42 U.S.C. § 2000e

Section 2000e(j)’s definition of religion can cover a vaccine objection adequately linked to an employee’s religious beliefs.

White v. Bayhealth Medical Center, Inc. · filed 2024-01-29(j)

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

Section 2000e(j)'s definition of religion does not cover vaccine objections grounded in medical or scientific judgments rather than religious beliefs.

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

Plaintiffs objection is therefore based fundamentally on her scientific and medical beliefs about the vaccine. Such medical and scientific judgments do not qualify as religious beliefs.

Section 2000e(j) requires an employee seeking religious accommodation to plausibly connect an objection to a sincerely held religious belief.

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

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’s definition of religion does not cover a vaccine objection based on medical safety concerns without a sufficient connection to religious belief.

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

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

A court assessing a claimed religious belief under § 2000e(j) must examine whether the belief is sufficiently connected to the employee’s religion.

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

However, because individuals cannot “cloak” all personal beliefs “with religious significance,” a court must still scrutinize whether a sincerely held belief, asserted by someone claiming a recognized religion, is sufficiently connected to their religion.

A vaccine objection must be plausibly based on a sincerely held religious belief to qualify under § 2000e(j).

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

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(j) does not treat medical concerns about vaccine safety as religious beliefs.

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

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

A vaccine objection must be plausibly based on a sincerely held religious belief to qualify under § 2000e(j).

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

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(j) requires a religious accommodation claimant to plausibly allege that the objection to a job requirement stems from a sincerely held religious belief.

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

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.

A vaccine objection must be plausibly connected to a religious belief to qualify for protection as religious practice.

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

For the following reasons, I find Plaintiff has failed to adequately plead facts that show either of these categories are religious beliefs that form the basis of her objection to the bovinas vaccine.

Section 2000e(j) requires a plaintiff seeking religious accommodation to plausibly connect an objection to a sincerely held religious belief.

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

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 vaccine objection must be plausibly based on a sincerely held religious belief to qualify under § 2000e(j).

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

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(j) allows an employer assessing a religious accommodation request to consider whether the employee's conduct is consistent with a sincerely held religious belief.

Matter of Ventresca-Cohen v. DiFiore · filed 2024-02-08(j)

Turning to the substantive analysis, respondents acknowledge that under Title VII of the Civil Rights Act of 1964 ( see 42 USC § 2000e et seq. ), an employer is required to provide a reasonable accommodation to an employee when a work requirement conflicts with a bona fide religious belief of the employee ( see 42 USC § 2000e [j]; Baker v The Home Depot , 445 F3d 541, 546 [2d Cir 2006]). ... In gauging sincerity, the Committee was entitled to factor in the consistency between an applicant's stated beliefs and conduct ( see Philbrook v Ansonia Bd. of Educ. , 757 F2d 476, 482 [2d Cir 1985], affd 479 US 60 [1986]).

A vaccine objection must be plausibly based on a sincerely held religious belief to qualify under § 2000e(j).

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

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(j) covers religious practice and belief, including a plausibly alleged faith based conflict with a vaccination requirement.

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

The term “religion” encompasses all aspects of religious practice and belief. ... 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(j) covers religious beliefs and practices, but a religious accommodation claim requires facts showing that a belief or practice conflicts with an employment requirement.

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

The term “religion” encompasses all aspects of religious practice and belief. 42 U.S.C. § 2000e(j); Peterson v. Hewlett-Packard Co., 358 F.3d 599, 602 (9th Cir. 2004). ... 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.

Section 2000e(j) includes religious beliefs and practices within its definition of religion, but does not protect secular medical, economic, political, or social preferences.

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

The term “religion” encompasses all aspects of religious practice and belief. ... Title VII does not protect medical, economic, political, or social preferences.

Section 2000e(j) requires a religious discrimination complaint to identify the plaintiff’s religion or explain how the objection is informed by specific religious beliefs or practices.

Shigley v. Tydings & Rosenberg LLP · filed 2024-03-18(j)

But the Complaint must at a minimum identify a plaintiff's religion or explain how a plaintiff's objections are informed by a specific set of religious beliefs or practices.

Section 2000e(j) does not require an employer to accommodate an objection to a workplace policy when the employee fails to identify a religious belief that conflicts with it.

Moli v. King County · filed 2024-04-29(j)

Having failed to identify any element of her religious belief system that conflicted with her employer’s COVID-19 vaccination requirement, plaintiff failed to give her employer timely notice of a religious conflict. Because an employer has no duty to accommodate non-religious objections to workplace policies, the alleged failure to engage in an interactive discussion regarding potential accommodations cannot establish liability in this case.

Section 2000e(j) broadly defines religion to include religious belief, observance, and practice.

Jackson v. Pilgrim Psychiatric Center · filed 2024-05-01(j)

Title VII defines religion broadly to include “all aspects of religious observance and practice, as well as belief.” 42 U.S.C. § 2000e(j). ... Plaintiff pled the relevant bona fide religious belief.

Section 2000e(j) does not cover a vaccine objection based on a concern about bodily harm rather than a religious belief.

McCadd v. The Kraft Heinz Company · filed 2025-02-28(j)

Clearly, the basis of her refusal to receive the COVID-19 vaccine, that it would “defile” her body, is a concern about harm to her body. This is a medical belief, not a religious one.

Section 2000e(j)’s definition of religion requires courts to consider whether an employee’s professed religious belief is sincerely held.

Leonhartt v. MedStar Health, Inc. · filed 2025-03-07(j)

Here, however, the record presents no genuine dispute of material fact as to the sincerity of Plaintiff’s Catholic belief and anti-abortion convictions.

Section 2000e(j) covers an accommodation request based at least in part on an employee’s religious beliefs, even if the request also reflects secular concerns.

Elliott v. Shriners Hospitals for Children · filed 2025-03-11(j)

Both exemption requests are based on their face, and at least in part, on a dimension of the Plaintiffs’ religious beliefs. This makes them – at least at the pleading stage – religious in nature within the meaning of Title VII.

Section 2000e(j) does not treat a personal or medical objection to workplace testing as a religious belief merely because the employee describes it in religious terms.

Gatto v. Johnson & Johnson Services Inc · filed 2025-03-14(j)

Her objection is based on her personal and medical preference, not religion.

Section 2000e(j)’s definition of religion can cover nonconventional beliefs that an employee understands as religious and communicates when seeking an accommodation.

Huber v. TIAA · filed 2025-04-17(j)

Applying the framework the Fourth Circuit endorsed in Barnett, this court finds that Huber has plausibly alleged the beliefs she communicated to TIAA were “religious in nature.”

Section 2000e(j) makes the undue hardship defense applicable to religious observance and practice, but not to discrimination based on religious belief.

Carter v. Southwest Airlines Company · filed 2025-05-08(j)

As a result, reasonable accommodation and undue hardship are only relevant for claims based on observance or practice. No undue hardship defense exists for discriminating against an employee’s beliefs.

Section 2000e(j)’s definition of religion can cover a sincerely held religious objection to vaccination when the employee presents evidence tying that objection to her religious beliefs.

Anoruo v. MedStar Health, Inc. · filed 2025-06-09(j)

The court is satisfied that Plaintiff has deduced sufficient evidence to generate a triable issue (i.e., a genuine dispute of material fact) as to her sincerely held religious belief that forms the alleged basis of her COVID-19 vaccine objection.

Section 2000e(j) includes religious observance, practice, and belief within its definition of religion; a claimant must identify the belief and explain how it conflicts with an employment requirement.

Barrett v. The Department of Education of the City of New York · filed 2025-06-26(j)

Title VII defines religion as “includ[ing] all aspects of religious observance and practice, as well as belief.” Id. at 318. ... Plaintiff’s assertion that she is a Christian and that she has a personally held religious belief preventing her from being vaccinated is not sufficient because she does not allege what that belief is or how that belief conflicts with vaccination.

Section 2000e(j)’s definition of religion does not cover a vaccine objection that is not grounded in an essential part of the employee’s religious faith.

Wilkins-Bailey v. Essity Professional Hygiene North America, LLC · filed 2025-07-24(j)

The point is that plaintiff’s vaccine-related beliefs do not go to “an essential part of a religious faith” and are thereby not religious in nature.

A genuine factual dispute over whether an employee’s belief is sincerely held can prevent summary judgment on a § 2000e(j) religious accommodation claim.

Harvey v. The Mitre Corporation · filed 2025-08-19(j)

With this guidance in mind, upon separate review of the Motions, the Court finds that neither party has “show[n] that there is no genuine dispute as to any material fact” such that the party “is entitled to judgment as a matter of law” on whether Plaintiff had sincerely held religious beliefs.

Section 2000e(j) covers a vaccine exemption request when the pleaded facts plausibly connect it to the employee’s religious beliefs.

Morris v. The City of Chicago · filed 2025-08-20(j)

“At the pleading stage, an employee seeking an accommodation in the form of an exemption from an employer’s vaccine mandate must allege facts plausibly permitting an inference that some ‘aspect[ ]’ of the request is based on the employee’s ‘religious observance and practice’ or ‘belief.’” Passarella, 108 F.4th at 1009 (quoting 42 U.S.C. § 2000e(j)). ... This sufficiently connects Morris’s exemption request to his religious ... beliefs.

An employee plausibly alleges a religious belief under § 2000e(j) when the complaint connects the vaccine objection to religious convictions.

Scodtt · filed 2025-09-03(j)

For the second inquiry, i.e. whether the purported beliefs are religious, Plaintiff has sufficiently alleged her beliefs were religious in nature. ... These allegations are sufficient to establish that Plaintiff had a bona fide religious belief.

Section 2000e(j) requires an employee seeking a religious accommodation to identify a religious belief or practice that conflicts with the employment requirement; an objection based only on moral conscience does not suffice.

Bowlin v. Board of Directors, Judah Christian School · filed 2026-03-06(j)

... here, Plaintiffs do not moor their objections to the testing requirement to any religious beliefs.

Section 2000e(j) requires a religious basis for an accommodation request; sincerely held personal or moral objections alone do not qualify.

Hodges · filed 2026-03-13(j)

Hodges’s objection to testing may have been based on sincerely held moral or personal views. But that is not enough to state a viable religious discrimination claim under Title VII.

Section 2000e(j) includes religious beliefs in Title VII’s definition of religion, so discrimination because of those beliefs is religious discrimination.

Brown v. Alaska Airlines, Inc. · filed 2026-06-24(j)

This case involves claimed discrimination on the basis of plaintiffs’ religious beliefs. Title VII defines “religion” to ... “include[] all aspects of religious observance and practice, as well as belief.” 42 U.S.C. § 2000e(j). Accordingly, “[d]iscrimination on the basis of religious beliefs is discrimination on the basis of religion for purposes of Title VII.” Damiano, 140 F.4th at 1155 (citing Groff v. DeJoy, 600 U.S. 447, 458 (2023)).

Section 2000e(j) covers religious beliefs and practices, including vaccine objections that overlap with secular concerns, but does not cover purely secular preferences.

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

The term “religion” encompasses all aspects of religious practice and belief. 42 U.S.C. § 2000e(j); Peterson v. Hewlett–Packard Co., 358 F.3d 599, 602 (9th Cir. 2004). ... Title VII does not protect medical, economic, political, or social preferences. ... However, overlapping secular and religious objections do not place a requested accommodation outside the scope of Title VII. Id.

Section 2000e(j)'s definition of religion can cover an objection to workplace testing when the complaint plausibly connects it to religious beliefs, even if the employee also gives secular reasons.

Prida v. Option Care Enters., Inc. · filed 2025-02-11(j)

Thus, Prida sufficiently pled that refusing weekly Covid testing was an aspect of her religious belief.

Section 2000e(j)'s definition of religion excludes medical, economic, political, social, and personal preferences.

Piccolo v. Mayo Clinic · filed 2025-03-13(j)

Title VII does not protect medical, economic, political, social, or personal preferences.

Section 2000e(j) requires a religious accommodation plaintiff to allege an actual conflict between a religious belief and an employment duty; conclusory assertions of conflict are insufficient.

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

The term “religion” encompasses all aspects of religious practice and belief. 42 U.S.C. § 2000e(j); Peterson v. Hewlett-Packard Co., 358 F.3d 599, 602 (9th Cir. 2004). ... Here, Plaintiff’s conclusory allegations are insufficient to state a claim under Rule 12(b)(6).

Section 2000e(j) includes sincerely held religious beliefs within its definition of religion, and a factual dispute about sincerity can preclude summary judgment.

ROBINSON · filed 2025-12-19(j)

This court finds that genuine disputes of material fact preclude summary judgment on the first prong of sincerity.

Section 2000e(h)'s definition of industry affecting commerce can cover a college whose students and faculty come from across the country; those allegations suffice to survive a motion to dismiss.

Presseisen v. Swarthmore College · filed 1974-12-13(h)

In § 2000e(h), the phrase “industry affecting commerce” is further defined as an activity or industry affecting commerce within the meaning of the Labor-Management Reporting and Disclosure Act of 1959. ... Viewing the above averment as true and in the light most favorable to the plaintiff, the Court is unable to conclude that the plaintiff would not be able to prove that Swarthmore College is engaged in an “activity affecting commerce” under any state of facts which could be established.

Section 2000e(h) requires a substantial economic effect on interstate commerce for an activity to qualify as an industry affecting commerce.

Graves v. Methodist Youth Services, Inc. · filed 1985-12-24(h)

Although there is no set of standards an activity must meet in order to determine whether it affected commerce within the meaning of the Civil Rights Act of 1964, the economic effect on interstate commerce must be substantial.

Section 2000e(h) includes governmental activities in the definition of an industry affecting commerce, including a public housing authority.

Leveen v. Stratford Housing Authority · filed 1986-01-13(h)

42 U.S.C. § 2000e(h) states that "industry affecting commerce" includes any governmental industry, business, or activity. The Court finds that the defendant S.H.A. is clearly such a governmental industry in that the S.H.A. was created to administer and maintain state and federally assisted public housing in the Town of Stratford in accordance with state and federal law.

Section 2000e(h) includes nonprofit and charitable organizations in its definition of an industry affecting commerce when their activities affect interstate commerce.

Martin v. United Way of Erie County · filed 1987-09-23(h)

Although the term “industry affecting commerce” may suggest a limitation to commercial enterprises, it is clear that Congress intended to cover all activities affecting commerce, to the extent permitted by the Constitution, regardless of whether they are operated for non-profit or charitable purposes.

Section 2000e(h) broadly defines an industry affecting commerce; a factual dispute over whether a business meets that definition prevents summary judgment.

Equal Employment Opportunity Commission v. Ratliff · filed 1990-06-21(h)

These affidavits demonstrate that there was a genuine issue of fact as to whether the Spa was engaged in an industry affecting commerce, especially given how little it takes to establish that fact.

Section 2000e(b) covers a nonprofit employer whose activities affect commerce, even when its connections to commerce are small.

EEOC v. Assn of Community · filed 1996-03-26(b)

These connections to commerce may be small in absolute terms, but they are sufficient to characterize ACORN as an employer that affects commerce under the purview of Title VII.

Section 2000e(h) covers a school as an industry affecting commerce when its purchases, employees’ commutes, and communications cross state lines.

Equal Employment Opportunity Commission v. St. Francis Xavier Parochial School · filed 1996-06-04(h)

The ADA refers to 42 U.S.C. § 2000e: “The term ‘industry affecting commerce’ means any activity, business, or industry in commerce or in which a labor dispute would hinder or obstruct commerce or the free flow of commerce.” ... The effect of the School’s conduct on interstate commerce is sufficiently “substantial” to place it within the ambit of the Act.

Section 2000e(b) can cover a labor organization as an employer, and subsection (h) can cover its work as an industry affecting commerce.

Doe v. AFL-CIO, Department of Organization, Region 6 · filed 1975-12-17(b), (h)

The defendant is an employer within the meaning of 42 U.S.C. § 2000e(b), and is engaged in an industry affecting commerce within the meaning of 42 U.S.C. § 2000e(h).

A manufacturer and seller of miniature lamps and related components operates in an industry affecting commerce under § 2000e(g) and (h).

Equal Employment Opportunity Commission v. Chicago Miniature Lamp Works · filed 1985-10-30(g), (h)

Chicago Miniature was and is now an employer in an industry affecting commerce within the meaning of Sections 2000e(g) and (h) (Stip. ¶ 2).

Section 2000e(h) covers a school board’s governmental activity affecting commerce.

Mira v. Monroe County School Board · filed 1988-05-31(h)

Defendant School Board is engaged in a governmental activity affecting commerce under 42 U.S.C. § 2000e(h).

Section 2000e(h) defines an industry affecting commerce for Title VII coverage.

Equal Employment Opportunity Commission v. O & G Spring & Wire Forms Specialty Co. · filed 1988-12-14(h)

0 & G is an employer in an industry affecting commerce within the meaning of 42 U.S.C. §§ 2000e(g), (h) and 29 U.S.C. § 203.

Section 2000e(b)’s private membership club exception requires more than tax-exempt status.

Price v. Southern Ale House LLC · filed 2024-12-27(b)

Pi Kappa Phi’s tax-exempt status is insufficient to trigger the private membership club exception to Title VII. See 42 U.S.C. § 2000e(b).

Section 2000e(b)’s private membership club exemption does not cover a nursing home that does not resemble a private club.

Mills v. Fox · filed 1976-10-21(b)

Therefore, construing the Act liberally and considering that the Home does not resemble a private club, this Court holds that the Home is not exempt from coverage under 42 U.S.C. § 2000e(b), and so defendants’ motion to dismiss under FRCP 12(b)(1) must be denied.

Section 2000e(b)'s private membership club exemption does not extend to a retirement home merely because its sponsoring organization is a private club; the home must qualify independently.

Fesel v. Masonic Home of Delaware, Inc. · filed 1977-03-14(b)

If the Home is a private membership club, it must establish its status as such independently. ... Thus, the Home is without a membership of the kind that would be entitled to claim the exemption.

Section 2000e(b) excludes a bona fide private membership club from the Title VII definition of employer when the club is exempt from taxation under Internal Revenue Code § 501(c).

Ahmad v. Independent Order of Foresters · filed 1979-03-08(b)

That statute, at 42 U.S.C. § 2000e(b), excludes from the definition of employer “a bona fide private membership club (other than a labor organization) which is exempt from taxation under section 501(c) of [the Internal Revenue Code of 1954] . . . .” The defendant notes that it is exempt from taxation under section 501(c)(8) of the IRS Code of 1954, and has submitted a copy of the document granting it such tax-exempt status. However, as the plaintiffs correctly argue, the matter does not end there. It is for us to determine not only whether the defendant is tax-exempt, but also whether it is indeed a “bona fide private membership club”.

Section 2000e(b)(2)’s private membership club exemption did not remove this credit union from Title VII’s employer definition.

Carol QUIJANO Et Al., Plaintiffs-Appellants, v. UNIVERSITY FEDERAL CREDIT UNION, Defendant-Appellee · filed 1980-05-15(b)(2)

The credit union’s position that it is not an employer within Title VII’s definition of that term because of its claimed status as a “bona fide private membership club”, is patently without merit.

Section 2000e(b)(2) excludes bona fide private membership clubs from Title VII’s definition of employer; the court held that this exemption also bars § 1981 claims against such a club.

Kemerer v. Davis · filed 1981-08-21(b)(2)

Accordingly, having concluded that private membership clubs are impliedly exempted from the provisions of 1981 by virtue of the explicit, conflicting and therefore superseding exemption of Title VII, and having found that the Bay City Country Club is such a “bona fide private membership club,” plaintiff’s cause of action against the Club must be DISMISSED for lack of jurisdiction.

Section 2000e(b) excludes a qualifying private membership club from Title VII’s definition of an employer.

Hudson v. Charlotte Country Club, Inc. · filed 1982-04-01(b)

However, Section 2000e(b) specifically excludes “a bona fide private membership club . . . which is exempt from taxation under Section 501(c) of the Internal Revenue Code ...” as an “employer” within the meaning of the Act. ... Consequently, based on the evidence presented, this Court finds that the Defendant “Charlotte Country Club, Inc.” is a private membership club within the meaning of the Act and hereby dismisses the Title VII claim of discrimination.

Section 2000e(b)(2)’s private club exemption does not apply to employment discrimination claims under § 1981.

Guesby v. Kennedy · filed 1984-02-21(b)(2)

We hold, therefore, that the bona fide private membership club exemption contained at 42 U.S.C. § 2000e(b)(2) does not apply to the case at bar.

Section 2000e(b) exempts tax-exempt bona fide private membership clubs from Title VII.

Baptiste v. Cavendish Club, Inc. · filed 1987-09-08(b)

Bona fide private membership clubs which are also exempt from tax under 26 U.S.C. § 501(c) are exempt from Title VII. ... Based on these factors, the Court finds that the Club is a bona fide membership club, and thus exempt from Title VII.

A club qualifies for the private membership club exception to Title VII’s definition of employer only if it is private and has meaningful limits on membership.

Equal Employment Opportunity Commission v. University Club · filed 1991-04-25(b)(2)

The University Club does not qualify as a private membership club because it is not private and it does not have meaningful conditions of limited membership.

Section 2000e(b)(2) excludes a tax-exempt bona fide private membership club from the definition of employer; a qualifying club must be private and impose meaningful limits on membership.

Kelsey v. University Club of Orlando, Inc. · filed 1994-03-10(b)(2)

Both the ADA and Title VII exempt bona fide private membership clubs from the statutory prohibitions by providing that the term “employer” does not include “a bona fide private membership club (other than a labor organization) that is exempt from taxation under section 501(e) of Title 26.” ... To qualify as a bona fide private membership club, defendant must show that it (1) is a club in the ordinary sense of the word; (2) is private as opposed to public; and (3) requires some meaningful conditions of limited membership.

Section 2000e(b)(2) excludes a bona fide private membership club from Title VII’s definition of employer without requiring proof that compliance would impair its members’ associational rights.

Equal Employment Opportunity Commission v. Chicago Club · filed 1995-03-31(b)(2)

Thus, plaintiffs argument that the exemption in Title VII for private membership clubs should be interpreted to apply only when the exemption is necessary to protect the associational rights of members is inconsistent with the language of the statute; is based on an improper method of statutory interpretation; and is not required by the legislative history cited.

Section 2000e(b)'s private membership club exemption covers the Chicago Club.

Equal Employment Opportunity Commission v. The Chicago Club · filed 1996-06-06(b)

The facts are undisputed, and it is absolutely clear that the Club is entitled to summary judgment as a matter of law for it more than easily qualifies under the bona fide private membership club exemption of § 2000e(b).

Section 2000e(b)(2) exempts bona fide private membership clubs from Title VII coverage.

Richard v. Friar's Club · filed 1997-09-18(b)(2)

Accordingly, the controlling issue is whether Friars Club qualifies as a "bona fide private membership club" exempted from Title VII coverage under 42 U.S.C. § 2000e(b)(2). To qualify, Friars Club must show three elements: that it "(1) is a club in the ordinary sense of the word, (2) is private, and (3) requires meaningful conditions of limited membership."

Section 2000e(b) excludes private membership clubs from the definition of an employer.

Barry v. Maple Bluff Country Club · filed 1998-09-03(b)

We disagree with footnote 5 in the Club's brief wherein it asserts that the language of 42 U.S.C. § 2000e(b) "exactly tracks" § 106.04(lm)(p)2., Stats. Rather, they form a sharp contrast with one another because private membership clubs are always excluded from the definition of an "employer" by § 2000e (b), while private nonprofit organizations are excluded from the definition of a "public accommodation" only during specified "events" set out in § 106.04(lm)(p)2.

Section 2000e(b)(2) excludes a bona fide private membership club exempt from taxation under § 501(c) from Title VII’s definition of employer.

Roman v. Concharty Council of Girl Scouts, Inc. · filed 2002-03-01(b)(2)

It is a tax exempt organization under Section 501(c)(3) of Title 26 of the United States Code. As a “bona fide private membership club,” Defendant is exempt from the requirements of Title VII of the Civil Rights Act of 1964 and the Americans with Disabilities Act.

Section 2000e(b)(2) excludes a bona fide private membership club from Title VII's definition of employer.

Estevez v. Faculty Club of the University of Washington · filed 2005-03-28(b)(2)

Thus, we hold that the Club does not have “meaningful conditions of limited membership” sufficient to qualify it for a “bona fide private club” exemption under 42 U.S.C. § 2000e(b)(2).

A tax-exempt bona fide private membership club is excluded from Title VII’s definition of employer even if nonmembers use its facilities on a limited basis.

Thomas v. The Buffalo Club · filed 2021-02-24(b)(2)

Contrary to the premise underlying Thomas’s arguments, there simply is no legal requirement that a bona fide private membership club serve only dues-paying members all the time.

Section 2000e(b) excludes a private membership club from Title VII's definition of employer.

Deonna v. Centre Hills Country Club · filed 2022-12-30(b)

Therefore, it concludes that CHCC is a private membership club under 42 U.S.C. § 2000e(b) and exempt from DeOnna’s Title VII suit.

Section 2000e(j) requires an employer to attempt reasonable religious accommodation, but an employee may forgo that right by refusing to use available means or cooperate with the employer’s efforts.

CHRYSLER CORPORATION, Appellant, v. Curtis L. MANN, Trustee in Bankruptcy of William H. Blakely, Appellee · filed 1977-09-14(j)

42 U.S.C. § 2000e(j) does not contain such a requirement, however. It simply provides that an employer must attempt a reasonable accommodation of an employee’s religious beliefs. Where, as here, an employee is disinterested in informing his employer of his religious needs and will not attempt to accommodate his own beliefs through the means already available to him or cooperate with his employer in its conciliatory efforts, he may forego the right to have his beliefs accommodated by his employer.

Section 2000e(j)'s reasonable accommodation duty does not require an employer to guarantee that an applicant will never have to work on her Sabbath when that demand cannot be accommodated without undue hardship.

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

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".

Section 2000e(j) requires reasonable accommodation of an employee’s religious practices unless 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(j)

We hold that § 701(j) requires that a reasonable accommodation be made or a showing that to do so would work an undue hardship.

Section 2000e(j) requires an employer to reasonably accommodate an employee’s religious practice unless doing so would cause undue hardship.

Equal Employment Opportunity Commission v. Picoma Industries, Inc. · filed 1978-07-26(j)

Under the circumstances presented in this action, the Court concludes that Pi-coma has made reasonable accommodations to Mr. McCracken’s religious practices and, in light of the flexibility already shown by Picoma, to grant Mr. McCracken an exemption to the weekly switch rule would work an undue hardship upon the employer.

Section 2000e(j) requires employers and unions to make good faith efforts to accommodate an employee’s religious beliefs and prove that no reasonable accommodation is possible without undue hardship.

Duane Terrell BURNS, Plaintiff-Appellant, v. SOUTHERN PACIFIC TRANSPORTATION CO. Et Al., Defendants-Appellees · filed 1979-01-08(j)

Thereafter the burden was on the Company and the Union to prove that they made good faith efforts to accommodate Burns’ religious beliefs, that the efforts were unsuccessful, and that they were unable reasonably to accommodate those beliefs without undue hardship. (42 U.S.C. § 2000e(j); Anderson v. General Dynamics Convair Aerospace Division, supra.)

Section 2000e(j) defines religion to include religious observance and practice unless the employer cannot reasonably accommodate them without undue hardship.

19 Fair empl.prac.cas. 584, 19 Empl. Prac. Dec. P 9104 Donald Wren v. t.i.m.e.-d.c., Inc. · filed 1979-04-03(j)

Thus, it is an unlawful employment practice for an employer not to make reasonable accommodations, short of undue hardship, for the religious practices of its employees.

Section 2000e(j) requires an employer to reasonably accommodate an employee’s religious observance or practice unless doing so would cause undue hardship.

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

On this basis, therefore, defendant cannot meet the “undue hardship” test of section 703(a)(1).

Section 2000e(j) requires employers to consider reasonable accommodation of religious observance even when accommodation treats an employee differently.

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

Carried to its logical conclusion the court’s application of the quoted language would preclude all forms of accommodation and defeat the very purpose behind § 2000e(j). ... Accordingly, finding that a proposed accommodation would entail some form of discrimination does not end the inquiry.

Section 2000e(j) places the burden on an employer and union to show good-faith efforts to accommodate an employee’s religious beliefs and that reasonable accommodation was unsuccessful without undue hardship.

Kenneth R. YOTT, Plaintiff-Appellant v. NORTH AMERICAN ROCKWELL CORPORATION · filed 1979-08-21(j)

Yott having established that he had a belief that union membership and payment of union dues were contrary to his religion, that he had informed Rockwell and Local 887 about his religious beliefs and that he was discharged for failure to join the union or pay union dues, the burden shifted to Rockwell and Local 887. Specifically, Rockwell and Local 887 had the burden to show that they had made good faith efforts to accommodate Yott's religious beliefs, and that the efforts were unsuccessful in reasonably accommodating those beliefs without undue hardship.

Section 2000e(j)'s religious accommodation inquiry may consider hardship to a labor union.

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

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(j) requires an employer to reasonably accommodate an employee’s religious observance unless doing so would impose undue hardship on its business.

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

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(j) requires reasonable accommodation of an employee’s religious observance unless it would cause undue hardship.

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

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(j) requires religious accommodation, and whether an employer’s reassignment offer satisfied that requirement can be a material factual question.

Charles R. GAVIN, Appellant, v. PEOPLES NATURAL GAS COMPANY · filed 1980-01-16(j)

Here PNGC is charged with failing to accommodate to Gavin’s religious beliefs in violation of Section 701(j). ... Accommodation remains a genuine issue because the district court made no findings, and the parties have not stipulated, as to whether PNGC’s offer of reinstatement as a gas man made to Gavin on June 14, 1979 constituted compliance with the provisions of Title VII which mandate accommodation of religion.

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

Nottelson v. Department of Industry, Labor & Human Relations · filed 1980-02-07(j)

The intent and effect of the definition of religion in the act is clear: it is an unlawful employment practice for an employer not to make reasonable accommodation for the religious practices of employees, short of incurring undue hardship.

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

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

Title VII’s prohibition against religious discrimination is created by the interplay of sections 2000e(j) and 2000e-2(a)(l). Together these sections make it an unlawful employment practice if an employer fails to make a reasonable accommodation to the religious practices of its employees, unless such an accommodation would impose an undue hardship on its business.

Section 2000e(j)'s religious accommodation duty applies only to employers prohibited from religious discrimination.

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

The short answer to this contention is that the duty to accommodate applies only to those employers who are prohibited from religious discrimination. The import of § 701(j) is to equate the failure to accommodate with discrimination.

Section 2000e(j) defines religion to include religious observance, practice, and belief, subject to an employer’s undue hardship defense.

Isaac v. Butler's Shoe Corp. · filed 1980-12-19(j)

Accordingly, the court holds that the religious accommodation provision of Title VII, 42 U.S.C. § 2000e(j), violates the establishment clause of the first amendment to the United States Constitution.

Section 2000e(j) requires an employer to reasonably accommodate an employee’s religious observance or practice unless doing so would cause undue hardship.

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

Nevertheless, it is the opinion of this court that proof of an effort by the defendant to accommodate the religious practices of an employee is required before that defendant can be allowed to raise the further defense of undue hardship.

Section 2000e(j) requires employers to accommodate religious observance, practice, and belief unless the accommodation causes undue hardship.

Nottelson v. Smith Steel Workers · filed 1981-04-20(j)

Section 701(j), by prohibiting unreasonable refusal to accommodate religiously motivated conduct and practices as well as beliefs, is plainly intended to protect the employment opportunities not only of the victims of overt discrimination but also of individuals who are unintentionally discriminated against because their religious convictions are not reflected in facially neutral majoritarian rules.

Section 2000e(j)'s religious accommodation provision is constitutional under the Establishment Clause.

Anderson v. General Dynamics Convair Aerospace Division · filed 1981-06-23(j)

This appeal squarely poses the issue of the constitutionality of 42 U.S.C. § 2000e-2(a) & (c) and 42 U.S.C. § 2000e(j). We hold that those provisions of Title VII are constitutional for the reasons expressed in our opinion in Tooley v. Martin Marietta Corp., 648 F.2d 1239 (9th Cir. 1981), which was argued with this case, on the same date, before this panel.

Section 2000e(j) places the burden of religious accommodation on the employer but requires the employee to make a good faith effort to use the means the employer offers.

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

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(j) requires reasonable accommodation of religious observance unless it would cause undue hardship; granting leave can satisfy that duty when rescheduling a meeting would cause undue hardship.

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

Third, Defendants made a reasonable accommodation to Reichman’s observance of Yom Kippur. Rescheduling of the meeting would have caused an undue hardship because employees of approximately forty state agencies were attending. Nevertheless, Reichman’s request for leave with pay was approved and she was not required to attend the meeting.

Section 2000e(j) requires reasonable religious accommodation, but an employer need not use the employee’s preferred method or spare every cost.

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

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.

Section 2000e(j) requires an employer to make good faith efforts to accommodate religious beliefs, but does not require overriding an established seniority system or taking steps beyond those a reasonable person would take.

Johnnie F. TURPEN, Plaintiff-Appellant, v. MISSOURI-KANSAS-TEXAS RAILROAD COMPANY, Defendant-Appellee · filed 1984-07-19(j)

Section 701(j) mandates that an employer make good faith efforts to accommodate an employee’s religious beliefs. It does not require that in doing so an employer override an established seniority system, nor does it require an employer to take steps that go beyond those that a reasonable person would take.

Section 2000e(j) requires employers and unions to make good faith efforts to accommodate an employee’s religious beliefs, but does not require them to override a collective bargaining agreement.

Equal Employment Opportunity Commission v. Caribe Hilton International · filed 1984-10-25(j)

In sum, Section 2000e(j) mandates that an employer and the union make good faith efforts to accommodate an employee’s religious beliefs. It does not require that in so doing they override an established collective bargaining agreement.

Section 2000e(j) requires an employer to attempt to accommodate an employee’s religious practices unless doing so would cause undue hardship.

Baz v. Walters · filed 1984-11-19(j)

The requirements of the statute and of the Code of Federal Regulations that the employer attempt to accommodate the religious precepts and demands of an employee unless undue hardship would be incurred by the employer are also satisfied in this case.

Section 2000e(j)’s religious accommodation requirement does not violate the Establishment Clause because it has a secular purpose, neither advances nor inhibits religion as its primary effect, and avoids excessive government entanglement.

Equal Employment Opportunity Commission v. E.I. DuPont de Nemours & Co. · filed 1985-05-17(j)

Section 2000e(j) passes the three-pronged Nyquist test. It does not represent an unconstitutional governmental establishment of religion. As it reflects a clearly secular purpose, its primary effect neither inhibits nor advances religion and it avoids excessive governmental entanglement with religion.

Section 2000e(j) requires reasonable accommodation of an employee’s religious practice, but does not require an employer to violate a valid collective bargaining agreement.

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

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.

Section 2000e(j) does not require an employer to make a special exception to a bona fide seniority system to accommodate an employee’s religious observance.

Gibson v. Missouri Pacific Railroad · filed 1985-10-29(j)

MoPac has no obligation under Title VII to make a special exception to its seniority system in order to help plaintiff meet his religious obligations.

Section 2000e(j) requires an employer to reasonably accommodate an employee’s religious practices unless doing so would cause undue hardship; constitutional limits can restrict the accommodations available to a public employer.

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

The Court concludes that defendant County, acting through Sheriff Heffron, made every effort at accommodation reasonably available under the circumstances.

Section 2000e(j) requires reasonable accommodation of religious observance unless it would cause undue hardship; allowing Sabbath absences and offering available hours can satisfy that duty.

Benefield v. Food Giant, Inc. · filed 1985-12-04(j)

The Court concludes that the Defendant made reasonable accommodation to the Plaintiff’s religious beliefs by permitting him to be absent during the sabbath work hours and by endeavoring to and in fact giving him as many hours as were available consistent with the store scheduling requirements.

Section 2000e(j) does not require an employer to adopt an employee’s religious approach to patient care or continually monitor it as an accommodation.

Baz v. Walters · filed 1986-01-28(j)

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 2000e(j) requires an employer to accommodate an employee’s religious beliefs in a way that 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(j)

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(j) requires an employer to reasonably accommodate a prospective employee’s religious practice unless the employer shows that accommodation would cause undue hardship.

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

In conjunction with § 2000e-2(a), subsection (j) requires that an employer not discriminate against any religious observance, practice or belief “unless an employer demonstrates that he is unable to reasonably accommodate to an employee’s or prospective employee’s religious observance or practice without undue hardship on the conduct of the employer’s business.” 42 U.S.C. § 2000e(j). ... I conclude that Nobel could have accommodated Toledo’s religious practice without undue hardship by restricting his practice slightly, and that the accommodation offer of July 10, 1984, was reasonable.

Section 2000e(j) protects religious observance that prohibits all Sabbath work, so a request for every Sabbath off invokes the employer’s duty to accommodate.

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

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(j) requires an employer to initiate good faith efforts to accommodate an employee’s religious practice in a new position, even if it accommodated the employee in a previous position.

Corine Proctor v. Consolidated Freightways Corporation of Delaware, a Delaware Corporation · filed 1986-08-01(j)

The fact that Proctor applied for a position which she knew required Saturday work thus does not exempt Consolidated from its statutory duty to initiate a good faith effort to accommodate her in that position.

Section 2000e(j) allows a religious objector to make substitute charitable payments instead of joining or financially supporting a union, without requiring membership in a religious organization.

International Ass'n of MacHinists & Aerospace Workers, District Lodge 751 v. Boeing Co. · filed 1986-11-03(j)

Nichols does not argue that she belongs to such a sect, and bases her claim entirely on Title VII, which does not make membership in a religious organization a prerequisite for exemption. ... Defendant Nichols had the right, under the religious accommodation provision of Title VII, to make a substituted charitable payment in lieu of joining or financially supporting the union.

Section 2000e(j) requires employers to reasonably accommodate employees’ religious practices even when their scheduling rules are facially neutral, unless accommodation would cause undue hardship.

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

That notion clearly flies in the face of § 2000e(j). In the context of religious beliefs, it is not enough that an employer has adopted certain practices which are facially neutral.

Section 2000e(j)'s duty of reasonable religious accommodation does not require an employer to discriminate against other employees so one employee can observe a Sabbath.

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

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

Section 2000e(j) allows a charitable contribution in place of union dues as a reasonable religious accommodation and does not violate the Establishment Clause.

International Association Of Machinists & Aerospace Workers, Lodge 751 v. The Boeing Company · filed 1987-11-27(j)

Accordingly, we need not reconsider the holdings we made in Tooley: the substituted charitable contribution is a reasonable accommodation under section 701(j), and section 701(j) does not violate the Establishment Clause.

Section 2000e(j) requires religious accommodations that are reasonable and do not cause undue hardship.

International Ass'n of Machinists Workers, Local 751 v. Boeing Co. · filed 1987-11-27(j)

By its terms section 701(j) is flexible, requiring only those accommodations which are reasonable and which may be accomplished without undue hardship.

Section 2000e(j) does not require an employer to operate its business in the manner a court considers safe and efficient to accommodate an employee's religious observance.

Thomas Harold LAKE, Plaintiff-Appellee, v. B.F. GOODRICH COMPANY, Defendant-Appellant · filed 1988-03-21(j)

We agree with appellant that Title VII does not require an employer to operate its business in a manner the district court considers safe and efficient.

Section 2000e(j) requires an employer to offer a reasonable accommodation for an employee’s religious practice; the offer need not be presented as an ultimatum.

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

The fact that it was not offered in the form of an ultimatum does not diminish the force or status of the offer as an attempt to accommodate the Plaintiff’s religious practices. The law requires only that the employer afford a reasonable accommodation.

Section 2000e(j) requires an employer to offer reasonable accommodation for an employee’s Sabbath observance, even if the employee refuses all Sabbath work, unless accommodation would cause undue hardship.

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

Section 701(j) clearly anticipates that some employees will absolutely refuse to work on their Sabbath and that this firmly held religious belief requires some offer of accommodation by employers.

Section 2000e(j) requires reasonable accommodation of religious practice, but an employee who does not use reasonable accommodations already provided cannot demand further ones.

Bruce HUDSON, Plaintiff-Appellant, v. WESTERN AIRLINES, INC., Defendant-Appellee · filed 1988-07-01(j)

As the trial court found, Western provided reasonable means to eliminate her conflicts. Western and AFA both pointed out to Hudson her options under the collective bargaining agreement. Title VII does not allow Hudson to ignore these reasonable accommodations and then demand further accommodations when she subsequently developed a conflict.

Section 2000e(j) requires an employer that has not resolved an employee's religious conflict to accept the employee's proposed accommodation or demonstrate undue hardship.

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

When an employer does not propose an accommodation, or when its proposed accommodation does not eliminate the employee's religious conflict, the employer must accept the employee's proposal or demonstrate that the proposal would cause the employer undue hardship.

Section 2000e(j) requires employers to take reasonable steps to accommodate religious practice, while employees must make a good faith attempt to use means the employer offers to meet their needs.

Cary v. Anheuser-Busch, Inc. · filed 1988-12-16(j)

While employers must take reasonable steps to accommodate an employee’s religious observance or practice, ... the employee has a correlative duty to make a good faith attempt to satisfy his needs through means offered by the employer. ... Cary could have most easily marked “refused” on the overtime canvass sheet for that day. He did not mark the sheet and admitted that this was why he was required to work overtime on March 8. Cary Deposition at 87. Anheuser-Busch is entitled to judgment on this claim also.

Section 2000e(j) requires an employer that offers no religious accommodation to accept the employee’s proposal or show that it would cause undue hardship.

Equal Employment Opportunity Commission v. Hacienda Hotel · filed 1989-08-10(j)

If the employer does not propose an accommodation, the employer must accept the employee’s proposal or demonstrate that the proposal would cause the employer undue hardship.

Section 2000e(j)'s religious accommodation duty can be satisfied by a program that encourages voluntary shift swaps.

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

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

Section 2000e(j) requires an employer that acts against an employee or applicant without first attempting religious accommodation to show that no accommodation was possible without undue hardship.

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

Accordingly, we hold that an employer who has made no efforts to accommodate the religious beliefs of an employee or applicant before taking action against him may only prevail if it shows that no accommodation could have been made without undue hardship. Absent this showing, failure to attempt some reasonable accommodation would breach the employer’s duty to initiate accommodation of religious practices.

Section 2000e(j) requires reasonable accommodation of religious practice; a rebate limiting union fees to collective bargaining expenses can satisfy that duty.

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

Consistent with the Supreme Court’s findings, therefore, this Court need only find that defendants’ proposed accommodations are reasonable. We so find. ... Consequently, we hold that defendant union has complied with its statutory obligation under Title VII.

Section 2000e(j) requires a reasonable accommodation to address the employee’s sincere religious conflict with an employment requirement, including each distinct part of that conflict.

Equal Employment Opportunity Commission v. University of Detroit · filed 1990-04-17(j)

Since the sincerity of Roesser’s religious belief was taken as true for the purposes of ruling on the motion for summary judgment, the district court erred in concluding that an accommodation offered by an employer which does not even address, let alone resolve, the employee’s conflict is reasonable as a matter of law. The duty to accommodate cannot be defined without reference to the specific religious belief at issue.

Section 2000e(j) requires an employer to address each aspect of an employee’s sincere religious belief that conflicts with a work requirement, unless accommodation would cause undue hardship.

Equal Employment Opportunity Commission v. University of Detroit · filed 1990-05-31(j)

Since the sincerity of Roesser's religious belief was taken as true for the purposes of ruling on the motion for summary judgment, the district court erred in concluding that an accommodation offered by an employer which does not even address, let alone resolve, the employee's conflict is reasonable as a matter of law. The duty to accommodate cannot be defined without reference to the specific religious belief at issue.

Section 2000e(j) requires reasonable accommodation of religious practice, but an employee’s refusal to cooperate with an employer’s efforts may make accommodation impossible.

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

Because Riselay did not cooperate with his employer in its attempt to accommodate his religious beliefs, he rendered an accommodation impossible.

Section 2000e(j) requires an employer to reasonably accommodate an employee's religious practices and beliefs unless doing so would impose an undue hardship.

McGuire v. General Motors Corporation · filed 1992-02-12(j)

Title VII requires that an employer offer a reasonable accommodation of an employee’s religious practices and beliefs or demonstrate that it could not reasonably accommodate the employee without incurring undue hardship. 42 U.S.C. § 2000e(j).

Section 2000e(j) requires an employer to reasonably accommodate an employee's religious practice unless accommodation would impose undue hardship on its business.

Hiatt v. Walker Chevrolet Co. · filed 1992-10-08(j)

If a prima facie case is established, the burden shifts to the employer to show that it attempted in good faith to accommodate the religious practices of the employee, thus discharging its statutory duty to the employee; or it may show that accommodation of the religious practice cannot be made without undue hardship on the business of the employer.

Section 2000e(j) protects sincerely held religious practices and requires employers to accommodate them unless doing so would cause undue hardship.

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

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(j) requires an employer to provide a reasonable accommodation for religious practice, but offering one reasonable accommodation satisfies that obligation.

Wright v. Marvin Runyon, Postmaster General · filed 1993-08-10(j)

The USPS admittedly did not investigate every possible way in which Wright could avoid a conflict between his work requirements and his religious practices. But, by providing at least one reasonable accommodation, the USPS discharged its obligations.

Section 2000e(j) does not require an employer to abandon a collective bargaining agreement’s seniority system to accommodate an employee’s religious practice.

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

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.

Section 2000e(j) does not treat requiring an employee to use accrued vacation as the only way to avoid mandatory Sabbath work as a reasonable religious accommodation.

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

An employer who permits an employee to avoid mandatory Sabbath work only by using accrued vacation does not “reasonably accommodate” the employee’s religious beliefs.

Section 2000e(j) can require an employer to reasonably accommodate an employee’s religious beliefs even when the employer did not intentionally discriminate.

Ron Tonkin Chevrolet Co. v. Continental Insurance · filed 1994-03-09(j)

Religious accommodation employment discrimination need not be intentional. If proof that the defendant intentionally discriminated because of the plaintiffs religious beliefs were required, it would be a defense that the defendant was merely applying a neutral employment practice strictly and evenhandedly. Permitting that defense would undermine the apparent purpose of the religious accommodation action, which is to require employers to reasonably accommodate the religious beliefs of employees when those beliefs conflict with neutral employment practices.

Section 2000e(j) requires an employer to thoroughly explore ways to accommodate an employee’s religious practice and assess undue hardship based on facts.

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

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(j) requires reasonable accommodation of religious practice unless it causes undue hardship; allowing voluntary shift swaps within a neutral rotating schedule can satisfy that duty.

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

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.

Section 2000e(j) requires an employer to reasonably accommodate an employee’s religious observance unless the employer shows that accommodation would cause undue hardship.

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

This section has been interpreted to mean “that an employer, short of ‘undue hardship,’ [is required to] make ‘reasonable accommodations’ to the religious needs of its employees.” ... The court concludes that defendant has failed to establish that accommodation of Glukhovsky’s and Tomilina’s request for a day off for religious observance would have created undue hardsMp.

Section 2000e(j) does not require an employee to explicitly request religious accommodation when the employer is aware of the conflict between the employee's religious practices and job requirements.

Isaiah Brown v. Polk County, Iowa, a Municipal Corporation Ray Sears, Former County Administrator for Polk County and Po · filed 1995-09-21(j)

Preliminarily, we reject the defendants' argument that because Mr. Brown never explicitly asked for accommodation for his religious activities, he may not claim the protections of Title VII.

Section 2000e(j) requires an employer to reasonably accommodate an employee’s religious beliefs when a workplace policy conflicts with them.

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

However, such a policy applied in this case would violate Title VIPs requirements that an employer provide reasonable accommodation to an employee’s religious beliefs. 42 U.S.C. § 2000e(j).

Section 2000e(j) permits an employer to meet its religious accommodation duty by allowing an employee to arrange substitute shifts for Sabbath work.

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

Nevertheless, the defendant met his initial burden of showing an absence of evidence to support Cowan's claim, after he presented evidence that he reasonably accommodated Cowan's religious beliefs. 42 U.S.C. § 2000e(j); Smith, 827 F.2d at 1085. Cowan's employer permitted her to secure a substitute for her shift any time she was scheduled to work on her Sabbath Day. She was permitted to use the employer's bulletin board to notify co-workers of her interest in swapping shifts, when necessary. This policy was sufficient to meet the employer's accommodation obligation under Title VII.

A union may have to accommodate a religious objection to shop fees by allowing payment to charity when a rebate does not address the objection and the union shows no undue hardship.

Eeoc v. Am. Fed. of State, County & Mun. Emp. · filed 1996-06-14(j)

It is only through redirecting the funds entirely that Kelly's religious objections are fully met. ... No such showing has been made here. As such, plaintiffs are entitled to summary judgment in their favor, allowing Kelly to pay an amount equal to his shop fee to an agreed upon charitable organization.

Section 2000e(j) requires reasonable accommodation of religious objections to union shop fees unless the union shows undue hardship; payment to an agreed charity can provide that accommodation.

Equal Employment Opportunity Commission v. American Federation of State, County & Municipal Employees · filed 1996-06-14(j)

No such showing has been made here. As such, plaintiffs are entitled to summary judgment in their favor, allowing Kelly to pay an amount equal to his shop fee to an agreed upon charitable organization.

Section 2000e(j) places the burden on an employer to show that it could not reasonably accommodate an employee’s religious practice without undue hardship once the employee establishes a prima facie case.

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

The burden shifts to Huntsville ISD to show that it could not reasonably accommodate plaintiffs, without undue hardship.

Section 2000e(j) requires an employer to reasonably accommodate an employee’s religious practice unless the employer shows undue hardship; offering a different day off does not suffice when it leaves the conflict unresolved.

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

Somewhat awkwardly, this definition also gives substance to Title VII’s prohibition against religious discrimination by imposing an affirmative duty on employers to reasonably accommodate the religious observances and practices of its employees, unless the employer can demonstrate that such an accommodation would cause undue hardship to the conduct of its business. ... 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(j) requires employers to reasonably accommodate religious practices unless they show that every possible accommodation would cause undue hardship.

OPUKU-BOATENG v. STATE OF CALIFORNIA · filed 1996-11-19(j)

Only if the employer can show that no accommodation would be possible without undue hardship is it excused from taking the necessary steps to accommodate the employee's religious beliefs.

Section 2000e(j) requires an employer to reasonably accommodate an employee’s religious practice unless the accommodation would cause undue hardship.

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

Therefore the issue is whether defendant’s refusal to accommodate plaintiffs’ religious speech violated its obligation under § 701(j) to reasonably accommodate its employees’ religious observance or practice without undue hardship on the conduct of its business. 42 U.S.C. § 2000e(j). ... 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.

Section 2000e(j)’s accommodation duty gives an employee a religious-discrimination theory distinct from disparate treatment.

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

Because this definition includes a requirement that an employer "accommodate" an employee's religious expression, an employee is not limited to the disparate treatment theory to establish a discrimination claim.

An accommodation under § 2000e(j) is not reasonable if it leaves the conflict between the job requirement and religious practice unresolved.

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

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(j) includes religious observance and practice in the definition of religion unless the employer cannot reasonably accommodate them without undue hardship.

Breech v. Alabama Power Co. · filed 1997-04-15(j)

In addition, Title VII imposes an affirmative obligation on an employer to attempt to reasonably accommodate an employee’s religious observances or practices. Section 701(j), codified as 42 U.S.C. § 2000e(j), states that “[t]he term ‘religion’ includes all aspects of religious observance and practice, as well as belief, unless an employer demonstrates that he is unable to reasonably accommodate to an employee’s or prospective employee’s religious observance or practice without undue hardship on the conduct of the employer’s business.”