subject them to an undue hardship.

Section 2000e-2(a)(1) prohibits employment discrimination based on religion, including a failure to accommodate religious needs when accommodation is required.

Equal Employment Opportunity Commission v. 704 HTL Operating, LLC · filed 2013-09-06(a)(1)

While Defendants’ bare assertion, without more, is insufficient to convince the Court that all of Plaintiffs religious discrimination claims should be assessed under the same standard, because Plaintiff does not dispute the applicable standard — and because the Court finds, in any event, that a material factual dispute exists as to whether Defendants failed to accommodate Plaintiffs religious needs — the Court finds for purposes of the instant motion only that the “failure to accommodate” standard applies to each of Plaintiffs religious discrimination claims.

A religious accommodation claimant must first establish a prima facie case before the employer bears a burden to respond.

U.S. Equal Employment Opportunity Commission v. Abercrombie & Fitch Stores, Inc. · filed 2013-09-03(a)(1)

The Ninth Circuit applies a two-part framework to analyze Title VII religious accommodation claims. A plaintiff must first establish a prima facie case.

Section 2000e-2(a)(1) does not require an employer to accommodate a religious practice by violating another law.

Tagore v. USA · filed 2013-11-13(a)(1)

An employer need not accommodate an employee’s religous practice by violating other laws.

For a religious accommodation claim under § 2000e-2(a)(1), an employee’s practice need not be a formal religious tenet if she sincerely believes it is religious.

Davis v. Fort Bend County · filed 2014-08-26(a)(1)

We disagree with Fort Bend and the district court. Neither addresses whether Davis’s religious belief was sincere and, instead, both improperly focus upon the nature of the activity itself. A showing of sincerity, however, does not require proof that the July 3rd church event was in itself a true religious tenet, but only that Davis sincerely believed it to be religious in her own scheme of things.

A religious accommodation claim requires a sincere belief that conflicts with a job requirement, notice of the conflict to the employer, and discipline for failing to comply with the requirement.

Mathis v. Christian Heating & Air Conditioning, Inc. · filed 2014-10-08(a)(1)

To establish a prima facie case of failure to accommodate under Title VII, plaintiff must show that: (1) he holds a sincere religious belief that conflicts with a job requirement; (2) he informed his employer of the conflict; and (3) he was disciplined for failing to comply with the conflicting requirement.

Section 2000e-2(a)(1) requires employers to reasonably accommodate employees’ religious practices unless doing so would cause undue hardship.

Equal Employment Opportunity Commission v. JetStream Ground Services, Inc. · filed 2015-09-29(a)(1)

Accordingly, an employer violates Section 2000e-2(a)(1) when it does not make reasonable accommodations, short of undue hardship, for the religious practice of employees.

Section 2000e-2(a)(1) allows an employer to meet its religious accommodation duty by offering shift swaps and permitting use of leave and attendance benefits to address scheduling conflicts.

Wimbish v. Nextel West Corp. · filed 2016-03-29(a)(1)

The Court finds that, as a matter of law, by offering to approve shift swaps with other co-workers, coupled with Sprint’s willingness to allow Ms. Wimbish to use other employee benefits, including accrued leave and attendance points, to account for shifts for which no swap could be arranged, Sprint offered Ms. Wimbish a reasonable accommodation.

A religious accommodation claim requires a conflict between a religious practice and an employment requirement; a neutral procedure for requesting religious leave does not itself create that conflict.

Abeles v. Metropolitan Washington Airports Auth. · filed 2017-01-26(a)(1)

Regarding Jewish holidays, however, no conflict existed between Plaintiff observing religious holidays and following MWAA’s neutral rules requiring advance approval of leave following specified procedures. Nor could she establish such a conflict. The Leave Policy merely requires employees to request leave by form or email, and obtain advance approval.

Section 2000e-2(a)(1) requires an employer to accommodate a sincerely held religious belief that conflicts with a work requirement, absent undue hardship.

U.S. Equal Employment Opportunity Commission v. Consol Energy, Inc. · filed 2017-06-12(a)(1)

So long as there is sufficient evidence that Butcher’s beliefs are sincerely held – which the jury specifically found, and Consol does not dispute – and conflict with Consol’s employment requirement, that is the end of the matter.

Requiring an employee to use vacation days to avoid work that conflicts with religious observance does not constitute an adverse employment action for a religious accommodation claim.

Chavis v. Wal-Mart Stores, Inc. · filed 2017-07-18(a)(1)

This argument fails as a matter of law because requiring an employee to use vacation days to avoid work conflicting with the employee’s religious observance does not constitute an adverse employment action.

Section 2000e-2(a)(1) supports a claim when an employer fails to reasonably accommodate an employee’s religious beliefs.

Mohamed v. 1st Class Staffing, LLC · filed 2017-12-14(a)(1)

Courts thus have recognized, as a variant of a religious discrimination claim, a cause of action for an employer's failure to reasonably accommodate an employee's religious beliefs.

An employer can satisfy its duty to accommodate an employee’s Sabbath observance by allowing the employee to arrange shift swaps with willing coworkers.

Patterson v. Walgreen Co. · filed 2018-03-09(a)(1)

Walgreens met its obligations under Title VII by allowing Patterson to arrange a schedule swap with other employees when they were willing to do so.

Section 2000e-2(a)(1) allows an employer to accommodate an employee’s religious practice by offering other work that removes a conflict with that practice.

Bobby Walker, Jr. v. Indian River Transport Co. · filed 2018-07-27(a)(1)

In sum, we conclude that Indian River offered Walker a reasonable accommodation by removing him from the milk route and offering him other routes because doing so eliminated the possibility of mandatory Sunday work.

Section 2000e-2(a)(1) provides a disparate treatment claim to an unsuccessful job applicant for failure to reasonably accommodate a religious practice.

Equal Emp't Opportunity Comm'n v. N. Mem'l Health Care · filed 2018-11-13(a)(1)

After she made the request and no mutually acceptable accommodation was reached, Sure-Ondara’s Title VII remedy as an unsuccessful job applicant was a disparate treatment claim under § 2000e-2(a) for failure to reasonably accommodate.

A religious accommodation claim requires the employee to show that the religious practice was the basis for discharge or other discriminatory treatment.

Mahran v. Advocate Christ Medical Center · filed 2019-09-16(a)(1)

But Mahran’s claim fails because a reasonable juror could not find that Mahran suffered any adverse action for praying during his breaks.

A religious accommodation claim requires a religious belief that conflicts with a job requirement; sincere opposition to vaccination alone is insufficient.

Niaja Brown v. Childrens Hospital of Philadel · filed 2020-02-14

Nothing in Brown’s second amended complaint suggests that her opposition to the flu vaccine was religious.

An employer may fail to reasonably accommodate an employee’s religious practice when it bars the employee from attempting to use an existing shift-swapping policy.

Logan v. Organic Harvest LLC · filed 2020-04-01(a)(1)

Even if an offer to remove a Sabbath-Keeper from fewer than all Saturday shifts could be a reasonable accommodation in some cases, the plaintiff in this case at least has raised a genuine issue of material fact as to whether the defendant fulfilled its obligation to reasonably accommodate him by coming forward with evidence the defendant had a shift-swapping policy it did not permit him even to attempt to use.

Section 2000e-2(a)(1) prohibits denying employees reasonable religious accommodations and discharging them because of their religion.

U.S. Equal Employment Opportunity Commission v. Aviation Port Services, LLC · filed 2020-04-01(a)(1)

Defendant therefore denied the six individuals reasonable accommodations and discharged then because of their religion in violation of § 703.

Section 2000e-2(a) prohibits religious discrimination, and an employer meets the religious accommodation requirement by offering a reasonable way to resolve a conflict between work and religious practice.

SHERROD v. ALLISON TRANSMISSION, INC. · filed 2021-03-29(a)

The Court finds that Allison met its burden of showing that it made a reasonable accommodation for Sherrod's sincerely held Seventh Day Adventist beliefs.

An employer that offers a reasonable accommodation for an employee’s religious practice need not offer the employee’s preferred accommodation or show that the preferred option would cause undue hardship.

Bailey v. Metro Ambulance Services, Inc. · filed 2021-04-06(a)(1)

The employer has no further obligation to offer an employee’s preferred accommodation or to demonstrate that an employee’s preferred accommodation would cause an undue hardship.

A salary reduction for refusing training that conflicts with a bona fide religious belief can establish a prima facie religious accommodation claim; whether accommodation would cause undue hardship may be a question for the jury.

Brennan v. Deluxe Corporation · filed 2021-05-27(a)(1)

In particular, Brennan has established a prima facie case for failure to accommodate based on the imposition of a one percent salary reduction, but there is a dispute of material fact as to whether Deluxe would have been subject to undue hardship in order to accommodate Brennan’s religious beliefs.

Section 2000e-2(a)(1), read with § 2000e(j), allows a religious accommodation claim to proceed when the employee alleges its necessary elements and undue hardship requires a factual inquiry.

HASHMI v. CITY OF JERSEY CITY · filed 2021-09-07(a)(1)

Officer Hashmi alleges the necessary elements of his failure-to-accommodate claim, so the Court will not dismiss it.

Title VII permits a religious accommodation that lets an employee continue working without violating a vaccination requirement; it does not require a blanket exemption.

We the Patriots USA, Inc. v. Hochul Dr. A. v. Hochul · filed 2021-11-04(a)(1)

Section 2.61 does not require employers to violate Title VII because, although it bars an employer from granting a religious exemption from the vaccination requirement, it does not prevent employees from seeking a religious accommodation allowing them to continue working consistent with the Rule, while avoiding the vaccination requirement.

Section 2000e-2(a)(1) requires an adverse employment action for a religious accommodation claim; denial of a prayer break alone is insufficient.

Mahran v. Roseland Community Hospital · filed 2022-01-18(a)(1)

That is a textual explanation for why claims of religious accommodation under Title VII require an adverse employment action, while claims for reasonable accommodation under the ADA do not.

Section 2000e-2(a)(1) does not require an employer to accommodate an employee’s preference to attend a religious event when attendance is not based on a bona fide religious belief.

Hittle v. City of Stockton · filed 2022-03-02(a)(1)

Put simply, the evidence shows Plaintiff’s attendance at the Global Leadership Summit was based on his preference, not a bona fide religious belief.

Section 2000e-2(a)(1) prohibits religious discrimination, including an employer’s failure to accommodate religious practice when the employer cannot establish undue hardship.

Sutton v. DirectTV LLC · filed 2022-03-16(a)(1)

DIRECTV’s bald assertion of undue hardship cannot be reconciled with this evidence.

Section 2000e-2(a) permits distinct claims for religious discrimination and failure to accommodate religious beliefs, even when both involve the same accommodation request.

Grooms v. Walden Security · filed 2022-03-29(a)

These counts present clearly distinct claims and are not duplicative of one another. Accordingly, Defendant’s request to dismiss Count I as duplicative of Count II will be denied.

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

Groff v. DeJoy · filed 2022-05-25(a)(1)

Thus, a legally sufficient accommodation under Title VII’s religious discrimination provision is one that eliminates the conflict between the religious practice and the job requirement.

A religious-accommodation discharge claim requires proof that the employer fired the employee because of a religious observance, practice, or belief.

Equal Employment Opportunity Commission v. Kroger Limited Partnership I · filed 2022-06-23(a)(1)

Those prongs are essentially a stand-in for the statutorily-required showing that the employer fired an employee “because of” any aspect of the employee’s religious observance, practice, or belief.

Section 2000e-2(a)(1) does not require a religious accommodation when an employee has an option that does not conflict with her religious observances.

Egelkrout, Jo Anne v. Aspirus, Inc. · filed 2022-07-20(a)(1)

Having acknowledged that she was given an alternative that did not conflict with her religious observances, plaintiff has pled her way out of the first element of her claim.

Section 2000e-2 requires employers to reasonably accommodate religious practices unless doing so would impose undue hardship.

Richards v. Walden Security · filed 2022-07-20(a)(1)

Accordingly, genuine issues of material fact exist as to whether Walden’s accommodation was reasonable and whether Plaintiff’s requested accommodation would impose undue hardship on Walden.

Section 2000e-2(a)(1) does not require an employer to accommodate a religious belief when doing so would violate federal law.

Truskey v. Vilsack · filed 2022-08-19(a)(1)

Circuit precedent forecloses the merits of this argument; an employer cannot be required to intentionally violate a federal regulation—and subject itself to potential penalties—in order to accommodate an employee’s religious belief. Because Defendant cannot be found liable for a Title VII violation for complying with federal law, we find that the district court did not err in dismissing the amended complaint.

Section 2000e-2(a)(1) prohibits religious discrimination in employment, including a failure to accommodate an employee’s religious beliefs.

McCarter v. UT-Battelle LLC · filed 2022-08-24(a)(1)

Under Title VII, an employer may not “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 an individual’s religion. ... The Court finds that Plaintiff has not established a prima facie case of religious discrimination for failing to accommodate.

A religious accommodation imposes undue hardship under Title VII when granting it would require the employer to violate state law.

Does v. Hochul · filed 2022-09-30(a)(1)

The sole “accommodation” the plaintiffs seek—a religious exemption from the vaccine requirement—would impose an undue hardship on the Private Defendants because it would require them to violate state law.

Section 2000e-2(a)(1) prohibits refusal to hire based on religion, including failure to accommodate a religious practice when the employer has not established an adequate accommodation or undue hardship.

Haley v. Community Hospital · filed 2023-01-25(a)(1)

As discussed above, however, Pastor Buie did not constrain the prohibited items to only pork products, so the accommodation offered did not put Haley on notice of whether receiving the vaccine would violate his religious practice. Community Hospital did not provide Haley with a list of the vaccine’s ingredients, as requested, which would have enabled him to better determine whether the vaccine was acceptable to his religious practice. Community Hospital has not met its burden, so the Court denies summary judgment on this claim.

Section 2000e-2(h) protects a bona fide seniority system applied without discriminatory intent; under a union seniority system, voluntary shift swapping can be a reasonable religious accommodation.

Cassell v. Skywest · filed 2023-02-03(h)

The court stands by its prior determination that voluntary shift swapping is a reasonable accommodation in light of a neutral union-mandated seniority system.

A religious accommodation claim may proceed when the complaint alleges a sincere religious belief conflicting with a work requirement, notice to the employer, and discharge, and does not establish undue hardship.

Haskins v. Interstate Blood Bank, Inc. · filed 2023-02-17

Accordingly, the Court will not dismiss Plaintiff’s claim that Defendant failed to accommodate her religious beliefs.

Title VII does not require a religious accommodation that would force an employer to violate a binding regulation.

Riley v. New York City Health & Hospitals Corporation · filed 2023-02-17(a)(1)

Title VII cannot be used to require employers to break the law. ... Granting this accommodation would cause the defendant the undue hardship of forcing it to violate Section 2.61.

A religious objection to receiving a vaccine does not by itself establish a religious conflict with administering it to others.

Petermann, Sonja v. Aspirus, Inc. · filed 2023-03-28(a)(1)

The court agrees with Aspirus that Petermann’s complaint doesn’t identify a religious objection to administering the vaccine, even assuming that she identified a religious objection to receiving the vaccine.

A religious discrimination claim under § 2000e-2(a)(1) can survive dismissal when an employee plausibly alleges a religious conflict with a work requirement, notice to the employer, and unpaid leave, while the reasonableness of that leave as an accommodation remains disputed.

Collins v. Tyson Foods, Inc. · filed 2023-03-30(a)(1)

Accordingly, Collins has sufficiently pled factual allegations to plausibly state a claim for religious discrimination. Therefore, Tyson’s motion must be denied as to this claim.

A religious discrimination claim can survive dismissal when an employee plausibly alleges that an employer denied an accommodation for sincerely held religious beliefs.

Pinner v. American Association of Orthodontists · filed 2023-03-30(a)(1)

These allegations, if proven, state claims of religious discrimination and retaliation in violation of Title VII.

A religious accommodation claim must plead facts describing the employee’s religious beliefs and how they conflict with an employment requirement; a bare reference to religious beliefs is insufficient.

Rogers v. Nebraska Urban Indian Health Coalition, Inc. · filed 2023-04-18(a)(1)

Rogers’s nondescript and cursory reference to “religious beliefs” without any accompanying factual detail means that Counts I and IV fail to state cognizable claims.

Section 2000e-2(a)(1) does not require an employer to provide a religious accommodation that would violate state law; doing so would impose an undue hardship as a matter of law.

Goodrich v. Good Samaritan Regional Health Center · filed 2023-04-21(a)(1)

Therefore, the Court finds that accommodating Plaintiff’s religious-based vaccine and weekly testing exemption requests would have imposed an undue hardship as a matter of law.

Undue hardship is an affirmative defense to a Title VII religious accommodation claim.

Rolovich v. Washington State University · filed 2023-05-30(a)(1)

Undue hardship is an affirmative defense.

An employee pleads a prima facie religious failure-to-accommodate claim by alleging a conflicting bona fide religious belief, notice to the employer, and discipline for failing to meet the conflicting work requirement.

Algarin v. NYC Health + Hospitals Corporation · filed 2023-06-23(a)(1)

Allegations of termination of employment for failure to comply with the conflicting employment requirement of mandatory vaccination are sufficient to plead the final element of the prima facie case of religious discrimination for failure to accommodate.

A religious discrimination claim based on a job requirement requires a conflict with the employee’s religious belief; religious affiliation alone does not establish that conflict.

LEECK v. LEHIGH VALLEY HEALTH NETWORK · filed 2023-06-23(a)(1)

So, accepting Leeck’s statements as true, it is clear that she holds a religious belief. But it is not Leeck’s Christian religious beliefs in general or her attendance at a Methodist church alone which conflicts with her job requirement. Rather, it is her belief that “obtaining any chemical injections at this time . . . is not His plan for me” and her belief that “[i]t is a God-given task that I protect the physical integrity of my body against injections and harmful substances” that conflicts with her job requirement.

Section 2000e-2(a)(1) requires a religious accommodation claim to rest on a belief that is religious in nature.

Ellison v. Inova Health System Foundation · filed 2023-07-19(a)(1)

However, the Court will nonetheless reject all but one of Plaintiffs’ claims as it finds that they are not rooted in concerns that are religious in nature.

Section 2000e-2(a) requires an employee seeking a religious exemption from a workplace rule to plead facts supporting a plausible conflict with a specific religious tenet or principle.

Griffin v. Massachusetts Department of Revenue · filed 2023-07-20(a)

Accordingly, a plaintiff who claims exemption from an employment requirement for religious reasons must plead some modicum of plausible facts sufficient to create an inference that the conflict arises from some specific religious tenet or principle.

Section 2000e-2(a)(1) permits a religious accommodation claim when an employee plausibly alleges a conflicting religious belief, notice to the employer, and an adverse employment action.

Ahmann v. Washington State Department of Transportation · filed 2023-07-28(a)(1)

To state a failure to accommodate religion claim, a plaintiff must plausibly allege (1) they have a bona fide religious belief, the practice of which conflicts with an employment duty; (2) they informed the employer of the belief and conflict; and (3) the employer subjected them to an adverse employment action because of the inability to fulfill the employment duty.

Section 2000e-2(a)(1) requires a religious accommodation claimant to allege a sincere religious belief that conflicts with an employment duty; vague references to religion do not suffice.

Kather v. Asante Health System · filed 2023-07-28(a)(1)

As a result, Kopish, Rada, and Begg do not satisfy the first step of alleging a prima facie failure-to-accommodate claim.

Section 2000e-2(a)(1) does not require a different religious accommodation when an employer offers an alternative that does not conflict with the employee’s religious beliefs.

Cole v. Group Health Plan, Inc. · filed 2023-08-10(a)(1)

Having acknowledged that she was given an alternative that did not conflict with her religious observances, Cole acknowledges that she has not alleged a bona fide religious belief that conflicts with an employment requirement.

An employer seeking dismissal of a religious accommodation claim on undue hardship grounds must show that the accommodation would impose a substantial burden in the context of its business.

MacDonald v. Oregon Health & Science University · filed 2023-08-28(a)(1)

Under Title VII, it is unlawful for an employer “to discharge any individual . . . because of such individual’s . . . religion.” 42 U.S.C. § 2000e–2(a)(1). ... For the reasons below, this Court finds that Defendants have not, at this stage, met their burden to show as a matter of law that accommodating Plaintiff would have resulted in an undue hardship as clarified by the United States Supreme Court in Groff.

A religious discrimination claim requires a conflict between an employee’s religious belief and an employment requirement.

Cole v. Group Health Plan, Inc. · filed 2023-09-11(a)(1)

Having acknowledged that she was given an alternative that did not conflict with her religious observances, Cole acknowledges that she has not alleged a bona fide religious belief that conflicts with an employment requirement.

Section 2000e-2(a)(1) requires a religious-accommodation claimant to allege a sincerely held religious belief that conflicts with an employment requirement.

Ellison v. Inova Health System Foundation · filed 2023-09-14(a)(1)

However, the Court will nonetheless reject all but one of Plaintiffs’ claims as it finds that they are not rooted in concerns that are religious in nature.

An employee’s secular objection to an offered religious accommodation does not establish that the accommodation is unreasonable under Title VII.

Mathisen v. Oregon Health and Science University · filed 2023-09-20(a)(1)

Plaintiff’s assertion that masking would not promote safety is a secular objection, not a religious one. That objection, therefore, does not establish that the offered accommodation to her religious objection was not reasonable for purposes of her claim of religious discrimination.

Title VII religious accommodation claims require a bona fide religious belief; vaccine safety concerns framed in religious terms do not qualify.

Beickert v. New York City Department of Education · filed 2023-09-25(a)(1)

Accordingly, Kushner fails to allege plausibly a bona fide religious belief.

Section 2000e-2(a)(1) permits a religious accommodation claim when an employee plausibly alleges that she told her employer her religious beliefs conflicted with an employment requirement and requested accommodation.

Stroup v. The Coordinating Center · filed 2023-09-28(a)(1)

As an initial matter, the Amended Complaint contains enough facts to state plausibly that she advised Defendant of her religious beliefs and requested accommodation based on a conflict between those beliefs and an employment requirement.

Section 2000e-2(a)(1) bars religious discrimination in employment; a religious accommodation claim fails when the employee cannot show a conflict with a work requirement that led to discipline.

Verne v. New York City Department Of Education · filed 2023-09-29(a)(1)

Accordingly, no reasonable factfinder could find in Verne’s favor on her Title VII-based failure to accommodate claim. The Court therefore grants summary judgment in the DOE’s favor on that claim.

Section 2000e-2 does not require an employer to accommodate secular objections to a workplace testing requirement merely because the employee expresses them in religious language.

Prida v. Option Care Enterprises, Inc. · filed 2023-10-24

Option Care was under no obligation to accommodate Prida’s secular beliefs under either Title VII or Ohio Rev. Code § 4112.02. As a result, a failure to accommodate claim does not lie.

Section 2000e-2(a)(1) permits a religious accommodation claim to proceed when an employee plausibly alleges a sincere religious objection; using an online exemption letter does not by itself defeat the claim.

Miller v. Charleston Area Medical Center · filed 2023-11-14(a)(1)

The fact that Mr. Miller may have found this letter online does not prove that he does not believe in the contents of the letter. As such, Mr. Miller’s failure to accommodate claim under Title VII need not be dismissed.

A Title VII religious accommodation claim must allege facts that make the employee’s religious conflict and the employer’s failure to accommodate plausible.

North v. State of Washington · filed 2023-11-30(a)(1)

Accordingly, North fails to state a ... claim for failure to accommodate her religious beliefs under Title VII or the WLAD.

Section 2000e-2(a)(1)’s ban on discrimination in employment terms and conditions covers a realistic threat of unpaid leave in response to a religious accommodation request.

McNeill v. Tyson Fresh Meats, Inc. · filed 2023-12-08(a)(1)

While “granting leave” is a distinct category of actionable adverse employment actions, this Court does not construe Defendant’s policy under that clause. Rather, the Court situates Defendant’s policy under the statute’s operative catchall provision prohibiting discrimination “with respect to [his] terms, conditions, or privileges of employment.” 42 U.S.C. § 2000e-2(a)(1).

Section 2000e-2(a) permits an employer to defeat a religious accommodation claim by showing that the requested accommodation would substantially burden its operations.

Issac v. Executive Office of Health and Human Services · filed 2023-12-11(a)

Here, the court need not decide whether Isaac has made her prima facie case because, even assuming she has, her claim fails at the undue hardship stage.

A Title VII religious accommodation claim requires an employee to show discipline for failing to comply with a job requirement that conflicts with a bona fide religious belief.

Colson v. Hennepin County · filed 2023-12-12(a)(1)

Colson does not allege that she was disciplined for failing to comply with the weekly testing requirement. Colson, therefore, fails to establish a prima facie case against Hennepin County for failure to accommodate under Title VII.

Section 2000e-2 does not protect a religious accommodation request when the objection to an employment requirement is based on a medical judgment rather than a religious belief.

Sturgill v. The American Red Cross · filed 2023-12-15(a)(1)

The specific accommodation requested has no bearing on whether the reasons given for it are, at their core, religious or medical.

Section 2000e-2(a)(1) prohibits religious discrimination, but an employer need not provide a religious accommodation that would impose undue hardship on its business.

BUSHRA v. MAIN LINE HEALTH, INC. · filed 2023-12-28(a)(1)

MLH has established that it would suffer undue hardship, as defined in Groff, if it were required to accommodate any sincerely-held religious belief of Dr. Bushra.

Section 2000e-2 permits a religious discrimination claim when an employer denies a religious accommodation because the employee’s religious leader did not confirm the employee’s belief.

Carrero v. City of Chicago · filed 2024-01-02(a)(1)

Title VII of the Civil Rights Act prohibits employers from discriminating against their employees based on religion. See 42 U.S.C. § 2000e-2. ... From this, it is reasonable to infer that the City denied his request and put him on “no pay” status because his religious belief was invalid if it could not be confirmed by his church leaders. Accordingly, the Court denies the City’s motion to dismiss as to Count V and VI.

Section 2000e-2(a) does not require an employer to grant a religious accommodation that would violate a state regulation or impose an undue hardship.

Conde v. Mid Hudson Regional Hospital Medical Center · filed 2024-01-12(a)

Where, as here, an employee’s request would require her employer to violate a state regulation, the proposed “accommodation” constitutes an undue hardship as a matter of law.

Section 2000e-2(a)(1) does not require an employer to provide a religious accommodation that would violate state law, because doing so would impose undue hardship.

Taylor v. Maritime Odyssey Preschool · filed 2024-01-18(a)(1)

Because the accommodation requested by the plaintiff would have required the defendant to violate state law, it would have constituted an undue hardship on the defendant, and the plaintiff cannot show that the defendant discriminated against her based on her religion in violation of Title VII.

A religious accommodation claim can proceed when an employee plausibly links a vaccine objection to sincerely held religious beliefs.

Hernandez v. Bayhealth Medical Center, Inc. · filed 2024-01-25(a)(1)

I find that Plaintiff has adequately linked her objection to the COVID-19 vaccines to religious beliefs stemming from Plaintiffs Christian faith.

Section 2000e-2(a)(1) allows a religious failure to accommodate claim to proceed when an employee plausibly links an objection to a job requirement to a religious belief.

Massotti v. Bayhealth Medical Center, Inc. · filed 2024-01-25(a)(1)

Plaintiff has plausibly stated a failure to accommodate claim based on at least one religious belief.

A religious accommodation claim under § 2000e-2(a)(1) requires a plausible allegation that the employee’s objection arises from a religious belief; concern about a vaccine’s safety alone does not qualify.

McDowell v. Bayhealth Medical Center, Inc. · filed 2024-01-25(a)(1)

For the reasons stated above, I find Plaintiff's Complaint does not plausibly allege that Plaintiff's objection to receiving the COVID-19 vaccine was based on a sincerely held religious belief.

Section 2000e-2(a)(1) allows a religious accommodation claim to proceed when an employee plausibly links an objection to a job requirement to a religious belief.

Proud v. Bayhealth Medical Center, Inc. · filed 2024-01-25(a)(1)

I find that Plaintiff has adequately linked her objection to the COVID-19 vaccines to religious beliefs stemming from Plaintiff's Christian faith. ... Plaintiff has plausibly stated a failure to accommodate claim based on at least one religious belief.

Section 2000e-2(a)(1) allows a religious accommodation claim to survive dismissal when the complaint plausibly ties an employee’s vaccine objection to a sincerely held religious belief.

Aiken v. Bayhealth Medical Center, Inc. · filed 2024-01-25(a)(1)

For the reasons stated above, I find Plaintiff's Complaint plausibly alleges that she had a “sincerely held religious belief, and that [her] objection to receiving the COVID-19 vaccine was based on that belief.” Aliano, 2023 WL 4398493, at *4. I therefore will not dismiss Plaintiffs Title VII failure to accommodate claim.

A religious accommodation claim requires facts plausibly connecting an employee’s objection to a job requirement with a sincerely held religious belief.

Osborne v. Bayhealth Medical Center, Inc. · filed 2024-01-25(a)(1)

Plaintiff fails to adequately link her objection to the COVID-19 vaccines to religious beliefs stemming from her Christian faith.

Section 2000e-2(a)(1) allows a religious failure-to-accommodate claim to proceed when an employee plausibly alleges that a job requirement conflicts with a sincerely held religious belief.

White v. Bayhealth Medical Center, Inc. · filed 2024-01-26(a)(1)

Plaintiff has plausibly stated a failure to accommodate claim based on at least one religious belief.

Section 2000e-2(a)(1) permits a religious accommodation claim to proceed when an employee plausibly alleges that a vaccine objection stems from her religious beliefs.

Griffin v. Bayhealth Medical Center, Inc. · filed 2024-01-29(a)(1)

I find that Plaintiff has adequately linked her objection to the COVID-19 vaccines to religious beliefs stemming from Plaintiff's Christian faith. ... I therefore will not dismiss Plaintiff s Title VII failure to accommodate claim.

Section 2000e-2(a)(1) permits a religious failure to accommodate claim when an employee plausibly links a vaccine objection to a sincerely held religious belief.

Wharton v. Bayhealth Medical Center, Inc. · filed 2024-01-29(a)(1)

I find that Plaintiff has adequately linked her objection to the COVID-19 vaccines to religious beliefs stemming from Plaintiff's Catholic faith. ... I therefore will not dismiss Plaintiff's Title VII failure to accommodate claim.

Section 2000e-2(a)(1) allows a religious accommodation claim to proceed when an employee plausibly links a vaccine objection to a sincerely held religious belief.

Thornton v. Bayhealth Medical Center, Inc. · filed 2024-01-29(a)(1)

I find that Plaintiff has adequately linked his objection to the COVID-19 vaccines to religious beliefs stemming from Plaintiff's Christian faith.

A religious failure-to-accommodate claim may proceed when an employee plausibly links an objection to a workplace requirement to a sincerely held religious belief.

Thompson v. Bayhealth Medical Center, Inc. · filed 2024-01-29(a)(1)

Plaintiff has plausibly stated a failure to accommodate claim based on at least one religious belief.

A religious accommodation claim requires a plausible allegation that the employee’s objection to a job requirement rests on a sincerely held religious belief; medical concerns about vaccine safety do not suffice.

Hand v. Bayhealth Medical Center, Inc. · filed 2024-01-31(a)(1)

For the reasons stated above, I find Plaintiff's Complaint does not plausibly allege that Plaintiff’s objection to receiving the COVID-19 vaccine was based on a sincerely held religious belief.

A religious accommodation claim must plausibly connect an employee’s objection to a job requirement to a sincerely held religious belief.

Isaacs v. Bayhealth Medical Center, Inc. · filed 2024-01-31(a)(1)

For the reasons stated above, I find Plaintiff's Complaint does not plausibly allege that Plaintiffs objection to receiving the COVID-19 vaccine was based on a sincerely held religious belief.

Section 2000e-2(a)(1) requires a religious accommodation claim to plausibly connect the employee’s objection to a sincerely held religious belief; vaccine safety concerns and general appeals to conscience do not suffice.

Maloney v. Bayhealth Medical Center, Inc. · filed 2024-01-31(a)(1)

Furthermore, Plaintiff's exemption form contains no information about what guideposts her religious beliefs provide for determining what materials are “unclean.” ... I will therefore dismiss Plaintiffs failure to accommodate claim with prejudice.

A religious failure-to-accommodate claim requires facts plausibly connecting the employee’s objection to a job requirement with a sincerely held religious belief.

Wilson v. Bayhealth Medical Center, Inc. · filed 2024-01-31(a)(1)

For the reasons stated above, I find Plaintiff's Complaint does not plausibly allege that Plaintiff's objection to receiving the COVID-19 vaccine was based on a sincerely held religious belief.

A religious accommodation claim must plausibly allege that the employee's objection to a job requirement rests on a sincerely held religious belief.

Lamb v. Bayhealth Medical Center, Inc. · filed 2024-01-31(a)(1)

For the reasons stated above, I find Plaintiff's Complaint does not plausibly allege that Plaintiff's objection to receiving the COVID-19 vaccine was based on a sincerely held religious belief.

Section 2000e-2(a)(1) requires a religious accommodation claimant to plausibly connect an objection to a job requirement with a sincerely held religious belief; concerns about vaccine safety alone do not qualify.

Roberts v. Bayhealth Medical Center, Inc. · filed 2024-01-31(a)(1)

Plaintiff's medical beliefs do not qualify as religious beliefs under Africa.

A religious accommodation claim requires facts connecting the employee’s objection to a sincerely held religious belief; medical concerns alone do not qualify.

Caruano v. Bayhealth Medical Center, Inc. · filed 2024-02-02(a)(1)

For the reasons stated above, I find Plaintiff's Complaint does not plausibly allege that Plaintiff's objection to receiving the COVID-19 vaccine was based on a sincerely held religious belief.

Section 2000e-2(a)(1) does not support a religious accommodation claim when an employee’s vaccine objection rests on medical safety concerns rather than a sincerely held religious belief.

McCarthy v. Bayhealth Medical Center, Inc. · filed 2024-02-02(a)(1)

For the reasons stated above, I find Plaintiff's Complaint does not plausibly allege that Plaintiffs objection to receiving the COVID-19 vaccine was based on a sincerely held religious belief.

Section 2000e-2(a)(1) does not protect a request for religious accommodation based on medical judgments about a vaccine rather than a sincerely held religious belief.

Maher v. Bayhealth Medical Center, Inc. · filed 2024-02-02(a)(1)

For the reasons stated above, I find Plaintiff's Complaint does not plausibly allege that Plaintiff's objection to receiving the COVID-19 vaccine was based on a sincerely held religious belief.

Section 2000e-2(a)(1) requires an employee seeking religious accommodation to plead facts connecting an objection to a sincerely held religious belief; medical concerns about a vaccine do not suffice.

Lane v. Bayhealth Medical Center, Inc. · filed 2024-02-05(a)(1)

Plaintiff's medical beliefs do not qualify as religious beliefs under Africa.

Section 2000e-2(a)(1) requires a religious basis for a failure-to-accommodate claim; a personal choice about vaccination does not suffice.

Harvey v. Bayhealth Medical Center, Inc. · filed 2024-02-05(a)(1)

Title VII makes it unlawful for an employer to discriminate against an employee based on that employee’s religion. 42 U.S.C. § 2000e-2(a)(1). ... For the reasons stated above, I find Plaintiff's Complaint does not plausibly allege that Plaintiff's objection to receiving the COVID-19 vaccine was based on a sincerely held religious belief.

Section 2000e-2(a)(1) does not protect a vaccine objection based on medical concerns rather than a sincerely held religious belief.

Berna v. Bayhealth Medical Center, Inc. · filed 2024-02-05(a)(1)

Plaintiff's focus on the efficacy and potential harm caused by the vaccine demonstrate that Plaintiff's objection to the vaccine is based on scientific and medical beliefs. These beliefs do not qualify as religious beliefs under Africa.

Denial of a reasonable religious accommodation without undue hardship is itself an adverse employment action; no additional adverse action is required to plead religious discrimination.

Billings v. Murphy · filed 2024-02-06(a)(1)

Contrary to the District Court’s holding, Billings was not required to allege an additional adverse employment action, beyond the denial of her request for religious accommodation, to plead a claim of religious discrimination.

Section 2000e-2 permits a religious accommodation claim when an employee minimally pleads a sincere religious belief that conflicts with an employment requirement.

Quinn v. Legacy Health · filed 2024-02-13

Both Cotton and Harris meet the minimal standard for pleading a sincere religious belief that conflicts with an employment requirement.

A religious accommodation claim requires facts showing an actual conflict between a religious belief and a job requirement; conclusory assertions of conflict are insufficient.

Medlin v. PeaceHealth · filed 2024-02-21(a)(1)

Here, Plaintiff’s conclusory allegations are insufficient to state a claim under Rule 12(b)(6). ... This Court concurs and concludes that Plaintiff has failed to allege a prima facie case and so Defendant’s Motion to Dismiss is GRANTED.

A religious accommodation claim can proceed when the employee plausibly alleges a sincere religious belief that conflicts with a job requirement.

Burns v. Asante Rouge Regional Medical Center, LLC · filed 2024-02-21(a)(1)

Based solely on the allegations in the complaint, Ms. Stebbins has sufficiently articulated a bona fide religious belief, the practice of which conflicted with the employment duty to take the COVID-19 vaccine.

Section 2000e-2(a)(1) permits a religious accommodation claim to proceed when the employee adequately alleges discharge after the employer denied the requested accommodation.

Donio v. Arch Oncology, Inc. · filed 2024-03-04(a)(1)

And as to Donio’s religious-accommodation claims asserted in Counts II and IV, the petition and charge of discrimination read together show Donio to have adequately asserted that he was discharged as a result of being denied his requested accommodation, which is an adverse employment action satisfying the third element of a failure-to-accommodate claim.

Section 2000e-2(a)(1) requires a religious accommodation plaintiff to plead facts showing an actual conflict between a religious belief and an employment requirement.

Kamrath v. Addictions Recovery Center, Inc. · filed 2024-03-05(a)(1)

Because Plaintiff fails to include any specific factual allegations demonstrating an actual conflict between his religious belief(s) and his employer’s vaccine mandate, he fails to establish the first element of a prima facie case of religious discrimination under Title VII or Oregon law.

A Title VII religious accommodation claim requires a plausible allegation that a sincere religious belief conflicts with a job duty, that the employee informed the employer, and that the conflict led to an adverse employment action.

Bird v. Alanson M. Randol, D.D.S., P.C. · filed 2024-03-06(a)(1)

But at this early stage of litigation, Plaintiffs Bird and Egenhoff have each sufficiently plead a conflict between Defendants’ vaccine policy and their respective religious beliefs. ... Accordingly, Shaw-David fails to satisfy the first step of alleging a prima facie discrimination claim.

A religious accommodation claim requires an employment requirement that conflicts with the employee’s religious practice.

Baraona v. Village of Niles · filed 2024-03-08(a)(1)

Having failed to offer any evidence that she was unlawfully subject to an employment requirement that conflicted with her religion, the Village is entitled to summary judgment on Baraona’s failure to accommodate claim.

Section 2000e-2(a)(1) covers constructive discharge based on an employer’s failure to accommodate an employee’s religious practice.

Savel v. MetroHealth Sys. · filed 2024-03-20(a)(1)

A constructive discharge is the same as an ordinary discharge “for remedial purposes,” Suders, 542 U.S. at 141, so it is covered by Title VII.

An employer’s duty to accommodate religious practice continues despite a customer’s objection, but accommodation is not required if it would cause undue hardship.

Kalejaiye v. Quality Investigations, Inc. · filed 2024-03-21(a)(1)

It is true that QI has an obligation to comply with the religious accommodation strictures of Title VII regardless of whether DOT told QI that it could not post security officers with beards. ... Accordingly, because there is a genuine dispute of material fact with respect to whether accommodating Kalejaiye by permitting him to grow out his beard while working at the DOT site would have caused an undue hardship, summary judgment is inappropriate.

Section 2000e-2 prohibits religious employment discrimination, but an employer need not provide a religious accommodation that would cause undue hardship.

White v. University of Washington · filed 2024-03-22

The record shows that accommodating Plaintiff would cause undue hardship as a matter of law. Accordingly, dismissal of this claim is appropriate.

Section 2000e-2(a) prohibits religious discrimination in employment; a plaintiff seeking judgment on the pleadings for failure to accommodate must overcome the employer’s pleaded undue hardship defense.

Hall v. Sheppard Pratt Health Systems, Inc. · filed 2024-03-29(a)

Title VII prohibits an employer from taking adverse employment action against an individual “because of such individual’s . . . religion.” 42 U.S.C. § 2000e-2(a). ... The undenied material allegations in Ms. Hall’s complaint do not conclusively establish that Sheppard Pratt is liable for religious discrimination, in part because Sheppard Pratt has asserted, in its answer (and further in its amended answer) that accommodating Ms. Hall’s religious needs constituted an undue hardship.

Section 2000e-2(a) allows an employer to deny a religious accommodation when the requested accommodation would impose an undue hardship on its operations.

Antredu v. Department of Youth Services · filed 2024-04-09(a)

Considering Antredu’s statements in his request for an exemption regarding his views on the sanctity of life, and considering the Department’s admission that Antredu’s beliefs are sincerely held, the Court ruled that Antredu has established a prima facie case. ... The Department, therefore, met its burden in demonstrating that the requested accommodation would have been an undue hardship, and that therefore, it was justified in terminating Antredu’s employment.

Section 2000e-2(a) allows a religious discrimination claim to proceed when an employee plausibly alleges that an employer fired him after he objected on religious grounds to a vaccination requirement.

Lewis v. Tegna, Inc. · filed 2024-04-12(a)

Accepting Plaintiff’s facts as true, the Court can reasonably infer that Defendants terminated Plaintiff because of his religion. This states a claim of religious discrimination sufficient to survive a motion to dismiss.

A Title VII religious accommodation claim need not plead facts establishing a prima facie case to survive a motion to dismiss.

Horne v. Pentastar Aviation, LLC · filed 2024-04-12(a)(1)

This Court denies Defendant’s challenges to Plaintiff’s Title VII failure-to-accommodate claim. ... That matters because, as this Court recognized in Golles, a plaintiff is not required to allege facts establishing a prima facie employment discrimination claim in order to survive a 12(b)(6) motion to dismiss: ... Other district courts have recognized this same general concept in the context of motions to dismiss claims such as this one.

A religious accommodation claim requires an employee to show that a sincere religious belief conflicts with an employment requirement.

Ellison v. Inova Health System Foundation · filed 2024-04-15(a)(1)

Because Plaintiffs have failed to establish a genuine dispute as to whether the Novavax vaccine used fetal cell testing in its development, they cannot satisfy the first element of their prima facie claim: that their religious beliefs conflicted with the IPP. Inova is therefore entitled to summary judgment as to both Ellison and Graham.

Title VII permits an employer to deny a religious accommodation that would impose a substantial burden on its operations.

Haley v. Executive Office of Health and Human Services · filed 2024-04-26(a)

Here, the court need not decide whether Haley has made her prima facie case because, even assuming she has, her claim fails at the undue hardship stage.

An employee seeking a religious accommodation must give the employer notice of the religious reason for refusing a workplace requirement; refusal alone does not suffice.

Ouida v. Harbors Home Health and Hospice · filed 2024-05-23(a)(1)

However, simply refusing a vaccine or a nasal swab test did not give her employer notice of the religious motivation behind her refusal or that she was seeking accommodation.

Employees can plausibly plead a religious accommodation claim under Section 2000e-2(a)(1) by alleging that their religious beliefs conflict with workplace vaccination or testing requirements.

Ringhofer v. Mayo Clinic Ambulance · filed 2024-05-24(a)(1)

All plaintiffs adequately pled a conflict between their Christian religious beliefs and Mayo Clinic’s Covid-19 policy.

Section 2000e-2(a)(1) permits a religious discrimination claim to proceed when a genuine dispute remains over whether an employee’s objection to a workplace requirement rests on a sincere religious belief, even as a secondary reason.

Cesare v. PACT MSO, LLC · filed 2024-06-04(a)(1)

Summary judgment is precluded where there are genuine disputes about whether a bona fide religious belief is a secondary, or even tertiary, reason for a party’s convictions.

A religious accommodation claim can survive dismissal when the employee plausibly alleges a religious belief that conflicts with a job requirement.

Niederberger v. Wegmans Food Markets, Inc. · filed 2024-06-06(a)(1)

The Court need not find Niederberger’s religious beliefs comprehensible or logical to find that he has sufficiently stated that he has a religious belief that conflicts with an employment requirement. ... Here, Niederberger has met this low bar, and accordingly the Court cannot dismiss his failure to accommodate claims on this basis.

A religious discrimination claim can survive dismissal when the complaint plausibly alleges that an employee’s religious beliefs conflicted with an employer’s vaccination requirement.

Carlson v. Centene · filed 2024-06-06(a)(1)

Title VII makes it unlawful for an employer “to fail or refuse to hire or to discharge any individual, or discriminate against any individual ... because of such individual's ... religion.” 42 U.S.C. § 2000e-2(a)(1). ... Construing the factual allegations of Plaintiff’s Amended Complaint and all reasonable inferences thereof as true, the Amended Complaint satisfies Rule 12(b)(6). The motion to dismiss will therefore be denied.

A religious accommodation claim requires a plausible allegation that a religious belief conflicts with an employment requirement.

Riser v. St. Charles Health System, Inc. · filed 2024-06-06(a)(1)

The Court concludes that Timms has failed to plausibly allege that her objection to the vaccine mandate was religious in nature or that there was a conflict between her beliefs and the vaccine mandate.

A plaintiff claiming religious discrimination based on a denied accommodation must identify the religious beliefs that conflict with the employer’s requirement.

Palmer v. Rancho Sahuarita Management Company LLC · filed 2024-06-10(a)(1)

Plaintiff must state his religious beliefs and explain how these beliefs conflict with Defendant’s employment requirement.

An employer need not grant a religious accommodation that would require it to violate a vaccination rule and impose undue hardship on its business.

Addonizio v. Nuvance Health · filed 2024-06-11(a)(1)

Defendants therefore could not have granted Plaintiff’s requested accommodation without violating the law. Moreover, Defendants would likely have suffered additional consequences, including harm to their accreditation, potential financial penalties, and a likelihood of malpractice suits or other litigation filed by patients who had suffered harm resulting from the violation. Defendants have therefore shown that granting the requested accommodation would have imposed an undue hardship on their business.

A religious accommodation plaintiff meets the minimal pleading burden for a religious conflict by alleging that her faith motivated her objection to a work requirement and that she requested an exemption.

Folin v. Asante · filed 2024-06-20(a)(1)

However, at this stage, the burden to allege a prima facie case is minimal. Plaintiff has pled that she expressed a religious conflict with receiving the COVID-19 vaccine, and she timely submitted her exemption request to Asante. She even alleges that Asante accepted her religious exemption, as she requested. Therefore, she has met her burden on this issue.

An employee seeking religious accommodation must give the employer enough information to understand the conflict between the employee’s religious belief and a workplace requirement.

Weiss v. The Permanente Medical Group, Inc. · filed 2024-06-21(a)(1)

Weiss has therefore failed to aver plausibly that she adequately informed TPMG of the conflict between her religious beliefs and the Policy, and judgment is accordingly warranted for TPMG on Weiss’s second and sixth claims.

Section 2000e-2(a)(1) prohibits religious discrimination in employment; a religious accommodation claim requires the employer to show that accommodation would impose an undue hardship once the employee establishes a prima facie case.

Lake v. HealthAlliance Hospital Broadway Campus · filed 2024-06-27(a)(1)

Thus, the burden shifts to defendant to establish that it would have suffered an undue hardship if it had provided plaintiff with an accommodation to the Policy.

Section 2000e-2(a)(1) requires an employee claiming failure to accommodate a religious belief to inform the employer of the belief and its conflict with an employment requirement.

Jenkins v. Valley Health System · filed 2024-06-28(a)(1)

To state a prima facie case of failure to accommodate religious beliefs under Title VII, a plaintiff must establish that (1) he has a bona fide religious belief that conflicts with an employment requirement, (2) he informed the employer of this belief, and (3) he was disciplined for failure to comply with the conflicting employment requirement. ... In short, Jenkins’s submission to Valley Health does not reflect that he adequately informed Valley Health of his religious beliefs.

A religious discrimination claim requires a conflict between an employee’s religious belief and an employment requirement; a general free-will objection to vaccination does not establish one.

Bowerman v. St. Charles Health System, Inc. · filed 2024-07-01(a)(1)

Without more, Plaintiff Bowerman has failed to offer any details or specifics of her religious beliefs that would cause a conflict with the vaccine mandate.

Section 2000e-2(a)(1) allows a religious accommodation claim for harm to a term or condition of employment without requiring discharge or discipline.

Staple v. Broward County School Board · filed 2024-07-02(a)(1)

Employment practices that are actionable under a religious accommodation claim are the same as the ones actionable for any other claim under Title VII’s disparate treatment provision.

A religious accommodation claim requires a bona fide religious belief that conflicts with an employment requirement, notice to the employer, and an adverse employment action for failing to comply with that requirement.

Rainey v. Westminster Public Schools · filed 2024-07-07(a)(1)

For Plaintiffs to state a claim for relief under a failure to accommodate theory, they must adequately allege that (1) they had a bona fide religious belief that conflicted with an employment requirement; (2) they informed Defendant WPS of that belief; and (3) they suffered an adverse employment action for failing to comply with the employment requirement.

Extended unpaid leave may be an unreasonable religious accommodation under § 2000e-2(a)(1) when a less burdensome option may be feasible.

Bottman v. Springfield Public Schools · filed 2024-07-12(a)(1)

Nonetheless, under the proper standard, the District here is not entitled to summary judgment because a reasonable factfinder could conclude that the accommodation for Mr. Bottman was unreasonable.

Section 2000e-2(a)(1) requires a religious accommodation claim to allege how a religious belief conflicts with an employment requirement.

Prakash v. Oregon Health and Science University · filed 2024-07-22(a)(1)

In sum, Plaintiff has not sufficiently pleaded a conflict between her Hindu beliefs and the COVID-19 vaccine.

Section 2000e-2(a) does not require an employer to grant a religious accommodation that would impose substantial hardship on its operations.

Howe v. Massachusetts Department of Correction · filed 2024-07-25(a)

Even assuming Howe meets his prima facie case, Defendant has successfully demonstrated how accommodating an unvaccinated Correction Officer would cause undue hardship to DOC.

A religious accommodation request can support a claim under § 2000e-2(a)(1) when it plausibly rests in part on religious belief or practice, even if it also raises secular concerns.

Dottenwhy v. Aspirus, Inc. · filed 2024-07-29(a)(1)

But the fact that an accommodation request also invokes or, as here, even turns upon secular considerations does not negate its religious nature.

Section 2000e-2(a)(1) protects an employee who seeks religious accommodation when the request is plausibly based in part on religious belief or practice, even if it also raises secular concerns.

Passarella v. Aspirus, Inc. · filed 2024-07-29(a)(1)

We reverse and, aligned with the only two circuits to have considered the question, hold that an employee seeks accommodation because of their religion when their request, by its terms, is plausibly based at least in part on some aspect of their religious belief or practice.

A religious accommodation request satisfies Title VII’s pleading threshold when it plausibly rests at least in part on the employee’s religious belief or practice.

Bube v. Aspirus Hospital, Inc · filed 2024-07-29(a)(1)

Put another way, the controlling inquiry at the pleading stage is whether the employee plausibly based her vaccination exemption request at least in part on an aspect of her religious belief or practice.

A religious accommodation claim can survive dismissal when the complaint identifies the employee’s religion and explains the religious basis for objecting to an employment requirement.

Dodson v. Lutheran Village at Miller's Grant · filed 2024-07-30(a)(1)

While Ms. Dodson’s Complaint is not a model of clarity, taken together, the Complaint and Exhibits plausibly allege facts that allow the Court to infer that the elements of her failure to accommodate claim are satisfied, which is all that is required at this stage of the case.

Section 2000e-2 does not require an employer to provide a religious accommodation that would impose an undue hardship.

Snow v. Women's HealthCare Associates, LLC · filed 2024-08-02

For the reasons below, this Court GRANTS Defendants’ Motion for Summary Judgment, ECF 15. Defendants have provided sufficient evidence demonstrating that accommodating Plaintiff would have posed an undue hardship to WHA.

Section 2000e-2(a) does not require an employer to forgo collecting an employee’s Social Security number when federal tax law requires it, even if the employee objects on religious grounds.

Henry, Robert v. Decker, Edward · filed 2024-08-12(a)

Courts have held that because the Internal Revenue Code requires employers to collect and provide the social security numbers of their employees, employers do not violate Title VII by requiring employees’ social security numbers even over their religious objections. ... So as currently written, Henry’s complaint does not state a claim for which the court could grant relief.

A religious-accommodation complaint can survive dismissal without pleading every element of a prima facie case if it plausibly alleges that the employer failed to accommodate a religious belief.

Sturgill v. Am. Red Cross · filed 2024-08-21(a)(1)

The district court’s element-by-element examination of whether plaintiff established a prima facie case for failure to accommodate was therefore erroneous.

Section 2000e-2(a)(1) requires a plaintiff claiming religious discrimination over a workplace vaccine mandate to allege facts describing how a religious belief conflicts with the mandate; conclusory allegations are insufficient.

Beeching v. PeaceHealth · filed 2024-08-22(a)(1)

The Court concludes that the Complaint, as currently pleaded, fails to state a claim on its face because the allegations concerning Plaintiffs religious beliefs and the conflict between those beliefs and the vaccine mandate are conclusory.

Section 2000e-2(a)(1) bars sex discrimination in employment; an accommodation that would sanction such discrimination can impose an undue hardship on an employer.

Trueblood v. Valley Cities Counseling and Consultation · filed 2024-08-28(a)(1)

VCCC demonstrates undue hardship because the Disputed Accommodations would sanction discrimination against VCCC’s clients and staff and, at the very least, create a danger of violating federal and state law, exposing VCCC to potential liability as a result.

Section 2000e-2(a)(1) does not require a hospital to accommodate religious objections to vaccination by allowing unvaccinated employees to work with patients when doing so would impose substantial costs.

Williams v. Legacy Health · filed 2024-08-29(a)(1)

Accommodating hundreds of employees refusing vaccination (see id. at ¶ 19), who would then pose heightened risks of getting infected and spreading COVID-19 further (see supra Sec. II.A.) among Legacy’s patient population and staff—in spite of any non-vaccination-based safety protocols (see supra Sec. II.B.)—would have imposed substantial costs on Legacy.