Statute Annotations › Federal › 42 U.S.C. § 2000e

42 U.S.C. § 2000e

Definitions: the cases that interpreted this section

Jurisdiction
Federal
Case notes
3,833
Cited in passing
30,154
Citing cases indexed
37,736
Case dates
1967–2026
Screened through
2026-06-29
Checked for later law changes
2026-10-20
Courts' treatment: live
No reviewed case has held this section invalid, preempted, superseded or repealed.
This reflects what the reviewed cases said, not legislative action: a later amendment or repeal by the legislature would not appear here unless a reviewed case discussed it.

33,987 citing cases reviewed of 37,736 in the citation index: 3,833 interpreted the section (annotated below), 30,154 cited it only in passing. Cases filed after 2026-06-29 may not have been reviewed yet.

Have a situation under 42 U.S.C. § 2000e?

These notes show how courts have ruled. Ask about your specific facts and see which of these rulings apply, with citations you can check.

Constitutionality of religious accommodation requirement

Section 2000e(j) defines religion to include religious observance, practice, and belief and requires reasonable accommodation absent undue hardship.

Pedersen v. Casey's General Stores, Inc. · filed 1997-09-29(j)

Fourth, Casey’s has a defense to liability if it (1) offered a reasonable accommodation to the manner in which Pedersen proposed to observe her religious beliefs or (2) was unable reasonably to accommodate Pedersen’s religious beliefs without undue hardship. See 42 U.S.C. § 2000e(j) (“The 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 ... religious observance or practice without undue hardship on the conduct of the employer’s business.”). The burden to prove this defense is on Casey’s. See Brown, 601 F.2d at 961 (stating that General Motors, the defendant, had the “burden of proving undue hardship”).
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Section 2000e(j) requires a bona fide religious belief that conflicts with an employment requirement for a failure-to-accommodate claim.

Gunning v. Runyon · filed 1998-04-17(j)

There is no evidence that Plaintiff possesses a bona fide religious belief that conflicts with an employment requirement.
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Employing a worker without a Social Security number would cause undue hardship under the religious accommodation rule of § 2000e(j).

Weber v. Leaseway Dedicated Logistics, Inc. · filed 1998-05-15(j)

Employing plaintiff without his social security number would amount to an undue hardship.
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Section 2000e(j) permits an employer to satisfy its duty of reasonable religious accommodation by offering a transfer that eliminates the conflict between an employee’s job duties and religious beliefs.

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

Because the CBA provided Officer Rodriguez with the option of transferring to a district without an abortion clinic and such a transfer would have eliminated the conflict between his job responsibilities and his religious beliefs, we conclude that the City has satisfied its duty of reasonable accommodation under Title VII.
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Section 2000e(j) requires a reasonable accommodation that addresses an employee’s religious objection to union membership unless doing so would cause undue hardship.

Eeoc v. Uia · filed 1998-12-17(j)

An employer does not satisfy subsection (j) if it disregards one of the faith-based objections of an employee.
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Section 2000e(j) requires an employer to reasonably accommodate religious practice unless the employer shows that accommodation would cause undue hardship.

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

The Defendant has failed to meet its burden of proving that no accommodation could have been made without incurring undue hardship. Because a reasonable trier of fact could find that Eckerd could have accommodated the Plaintiff without undue hardship, the Defendant is not entitled to judgment as a matter of law.
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Section 2000e(j) requires employers to accommodate religious beliefs once informed of them, unless accommodation would cause undue hardship.

Grant v. Joe Myers Toyota, Inc. · filed 2000-01-20(j)

Under both Title VII and the TCHRA, employers must accommodate religious beliefs once they are informed of them.
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Section 2000e(j) requires an employer to reasonably accommodate an employee’s religious observance unless doing so would cause undue hardship.

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

An employer has the statutory obligation to make reasonable accommodations for the religious observances of its employees, but is not required to incur undue hardship.
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Section 2000e(j) includes religious observance and practice within religion and requires reasonable accommodation unless it would cause undue hardship.

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

The statute defines “religion” to include “all aspects of religious observance and practice, as well as belief.” 42 U.S.C. § 2000e(j). Moreover, it imposes an affirmative duty on employers to accommodate reasonably the religious observances and practices of its employees, unless the employer can demonstrate that such an accommodation would cause undue hardship to its business.
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Section 2000e(j) requires reasonable accommodation of religious practices unless the accommodation would cause the employer undue hardship.

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

Gunite accommodated his tattoo depiction of his religious belief that many would view as a racist and violent symbol by allowing him to work with the tattoo covered; Title VII doesn’t require more.
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Section 2000e(j) requires a reasonable accommodation of an employee’s religious practice, but does not require the employer to offer the accommodation the employee prefers.

Durant v. Nynex · filed 2000-06-21(j)

This Court need not determine whether Durant’s proposed alternative accommodation is reasonable, since Title VII only requires that the employer propose a reasonable accommodation and does not require that the employer offer the specific accommodation the employee seeks.
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Section 2000e(j) requires employers to reasonably accommodate employees’ religious practices unless doing so would cause undue hardship; any reasonable accommodation satisfies that duty.

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

In short, the employer satisfies its Title VII religious accommodation obligation when it offers any reasonable accommodation.
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Section 2000e(j) requires reasonable accommodation of religious practices unless accommodation would cause undue hardship.

Hussein v. Hotel Employees & Restaurant Union, Local 6 · filed 2000-08-11(j)

Accordingly, I find, as a matter of law, that there is no reasonable accommodation the Union could make without causing undue hardship.
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Section 2000e(j) does not require an employer to grant an employee’s last-minute demand for an exception to a grooming policy when the circumstances prevent reasonable accommodation.

Hussein v. the Waldorf-Astoria · filed 2001-03-30(j)

Given the circumstances and the manner in which Hussein notified his employer of his need for accommodations at the last moment, the Waldorf was not obligated to comply with Hussein’s on-the-spot demand for an exception to its policies.
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Section 2000e(j) requires employers to accommodate religious beliefs and practices, but not an employee’s preferences.

Dachman v. Shalala, Sec · filed 2001-05-18(j)

While an employer has a duty to accommodate an employee’s religious beliefs, the employer does not have a duty to accommodate an employee’s preferences.
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An employer satisfies its duty to accommodate an employee’s religious practice by offering any reasonable accommodation, even if the employee prefers another.

Cosme v. William J. Henderson, in His Capacity as United States Postmaster General · filed 2002-03-29(j)

Nevertheless, to avoid Title VII liability, the employer need not offer the accommodation the employee prefers. Instead, when any reasonable accommodation is provided, the statutory inquiry ends.
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Section 2000e(j) includes religious observance and practice within the definition of religion unless an employer cannot reasonably accommodate them without undue hardship.

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

The term “religion” as used within Title VII 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.” 42 U.S.C. § 2000e(j). ... And so it goes that in the matter at hand, the district court properly found that where any of Plaintiffs proposed accommodations had the ability of violating the collective bargaining agreement by interfering with the seniority system, Defendant was not required to accommodate Plaintiff.
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Section 2000e(j) requires employers to reasonably accommodate religious practices unless doing so would cause undue hardship; a neutral attendance policy alone may be insufficient when the employer makes no other effort to resolve the conflict.

EEOC v. Chemsico, Inc. · filed 2002-05-07(j)

Because it appears that Defendants took no other action whatsoever to accommodate Ms. Brown except for the imposed point system, the Court cannot conclude as a matter of law that based solely upon the existence of the neutral attendance point system, Defendants met their burden to provide a reasonable accommodation.
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Section 2000e(j) requires only reasonable religious accommodations, so police departments need not let officers choose assignments based on religious objections.

Endres, Benjamin v. Indiana State Police · filed 2003-06-27(j)

Whether or not a paramilitary organiza- tion could accommodate task-specific conscientious objec- tion without undue hardship, however, the demand would not be reasonable—and §701(j) calls only for reason- ... able accommodations.
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A religious accommodation claim requires a sincerely held belief that conflicts with a job requirement; an employer may show that accommodation would cause undue hardship.

Storey v. Burns Intl Security · filed 2004-12-09(j)

An employer’s failure to reasonably accommodate an employee’s sincerely held religious belief that conflicts with a job requirement can also amount to an adverse employment action unless the employer can demonstrate that such an accommodation would result in “undue hardship.” See Shelton v. University of Medicine & Dentistry of New Jersey, 223 F.3d 220, 224 (3d Cir. 2000); see also 42 U.S.C. § 2000e(j). Storey’s complaint fails to meet even these minimal pleading requirements.
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Section 2000e(j) requires accommodation of a sincerely held religious belief that conflicts with a job requirement, unless accommodation would cause undue hardship.

Storey v. Burns International Security Services · filed 2004-12-09(j)

An employer's failure to reasonably accommodate an employee's sincerely held religious belief that conflicts with a job requirement can also amount to an adverse employment action unless the employer can demonstrate that such an accommodation would result in "undue hardship." See Shelton v. University of Medicine & Dentistry of New Jersey, 223 F.3d 220, 224 (3d Cir.2000); see also 42 U.S.C. § 2000e(j). ... Nothing in Storey's complaint suggests that Burns' requirement conflicted with a sincerely held belief that was endemic to his professed national origin or religion claims.
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Section 2000e(j) requires accommodation of religious practices when it can be provided without undue hardship.

Flowers, Michael J. v. Columbia College · filed 2005-02-08(j)

Yet Title VII requires accommoda- tion of religious practices, when that can be accomplished without undue hardship.
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Section 2000e(j) requires accommodation of religious practices when it can be provided without undue hardship.

Michael J. Flowers, Jr. v. Columbia College Chicago · filed 2005-02-08(j)

Yet Title VII requires accommodation of religious practices, when that can be accomplished without undue hardship.
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Section 2000e(j) requires an employee claiming failure to accommodate a religious belief to show a conflict with an employment requirement, notice to the employer, and discipline for failing to comply with that requirement.

Garvin v. Potter · filed 2005-04-22(j)

Similarly, to the extent that the plaintiff argues that the defendant failed to accommodate him as required by § 701 (j) of Title VII, this claim is without merit. ... In order to establish a prima facie case for failure to accommodate the plaintiff's religious beliefs in violation of Title VII, the plaintiff must establish that: 1) the plaintiff held a bona fide religious belief conflicting with an employment requirement; 2) the plaintiff informed the employer of this belief; and 3) the plaintiff was disciplined for the plaintiff's failure to comply with the conflicting employment requirement. ... Here, the plaintiff was not required to work on Saturdays or Jewish holidays, and the plaintiff provides no evidence of any disciplinary measure taken against him that was related to the plaintiff’s failure to work on Saturdays or Jewish holidays. Therefore, the plaintiff has not established a prima facie case that the defendant failed to accommodate his religious beliefs in violation of Title VII.
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Section 2000e(j) requires reasonable accommodation of an employee’s religious practice unless it would impose undue hardship; a neutral seniority system alone does not satisfy that requirement.

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

This result is obviously incompatible with Title VII’s requirement that employers “reasonably accommodate to an employee’s ... religious observance or practice.” 42 U.S.C. § 2000e(j). Because a neutral seniority system of assigning work shifts, in and of itself, is not sufficient to satisfy the reasonable accommodation requirement, the court finds that Defendant USF Holland did not make “reasonable efforts to accommodate” Plaintiff Rice.
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Section 2000e(j) requires reasonable accommodation of an employee’s religious observance unless the employer shows undue hardship; permission to seek voluntary shift swaps does not always satisfy that duty.

Equal Employment Opportunity Commission v. Robert Bosch Corp. · filed 2006-02-21(j)

Merely granting employees permission to find volunteers to swap shifts, however, does not definitively constitute “reasonable accommodation” as a matter of law in all cases.
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Section 2000e(j) requires an employer to reasonably accommodate an employee’s religious practice unless doing so would cause undue hardship; an accommodation that leaves the religious conflict unresolved is insufficient.

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

Accordingly, Alamo’s proposal would have failed to accommodate Ms. Nur’s religious conflict, and was not a reasonable accommodation.
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Section 2000e(j) defines religion to include religious observance, practice, and belief that an employer can reasonably accommodate without undue hardship.

Menges v. Blagojevich · filed 2006-09-06(j)

First, § 2000e(j) defines religion to include all aspects of religious observances, practices, and beliefs that do not impose an undue hardship on employers.
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Section 2000e(j) requires reasonable accommodation of religious observance and practice; adjusted shifts and shift swaps can satisfy that requirement.

Bush v. Regis Corporation · filed 2007-12-03(j)

Here, Regis offered Bush a reasonable accommodation. When it required her to cover shifts every other Sunday, it started the shift after her religious services had concluded. And as soon as the services changed times, Regis gave Bush Sundays off to accommodate the services. In addition, Regis permitted Bush to swap shifts to allow her to attend religious conventions.
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Section 2000e(j) requires an employer to reasonably accommodate an employee’s religious practice, but does not require an accommodation that eliminates every conflict with work requirements.

Equal Employment Opportunity Commission v. Firestone Fibers & Textiles Co. · filed 2008-02-11(j)

For the reasons that follow, we cannot accept appellants’ interpretation of § 2000e(j) and hold that "reasonably accommodate" means what it says: reasonably accommodate.
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Section 2000e(j) requires an employer to accommodate an employee’s religious practice unless doing so would cause undue hardship, but the employee must inform the employer of the specific conflict before that duty arises.

Wilkerson v. New Media Technology Charter School Inc. · filed 2008-04-09(j)

In addition, under 42 U.S.C. § 2000e(j), an employer must make reasonable accommodations for its employees' religious beliefs and practices unless doing so would create an "undue hardship" for the employer. ... Because she did not inform New Media that the ceremony presented a conflict, it did not have a duty to accommodate her.
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An employer has no duty to accommodate a religious conflict unless the employee informs the employer of the conflict.

Wilkerson v. New Media Tech · filed 2008-04-09(j)

Because she did not inform New Media that the ceremony presented a conflict, it did not have a duty to accommodate her.
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Section 2000e(j) places the burden on an employer to reasonably accommodate an employee’s religious practice or show that doing so would cause undue hardship.

Equal Employment Opportunity Commission v. Texas Hydraulics, Inc. · filed 2008-04-16(j)

Title VII puts the burden on the employer to “demonstrate[ ] that he is unable to reasonably accommodate to an employee’s religious observance or practice without undue hardship on the conduct of the employer’s business.” 42 U.S.C. § 2000e(j).
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Section 2000e(j) requires an employee claiming failure to accommodate a religious practice to show discipline or a threat of adverse action for failing to meet a conflicting work requirement.

Siddiqi v. New York City Health & Hospitals Corp. · filed 2008-08-12(j)

Here, the only issue is whether Plaintiff can maintain a claim for discriminatory failure to accommodate when he was not threatened with discipline if he failed to come to work. ... He cannot.
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Law changed since Groff v. DeJoy (June 29, 2023) rejected the more than de minimis cost standard; an employer must show substantial increased costs in relation to the conduct of its business.

Section 2000e(j) requires reasonable accommodation of an employee’s religious practices unless the accommodation would impose undue hardship on the employer.

Adams v. Retail Ventures, Inc. · filed 2009-04-28(j)

Title VII requires employers to make reasonable efforts to accommodate the religious practices of employees unless doing so would cause the employer undue hardship. ... We agree that all of this adds up to more than minimal hardship on Value City and its other employees.
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Section 2000e(j)'s religious accommodation duty requires harm caused by a conflict between an employment obligation and a religious belief; the cost of an offered accommodation alone does not establish that harm.

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

Unless a plaintiff has suffered some independent harm caused by a conflict between his employment obligation and his religion, a defendant has no duty to make any kind of accommodation.
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Section 2000e(j) requires a plaintiff seeking religious accommodation to show harm caused by a conflict between an employment obligation and a religious belief.

Reed v. International Union · filed 2009-06-23(j)

Unless a plaintiff has suffered some independent harm caused by a conflict between his employment obligation and his religion, a defendant has no duty to make any kind of accommodation.
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Section 2000e(j)’s duty to accommodate a religious practice arises when that practice actually conflicts with a job requirement.

Prise v. Alderwoods Group, Inc. · filed 2009-09-21(j)

An employer’s duty to accommodate cannot arise until an actual conflict between a religious belief, observance or practice and a job-related requirement is actually presented.
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Section 2000e(j) requires an employer to show that it cannot reasonably accommodate an employee’s religious beliefs without undue hardship once the employee establishes a prima facie case.

Dixon v. the Hallmark Companies, Inc. · filed 2010-12-09(j)

As both parties acknowledge, once the Dixons establish a prima facie case, the burden shifts to Hallmark to demonstrate that it cannot reasonably accommodate their religious beliefs without undue hardship.
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Section 2000e(j) includes religious observance and practice within the definition of religion unless the employer cannot reasonably accommodate them without undue hardship.

Crider v. UNIVERSITY OF TENNESSEE KNOXVILLE · filed 2011-03-28(j)

The term “religion” as used within Title VII includes “all aspects of religious observance and practice, as well as belief, unless an employer demonstrates that he is unable to reasonably accommodate 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). ... Although Crider established a prima facie case of religious discrimination under Title VII, the University also met its burden of showing that it cannot reasonably accommodate Crider without incurring undue hardship.
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Section 2000e(j) includes religious observance and practice in the definition of religion unless accommodating them would impose undue hardship on the employer’s business.

Maroko v. Werner Enterprises, Inc. · filed 2011-04-14(j)

“Religion” includes “all aspects of religious observance and practice,” unless an employer “demonstrates that he is unable to reasonably accommodate ... an employee’s ... religious observance or practice without undue hardship on the ... employer’s business.” 42 U.S.C. § 2000e(j). In this “awkward” way, the statute makes it unlawful for an employer not to make reasonable accommodations for an employee’s religious practices, unless doing so would impose an undue hardship.
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Section 2000e(j) permits an employer to reasonably accommodate religious practice through alternative one-on-one sessions and shift trades when those arrangements address the employee’s scheduling conflicts.

Fields v. Rainbow Rehabilitation Center, Inc. · filed 2011-06-14(j)

Finally, Defendants offered Plaintiff a reasonable alternative to attending those meetings and sessions on his accommodation days, as well as when he was scheduled to work on one of those days, in that they allowed him to arrange alternative one-on-one meetings and/or sessions and to trade shifts with other employees.
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Section 2000e(j) requires an employer to reasonably accommodate an employee’s religious practices unless doing so would cause undue hardship.

Equal Employment Opportunity Commission v. Thompson Contracting, Grading, Paving, & Utilities, Inc. · filed 2011-06-17(j)

To satisfy its burden, the employer must demonstrate either (1) that it provided the plaintiff with a reasonable accommodation for his or her religious observances or (2) that such accommodation was not provided because it would have caused an undue hardship.
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Section 2000e(j) includes religious belief and practice, but an employer must have sufficient notice of an employee’s religious conflict before a duty to accommodate arises.

Warren v. Shaw Group, Inc. · filed 2011-09-26(j)

Title VII defines “religion” to include “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.” 42 U.S.C. § 2000e(j). ... No reasonable trier of fact would find that Plaintiff put the Defendants on notice that he had a strongly held religious belief not to provide his social security number.
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Section 2000e(j) requires an employer to reasonably accommodate an employee’s religious practice unless the accommodation would cause undue hardship.

Finnie v. Lee County · filed 2012-01-17(j)

If a plaintiff can make out a prima facie case, the defendant must then show either: (1) that it offered the plaintiff a reasonable accommodation, or (2) that accommodating plaintiff would subject the defendant to undue hardship.
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Section 2000e(j) requires an employer to reasonably accommodate an employee’s religious practice unless doing so would cause undue hardship; an offered schedule change is reasonable when it eliminates the conflict with that practice.

Latice Porter v. City of Chicago · filed 2012-11-08(j)

We conclude, as the district court did, that the City discharged its obligation under Title VII by offering Porter an accom- modation that would have eliminated the conflict between her work schedule and her religious practice of attending church services on Sunday morning.
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Section 2000e(j) requires an employer to accommodate an employee’s religious observances unless doing so would cause undue hardship to its business.

Rashad v. Washington Metropolitan Area Transit Authority · filed 2013-05-23(j)

As stated above, an employer’s obligation to accommodate an employee’s religious observances extends only to the point that no “undue hardship” on its work results.
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A § 2000e(j) accommodation claim fails without evidence that the employee requested an accommodation.

Valenzisi v. Stamford Board of Education · filed 2013-06-05(j)

There is no evidence before the court to support Valenzisi’s claim that he requested an accommodation from Stamford.
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Law changed since Groff v. DeJoy (2023) ended the more-than-de-minimis-cost test quoted here; an employer must show substantial increased costs in relation to its business.

Section 2000e(j) includes religious observance and practice in the definition of religion and requires reasonable accommodation unless the employer shows undue hardship.

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

“The 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 ... religious observance or practice without undue hardship on the conduct of the employer’s business.” 42 U.S.C. § 2000e(j). ... To establish undue hardship, an employer must show that a requested accommodation would result in “more than a de minimus cost.” ... For the foregoing reasons,. the Court Grants Plaintiffs’ Motion as to Abercrombie’s undue hardship affirmative defense.
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Section 2000e(j) includes religious observance and practice in Title VII’s definition of religion when an employer can reasonably accommodate them without undue hardship.

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

Title VII defines “religion” to include only those “aspects of religious observance and practice” that an employer can “reasonably accommodate ... without undue hardship on the conduct of the employer’s business.” 42 U.S.C. § 2000e(j).
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Section 2000e(j) protects religious observance through reasonable accommodation, but denial of an accommodation alone does not establish a claim without an adverse action resulting from failure to meet a conflicting work requirement.

Francis v. Solis · filed 2013-10-07(j)

However, the denial of a religious accommodation does not suffice to establish a prima facie case. Plaintiff must also show that after the denial, she “fail[ed] to comply with the conflicting employment requirement” and was thus subjected to an adverse employment action.
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Religion includes religious observance and practice, which an employer must reasonably accommodate unless doing so would cause undue hardship.

St. Juste v. Metro Plus Health Plan · filed 2014-03-28(j)

An individual’s “religion” includes not just religious beliefs, but “all aspects of religious observance and practice,” unless the employer demonstrates that it is unable to reasonably accommodate that observance or practice “without undue hardship on the conduct of the employer’s business.”
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Section 2000e(j) protects religious observance and practice and requires employers to reasonably accommodate employees’ religious practices.

Lewis ex rel. Estate of Lewis v. New York City Transit Authority · filed 2014-03-31(j)

Title VII protects “all aspects of religious observance and practice, as well as belief’ and obligates employers to make reasonable accommodations for the religious practices of their employees.
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Section 2000e(j) requires reasonable accommodation of religious practice unless it would cause undue hardship; an employee’s refusal to cooperate with the accommodation process can defeat that claim.

Macon v. J.C. Penney Co. · filed 2014-04-23(j)

The statute defines “religion” to include “all aspects of religious observance and practice, as well as belief,” unless an employer could not reasonably accommodate an employee’s religious observance or practice without experiencing undue hardship. ... Macon’s apparent unwillingness to work together with JCPenney in, or even to respond to, its request for a written explanation of her objections as an initial step in the accommodation process rendered an accommodation impossible.
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Requiring an employee to use paid time off for religious observance can be a reasonable accommodation.

Mills v. PeaceHealth · filed 2014-07-14(j)

To the extent that plaintiff was required to use PTO to accommodate his religious needs, defendant’s policy does not constitute a failure to accommodate.
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Section 2000e(j) requires employers to reasonably accommodate an employee when religious beliefs conflict with the terms of employment.

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

Employers have a duty to provide reasonable accommodation to employees when there is a conflict between their religious beliefs and the terms and conditions of their employment. 42 U.S.C. § 2000e(j).
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Section 2000e(j) requires reasonable accommodation of an employee's religious beliefs unless doing so would impose an undue hardship on the employer.

Yeager v. FirstEnergy Generation Corp. · filed 2015-01-28(j)

Second, if Yeager establishes his prima facie case, his employer has the burden to show that it could not “reasonably accommodate” his religious beliefs without “undue hardship.” Id.; 42 U.S.C. § 2000e(j).
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Section 2000e(j) can require an employer to reasonably accommodate an employee’s religious objection to attending a religious event.

Garcimonde-Fisher v. Area203 Marketing, LLC · filed 2015-04-27(j)

An employee’s objection to attending a religious event can constitute a religious practice that requires a reasonable accommodation.
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Section 2000e(j) defines religion to include religious practice, which must be accommodated absent undue hardship.

Equal Emp't Opportunity Comm'n v. Abercrombie & Fitch Stores, Inc. · filed 2015-06-01(j)

In fact, however, Congress defined “religion,” for Title VII’s purposes, as “includ[ing] all aspects of religious observance and practice, as well as belief.” 42 U. S. C. §2000e(j). Thus, religious practice is one of the protected characteristics that cannot be accorded disparate treat- ment and must be accommodated.
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Section 2000e(j) requires a reasonable accommodation for religious observance, but an employee cannot use the accommodation to gain an advantage in an employment dispute.

Handverger v. City of Winooski · filed 2015-07-07(j)

While an employer must make a reasonable accommodation for an employee’s religious observance, an employee cannot, at the same time, selectively leverage that accommodation to advance himself in a professional negotiation.
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Section 2000e(j) places the burden of demonstrating undue hardship on the employer in a religious accommodation claim.

Equal Employment Opportunity Commission v. JBS USA, LLC · filed 2015-07-17(j)

In light of the foregoing authority, the Court rejects any notion that EEOC bears the burden of proving the absence of undue hardship. To so conclude, as noted above, would be contrary to Congress’ explicit directive' that the employer demonstrate undue hardship.
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Section 2000e(j) includes religious observance and practice within the definition of religion when an employer can reasonably accommodate them without undue hardship.

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

“Religion” is defined to include only those “aspects of religious observance and practice” that an employer is able to “reasonably accommodate.. .without undue hardship on the conduct of the employer’s business.” 42 U.S.C. § 2000e(j).
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Section 2000e(j) requires an employer to offer a reasonable accommodation for religious observance and practice once the employee gives notice.

White v. Andy Frain Servs., Inc. · filed 2015-11-03(j)

The employer has a duty to offer a reasonable accommodation for ʺall aspects of religious observance and practiceʺ once notified by the employee.
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Section 2000e(j) requires an employer to offer reasonable accommodation for religious observance and practice once the employee gives notice of a conflict with work.

White v. Andy Frain Services, Inc. · filed 2015-11-03(j)

The employer has a duty to offer a reasonable accommodation for “all aspects of religious observance and practice” once notified by the employee.
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Section 2000e(j) includes religious observance and practice within religion and requires reasonable accommodation unless it would impose undue hardship on the employer’s business.

Samuels v. We've Only Just Begun Wedding Chapel, Inc. · filed 2015-12-15(j)

Title VII defines “religion” to include “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.” 42 U.S.C. § 2000e(j). ... The circumstances of Ms. Samuels’ termination create an issue of fact as to whether the defendants made reasonable efforts to accommodate her religious practices.
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Religion includes religious observance and practice, which an employer must reasonably accommodate unless doing so would cause undue hardship.

Nichols v. Illinois Department of Transportation · filed 2016-01-19(j)

Title VII defines “religion” as “all aspects of religious observance and practice, as well as belief, unless an employer demonstrates that he is unable to reasonably accommodate to [sic] 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).
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An employer can satisfy § 2000e(j)’s religious-accommodation duty by permitting shift swaps and the use of employee benefits to cover conflicting shifts.

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

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.
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Section 2000e(j) allows paid time off and voluntary shift swaps to serve as reasonable accommodations for an employee’s religious practice.

Tabura v. Kellogg USA, Inc. · filed 2016-07-07(j)

Here, Kellogg’s policy incorporated its reasonable accommodations. In addition to allowing employees to use all their paid time off, they could also swap shifts.
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Section 2000e(j) includes religious practice within the protected trait of religion and requires reasonable accommodation unless the employer demonstrates undue hardship.

Holly v. Jewell · filed 2016-07-11(j)

Under this definition of “religion,” an individual’s “religious practice,” just like his religious belief, is a protected trait “that cannot be accorded disparate treatment and must be accommodated” unless the employer demonstrates undue hardship.
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Section 2000e(j) covers religious observance, but a failure-to-accommodate claim requires discipline equivalent to an adverse employment action.

Brooks v. City of Utica · filed 2017-07-28(j)

The term “religion” includes “all aspects of religious Observance and practice, as well as belief.” § 2000e(j). ... Because discipline is equivalent to an adverse employment action for purposes of a discrimination claim, and the Court has already concluded that Plaintiff did not suffer any adverse employment actions with respect to his discrimination claim, Plaintiffs failure-to-accommodate claim must be dismissed.
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Section 2000e(j) includes religious observance and practice in the definition of religion and requires reasonable accommodation unless the employer shows undue hardship.

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

The term "religion" is defined to include "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." ... Thus, the court finds that the motions for summary judgment should be denied with respect to plaintiffs' religious accommodation claim.
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Section 2000e(j) requires accommodation of religious observance, but does not create a failure-to-accommodate claim based on national origin.

Krzeptowski v. Corrugated Supplies Company, LLC · filed 2018-03-19(j)

Corrugated is correct that, unlike the ADA, the ADEA and Title VII do not provide a cause of action for the failure to accommodate. Compare 42 U.S.C. § 12112(b)(5)(A) (ADA provision requiring reasonable accommodation), with 29 U.S.C. § 623 (ADEA prohibited acts, not including reasonable accommodation), and 42 U.S.C. § 2000e(j) (Title VII provision only requiring reasonable accommodation of religious observance).
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A religious accommodation claim under § 2000e(j) requires evidence that the need for accommodation motivated an adverse employment action.

Little v. Hanes Industries · filed 2019-10-07(j)

In the absence of any request for an accommodation, Little cannot successfully argue that a jury could reasonably find that his need for an accommodation, or even his religious beliefs generally, was a motivating factor in his termination.
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Section 2000e(j) includes religious observance and practice within the definition of religion and requires reasonable accommodation unless it would impose undue hardship on the employer’s business.

Schaaf v. New York State Department of Transportation · filed 2020-01-22(j)

An individual’s “religion” includes not just religious beliefs, but “all aspects of religious observance and practice,” unless the employer demonstrates that it is unable to reasonably accommodate that observance or practice “without undue hardship on the conduct of the employer’s business.” ... Nor does Plaintiff claim that he ever requested an accommodation, such as the opportunity to pray in a designated place.
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Law changed since Groff v. DeJoy (June 29, 2023) rejected the quoted de minimis cost test; undue hardship now requires a substantial burden in the context of the employer’s business.

Section 2000e(j) does not require an employer to provide a religious accommodation that would impose an undue hardship on its business.

Small v. Memphis Light, Gas & Water · filed 2020-03-12(j)

But the company did not have to offer any accommodation that would have imposed an “undue hardship” on its business—meaning (apparently) anything more than a “de minimis cost.”
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Section 2000e(j)'s religious accommodation duty requires a conflict between a religious practice and an employment requirement.

AL HAFNAWI v. The Public Health Trust of Miami-Dade County, Florida · filed 2020-07-08(j)

Dr. Al-Hafnawi, thus, fails to satisfy the first element because he has admitted that his religious fast during the day did not actually conflict with his on-call duties at night.
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Section 2000e(j) permits an employer to require employees to use paid vacation and floating holiday time before unpaid leave for religious observance as a reasonable accommodation.

McCray v. FedEx Express · filed 2020-08-12(j)

In summary, FedEx presented McCray with a reasonable accommodation when it mandated that she use her paid vacation and floating holiday time before using her unpaid time.
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Section 2000e(j)’s religious accommodation requirement can be satisfied by an overtime policy that lets employees avoid work on a sacred day by choosing another shift.

Redmon v. FlexSol Packaging Corporation · filed 2021-03-23(j)

However, as discussed at length above, Flexsol fully accommodated Redmon’s (and its other employees’) religious beliefs by implementing a policy to allocate overtime which indisputably allowed all employees to avoid working overtime on a sacred day.
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An employer satisfies Title VII’s religious accommodation requirement by offering a reasonable accommodation and need not also offer the employee’s preferred accommodation.

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

If an employer establishes that it offered a reasonable accommodation for the employee’s religious practice, it is entitled to judgment in its favor. See id. 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.
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Section 2000e(j) requires an employer to reasonably accommodate an employee’s religious practice unless doing so would cause undue hardship.

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

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.
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Section 2000e(j) includes religious observance and practice in the definition of religion and requires reasonable accommodation unless the employer shows undue hardship.

U.S. Equal Employment Opportunity Commission v. Greyhound Lines, Inc. · filed 2021-08-12(j)

The statute defines “religion” to include “all aspects of religious observance and practice, as well as belief, unless an employer demonstrates that he is unable to reasonably accommodate an employee’s . . . religious observance or practice without undue hardship on the conduct of the employer’s business.” Id. § 2000e(j).
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Section 2000e(j) includes religious observance and practice within religion and requires employers to reasonably accommodate them unless doing so would cause undue hardship.

Powell v. Susdewitt Management, LLC · filed 2021-09-27(j)

Under Title VII, the 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 . . . religious observance or practice without undue hardship on the conduct of the employer’s business.” 42 U.S.C. § 2000e(j). ... Accordingly, the court will deny the motion to dismiss as to Powell’s failure to accommodate claim.
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Section 2000e(j) requires a religious belief to conflict with an employment requirement for a religious accommodation claim; disagreement with the beliefs behind the requirement is insufficient.

O'Connor v. The Lampo Group, LLC · filed 2021-09-29(j)

What she needs to have alleged is a religious belief that conflicts with an employment requirement; it is not enough (or even relevant) that she alleges a religious belief that conflicts with the religious beliefs underlying the employer’s requirement.
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Section 2000e(j) requires employers to accommodate religious beliefs, practices, and observances unless doing so would impose undue hardship.

Dr. T. v. McKee · filed 2021-09-30(j)

Title VII requires employers to accommodate religious beliefs, practices, or observances only to the extent that doing so would not impose “undue hardship” on the employer.
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Section 2000e(j) includes religious belief and practice within the definition of religion and provides for reasonable accommodation unless it would cause undue hardship.

Grubbs v. Arizona, State of · filed 2021-10-05(j)

“The 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 . . . religious observance or practice without undue hardship on the conduct of the employer’s business.” 42 U.S.C. § 2000e(j). ... The Court finds these factual allegations state a plausible claim for failure to accommodate Plaintiff’s religious beliefs.
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Section 2000e(j) requires employers to reasonably accommodate employees' religious beliefs unless doing so would impose an undue hardship.

Patel v. NYU Langone Hospitals · filed 2021-10-19(j)

A plaintiff is entitled to a reasonable accommodation for his religious beliefs, as long as that accommodation does not impose an undue hardship on his employer. See Cosme v. Henderson, 287 F.3d 152, 158 (2d Cir. 2002) (citing 42 U.S.C. § 2000e(j)).
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Section 2000e(j) does not require an employer to provide an employee’s preferred religious accommodation.

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

Contrary to the Dr. A. Plaintiffs’ interpretation of the statute, Title VII does not require covered entities to provide the accommodation that Plaintiffs prefer—in this case, a blanket religious exemption allowing them to continue working at their current positions unvaccinated.
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Section 2000e(j) includes religious observance and practice within the definition of religion and requires reasonable accommodation unless it would cause undue hardship.

U.S. Equal Employment Opportunity Commission v. Greyhound Lines, Inc. · filed 2021-11-09(j)

The statute defines “religion” to include “all aspects of religious observance and practice, as well as belief, unless an employer demonstrates that he is unable to reasonably accommodate an employee’s . . . religious observance or practice without undue hardship on the conduct of the employer’s business.” Id. § 2000e(j).
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A religious exemption to a vaccination mandate can satisfy § 2000e(j)’s reasonable accommodation requirement.

Cisneroz v. City of Chicago · filed 2021-12-01(j)

Here, the City offers a reasonable religious accommodation, namely, the exemption for religious beliefs.
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Section 2000e(j) requires employers to accommodate religious beliefs, practices, or observances unless doing so would impose undue hardship.

Dr. T. v. McKee · filed 2022-01-07(j)

Title VII requires employers to accommodate religious beliefs, practices, or observances only to the extent that doing so would not impose “undue hardship” on the employer.
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Section 2000e(j) includes religious accommodation within the definition of religion; a Title VII religious accommodation claim requires an adverse employment action.

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

Rather, accommodation is within the definition of religion. Thus, “to fail or refuse to hire or to discharge any individual, or otherwise to discriminate against any individual with respect to his compensation, terms, conditions, or privileges of employment, because of such individual’s” need for a religious accommodation is a violation of Title VII. 42 U.S.C. § 2000e-2(a)(1); 42 U.S.C. § 2000e(j). 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.
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A religious accommodation claim under § 2000e(j) can proceed separately from a general religious discrimination claim.

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

These counts present clearly distinct claims and are not duplicative of one another.
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Section 2000e(j) requires an employer to reasonably accommodate an employee’s religious practice unless doing so would impose an undue hardship.

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

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.
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Section 2000e(j) does not require an employer to accommodate a religious objection to providing a Social Security number when doing so would violate federal law.

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

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.
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Section 2000e(j) permits an employer to accommodate Sabbath observance by excusing Saturday work while a formal request is pending.

Jemmott v. New York City Health and Hospitals Corporation · filed 2022-09-26(j)

Because plaintiff was not required to work any weekend while her request was pending, plaintiff can hardly claim that defendants failed to accommodate her religion during that time.
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When the burden shifts in a religious accommodation claim, the employer must show it made a reasonable accommodation or that one would cause undue hardship.

JACKSON v. NEW JERSEY JUVENILE JUSTICE COMMISSION · filed 2023-01-03(j)

The burden then shifts to Defendant to show it made reasonable accommodations, or that an accommodation would create an undue hardship.
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Section 2000e(j) protects religious exercise unless the employer cannot reasonably accommodate it without undue hardship.

Milteer v. Navarro County Texas · filed 2023-01-25(j)

“Title VII prohibits an employer from discriminating against an employee on the basis of [his] religion, unless the employer is unable to reasonably accommodate the employee’s religious exercise without undue hardship to its business.”
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Section 2000e(j) requires a conflict between a bona fide religious belief and an employment requirement for a religious accommodation claim.

Allen v. McCarthy · filed 2023-02-02(j)

Plaintiff has failed to establish a prima facie case that the Army failed to accommodate her religion because she has not alleged that her bona fide religious belief conflicted with an employment requirement.
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Section 2000e(j) protects religious practice unless an employer cannot reasonably accommodate it without undue hardship.

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

In short, the complaint alone does not demonstrate that Defendant could not reasonably accommodate Plaintiff’s beliefs without undue hardship.
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Section 2000e(j) requires employers to accommodate an employee’s religious practice unless doing so would impose an undue hardship on the employer’s business.

Adams v. Mass General Brigham Incorporated · filed 2023-09-28(j)

Title VII requires an employer to accommodate the religious practice of an employee unless it “demonstrates that [it] 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).
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Section 2000e(j) defines religion to include religious observance and practice unless the employer cannot reasonably accommodate it without undue hardship.

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

“Title VII of the Civil Rights Act of 1964 requires employers to accommodate the religious practice of their employees unless doing so would impose an undue hardship on the conduct of the employer’s business.” ... see 42 U.S.C. § 2000e-2(a)(1) (making it unlawful for a covered employer “to discriminate against any individual with respect to his compensation, terms, conditions, or privileges of employment, because of such individual’s . . . religion”); id. at § 2000e(j) (defining “religion” for Title VII purposes as including “all aspects of religious observance and practice . . . unless an employer demonstrates that he is unable to reasonably accommodate to an employee’s . . . religious observance or practice without undue hardship on the conduct of the employer’s business”).
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Section 2000e(j) includes religious belief and practice within Title VII’s protection; a religious accommodation claim requires a plausible allegation that a bona fide religious belief conflicts with an employment requirement.

Daniel v. Honeywell International Inc. · filed 2023-10-02(j)

“The 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.” Id. at § 2000e(j). ... To survive Defendants’ motion, Daniel must allege facts plausibly showing that he (1) has a bona fide religious belief that conflicts with an employment requirement, (2) informed Honeywell of this belief, and (3) was disciplined for failing to comply with the conflicting requirement. ... Daniel does not allege facts plausibly showing the first element.
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Section 2000e(j) requires an employer to reasonably accommodate an employee’s religious practice unless doing so would impose an undue hardship on its business.

Bobadilla v. New York City Health and Hospitals Corporation · filed 2023-11-03(j)

The statute requires an employer to “reasonably accommodate” an employee's “religious observance or practice,” unless doing so would impose “undue hardship on the conduct of the employer's business.” Id. § 2000e(j). ... In this case, the NYCHHC provided every reasonable accommodation, until these accommodations presented an undue hardship.
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Section 2000e(j) requires individual proof that an employee’s belief is religious and permits an employer to avoid accommodation liability by proving undue hardship.

Speer v. UCOR LLC · filed 2023-11-06(j)

The statute requires each Plaintiff to prove his beliefs are religious within the meaning of Title VII, and to avoid liability Defendant must prove an accommodation could not be granted without undue hardship.
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Section 2000e(j) includes religious beliefs within the definition of religion and requires reasonable accommodation unless it would cause undue hardship.

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

Religion is defined as including “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 . . . religious observance or practice without undue hardship.” 42 U.S.C. § 2000e(j). This definition includes a requirement that an employer “accommodate” religious beliefs, and as such, a plaintiff can bring a claim based on failure to accommodate.
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Section 2000e(j) requires a religious accommodation only when the employee conveys a conflict between a religious belief and a job requirement.

MULLEN v. ASTRAZENECA PHARMACEUTICALS, LP · filed 2023-12-14(j)

A defendant employer is not required to offer an accommodation in the absence of a conflict and, here, there was no articulable conflict that was conveyed to the Defendant.
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Section 2000e(j) requires a plausible conflict between an employee’s religious beliefs and an employment requirement for a religious accommodation claim.

Giurca v. Bon Secours Charity Health Sys. · filed 2024-01-26(j)

However, Giurca’s Amended Complaint is devoid of any facts plausibly alleging that signing either contract, and therefore agreeing that his employment would be “subject to” or that he would provide services “in accordance with” the ERDs, would actually conflict with his personal religious beliefs. Without sufficient allegations of an actual conflict, Giurca has not stated a “plausible claim for relief” as to his religious discrimination and accommodation claims.
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Section 2000e(j) includes religious observance and practice in Title VII’s definition of religion; an accommodation claim requires a belief that conflicts with a job requirement, notice to the employer, and discipline for noncompliance.

Buck-Yael v. Washington University · filed 2024-03-28(j)

“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.” 42 U.S.C. § 2000e(j). ... Plaintiff fails to allege that she was disciplined for failing to comply with a conflicting requirement. ... However, even if the Court were to infer her termination was because of Defendant’s religious discrimination, Plaintiff fails to allege a “bona fide religious belief that conflicts with an employment requirement.” Therefore, the Court finds Count I fails to state a claim upon which relief can be granted.
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Section 2000e(j)’s religious accommodation duty is satisfied when an employer offers a reasonable accommodation, even if the employee prefers another.

Christians in the Workplace Networking Group v. National Technology and Engineering Solutions of Sandia, LLC · filed 2024-03-28(j)

In summary, Defendants met their burden of showing that they reasonably accommodated Plaintiff’s religious practices and Plaintiff has failed to proffer evidence sufficient to raise a genuine issue of material fact. As a result, Defendants are entitled to summary judgment. Because Defendants offered Plaintiff a reasonable accommodation, the Court need not reach the question of whether Plaintiff’s preferred accommodation would have imposed an undue hardship.
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Section 2000e(j) requires an employee seeking religious accommodation to show that a religious belief conflicts with an employment requirement.

Brokken v. Hennepin County · filed 2024-03-29(j)

Brokken needed to demonstrate a conflict between her belief to not provide her biological information to anyone and the requirement to complete an at-home saliva test, which she did not.
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Section 2000e(j) requires reasonable accommodation of an employee’s sincere religious belief when it conflicts with a work requirement, unless accommodation would impose undue hardship.

SUBER v. METHODIST SERVICES · filed 2024-05-15(j)

Employers must make reasonable accommodations with respect to their employees’ religious beliefs unless doing so results in undue hardship. ... Plaintiff plausibly alleges that she has a sincere religious belief, that she informed defendant of her belief, and that this belief conflicted with defendant’s requirement to provide a marriage certificate. ... At this stage, plaintiff’s allegations pass muster.
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Section 2000e(j) requires accommodation of a religious observance or practice that conflicts with an employment duty; a conflicting belief alone is insufficient.

Brown v. Alaska Airlines Inc · filed 2024-05-22(j)

But Title VII, by its terms, does not require accommodation of religious “beliefs,” as Plaintiffs claim; it requires accommodation of a religious “observance or practice.”
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Section 2000e(j) requires a religious accommodation claimant to identify a religious observance or practice that conflicts with an employment requirement.

Kondilis v. City Of Chicago · filed 2024-05-23(j)

Consequently, the court concludes that plaintiffs have failed to allege an observance or practice religious in nature that conflicted with the requirement to test and report.
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Section 2000e(j) defines religion for Title VII; an employee seeking a religious accommodation must inform the employer how a religious belief conflicts with a job requirement.

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

Moreover, Title VII defines “religion” as “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 . . . religious observance or practice without undue hardship on the conduct of the employer’s business.” 42 U.S.C. § 2000e(j). ... In short, Jenkins’s submission to Valley Health does not reflect that he adequately informed Valley Health of his religious beliefs.
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Section 2000e(j) requires an employee seeking religious accommodation to show a sincerely held belief that conflicts with an employment requirement and that the employer knew of the belief.

Felts v. NIRVC-TN, LLC · filed 2024-07-11(j)

However, Felts must show that she has a sincerely held religious belief that conflicts with a requirement of her employment. ... The Court finds that Felts has failed to demonstrate that her decision to undergo an abortion conflicted with a requirement of employment or that NIRVC was aware of her religion.
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Section 2000e(j)’s religious accommodation duty does not support a failure-to-accommodate claim when the employee was exempt from the conflicting requirement and faced no discipline for noncompliance.

Desmarais v. Granholm · filed 2024-08-16(j)

Mr. Desmarais could not have been disciplined for failing to comply with the vaccination requirement, because he was never in fact subject to the vaccination requirement. ... The court therefore concludes that this allegation is better addressed as part of Mr. Desmarais’s disparate-treatment claim, not as a failure-to-accommodate claim, and will dismiss Count VI of the complaint.
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Section 2000e(j) requires employers to reasonably accommodate religious practice unless doing so would cause undue hardship.

Oka v. United Airlines, Inc. · filed 2024-08-20(j)

An employer's obligation under Title VII is to reasonably accommodate an employee's religious practice unless it can show that doing so would subject it to undue hardship. See 42 U.S.C. § 2000e(j). Oka alleges that United withheld his pay, health benefits, and numerous other privileges for months; that is plainly sufficient to plausibly allege that United's proffered accommodation was not reasonable.
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Section 2000e(j) requires an employer to reasonably accommodate an employee’s religious practice; the employer need not provide the employee’s preferred accommodation.

Franchilli v. Albert Einstein College of Medicine · filed 2024-08-20(j)

As alleged in the complaint, the College satisfied its legal obligation to reasonably accommodate religious beliefs under Title VII.
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Section 2000e(j) requires employers to accommodate religious practice unless doing so would impose an undue hardship, but it does not require a blanket exemption allowing employees to remain unvaccinated in their current positions.

Lopes v. City of New York · filed 2024-08-27(j)

Although Plaintiffs use the term “accommodation” throughout their Complaint, what Plaintiffs allege was requested and denied were “exemptions” from the vaccine mandate. ... Title VII does not require employers to grant a “blanket religious exemption allowing [employees] to continue working at their current positions unvaccinated,” as Plaintiffs requested here.
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Section 2000e(j) requires an employer to reasonably accommodate a conflict between an employee’s sincerely held religious belief and a job requirement unless doing so would cause undue hardship.

Moore v. Health Care and Rehabilitation Services of Southeastern Vermont, Inc. · filed 2024-09-25(j)

“Under Title VII, an employer must offer a reasonable accommodation to resolve a conflict between an employee’s sincerely held religious belief and a condition of employment, unless such an accommodation would create an undue hardship for the employer’s business.” Cloutier v. Costco Wholesale Corp., 390 F.3d 126, 133 (1st Cir. 2004) (citing 42 U.S.C. § 2000e(j)). ... At this stage of the litigation, the allegations in Moore’s complaint are sufficient to make out a failure-to-accommodate claim under Title VII.
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An employer cannot deny a religious accommodation solely because an employee failed to complete a supplemental questionnaire when the initial request adequately established the need for accommodation.

Bergin v. New York State Unified Court System · filed 2024-10-08(j)

But if the claim for religious exemption itself presented sufficient grounds to grant the exemption, as defendant concedes it did here, defendant could not use the failure to timely complete the supplemental questionnaire as a reason to deny the exemption.
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Section 2000e(j) requires reasonable accommodation of religious beliefs and practices; an objection to workplace testing with no identified religious basis does not trigger that duty.

Jackson v. Methodist Health Services Corporation · filed 2024-11-20(j)

Jackson has identified no objection to testing that is grounded in her religious beliefs.
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Section 2000e(j) supports a religious accommodation claim when an employee communicates a religious conflict with a job requirement; employees who did not communicate their objections failed to plead that claim.

Menk v. The Mitre Corporation · filed 2024-12-02(j)

These Plaintiffs did not submit exemption requests or otherwise communicate their religious objections to Defendant and thus have not plead the elements of a failure-to-accommodate claim.
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Section 2000e(j) covers religious beliefs and practices; an employee seeking accommodation must allege how a religious belief conflicts with an employment duty.

Klus v. Legacy Health · filed 2024-12-11(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). ... Plaintiff’s general references to her sincerely held religious beliefs and her conclusory statement that those beliefs conflicted with Defendant’s vaccine mandate do not plausibly state a claim for relief.
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Religion includes observance, practice, and belief, but an accommodation claim requires a conflict between a religious belief and an employment requirement.

Peters v. Legacy Health · filed 2024-12-17(j)

Second, this Court concludes that Plaintiff has not pled a conflict between her sincere religious belief and the vaccination mandate. ... Title VII defines religion expansively, including “all aspects of religious observance and practice, as well as belief.” 42 U.S.C. § 2000e(j). ... This Court thus concludes that Plaintiff does not adequately plead a failure-to-accommodate claim under either Title VII or Oregon law.
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Section 2000e(j) requires an employer to reasonably accommodate an employee’s religious practice unless the accommodation would cause undue hardship.

Duden v. State of Washington · filed 2025-01-02(j)

However, Defendant DOC satisfied its burden by proving it could not reasonably accommodate Plaintiff because, despite good faith efforts to accommodate him, Plaintiff did not engage in discussions with Defendant DOC, and Defendant DOC could not find a reasonable accommodation that did not result in undue hardship.
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Section 2000e(j) requires employers to accommodate an employee’s religious practice unless the accommodation would impose an undue hardship on the business.

Allen v. Austal USA LLC · filed 2025-01-03(j)

Under Title VII of the Civil Rights Act of 1964, employers must reasonably “accommodate the religious practice of their employees unless doing so would impose an ‘undue hardship on the conduct of the employer’s business.’” Groff v. DeJoy, 600 U.S. 447, 454 (2023) (quoting 42 U.S.C. § 2000e(j)).
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Section 2000e(j) requires employers to accommodate employees’ religious beliefs unless doing so would impose an undue hardship.

UnifySCC v. Cody · filed 2025-01-15(j)

Under both statutes, employers must accommodate employees’ religious beliefs unless it would impose an undue hardship to do so. See 42 U.S.C. § 2000e(j); Cal. Gov. Code § 12940(l)(1).
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Section 2000e(j) requires a religious accommodation request to be based at least in part on a religious observance, practice, or belief that the employee brings to the employer’s attention.

McKay, Michael v. Wisconsin Department of Revenue · filed 2025-01-22(j)

Regardless, without more, the court cannot plausibly infer even now that some aspect of McKay’s accommodation request was based on his religious observance, practice, or belief, and more importantly, that McKay informed DOR of that observance, practice, or belief.
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The employer satisfied Title VII in this case by accommodating the employee’s religious conflict and preserving her employment status.

Oberst v. County of Lane · filed 2025-01-28(j)

Title VII required only that Defendant accommodate Plaintiff’s religious conflict and preserve her employment status, both of which Defendant indisputably did.
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Section 2000e(j) does not require an employer to accommodate a religious practice by violating another law.

BRUNSMAN v. FRANCISCAN ALLIANCE, INC. · filed 2025-01-29(j)

Under Title VII, an employer is not required to accommodate an employee's religious beliefs if doing so would require the employer to violate the law.
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The employer failed to show undue hardship from proposed religious accommodations given their minimal cost and the worksite’s existing public contact.

Keene v. City and County of San Francisco · filed 2025-01-30(j)

CCSF has failed to show these proposed measures imposed an “undue hardship” given their minimal cost and considering that during the relevant time period Appellants’ worksite hosted thousands of appointments with members of the public, regardless of their vaccination status.
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Section 2000e(j) allows an employer to accommodate a religious objection to vaccination through masking and testing when those measures are reasonable in the workplace.

Beach v. South Lane School District · filed 2025-03-04(j)

The Court finds that the District’s proffered accommodation of masking and testing was reasonable in a school setting.
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Section 2000e(j) requires employers to reasonably accommodate an employee’s religious practice unless the employer proves that doing so would cause undue hardship.

Chowdhury v. Department of Housing Preservation and Development, NYC · filed 2025-03-06(j)

Employers must reasonably accommodate an employee’s religious practice unless the employer proves that it would cause “undue hardship” on the employer’s business. See 42 U.S.C. § 2000e(j).
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Section 2000e(j) defines religion to include religious observance and practice and requires reasonable accommodation unless it would cause the employer undue hardship.

Stafford v. Acadia Pharmaceuticals, Inc. · filed 2025-03-10(j)

The definition of “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.” 42 U.S.C. § 2000e(j).
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Section 2000e(j) includes religious observance and practice within religion and requires reasonable accommodation unless it would cause the employer undue hardship.

Nanakumo v. New York City Health & Hospitals Corporation · filed 2025-03-26(j)

Title VII defines “religion” as including “all aspects of religious observance and practice, as well as belief,” and imposes an obligation on an employer “to reasonably accommodate to an employee’s . . . religious observance or practice” unless doing so would cause “undue hardship on the conduct of the employer’s business.”
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Section 2000e(j) includes religious observance, practice, and belief within the definition of religion and requires reasonable accommodation unless it would cause undue hardship.

Shepherd v. DLA Piper US LLP · filed 2025-04-02(j)

As used in Title VII, “religion” “includes all aspects of religious observance and practice, as well as belief, unless an employer demonstrates that he is unable to reasonably accommodate 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). ... Without additional factual evidence, the Court cannot conclude that Defendant’s actions and offered accommodation was reasonable.
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Section 2000e(j)'s religious accommodation duty does not support a failure-to-accommodate claim when an employee does not request an accommodation through available procedures.

Foster v. Wormuth · filed 2025-04-14(j)

And, in any event, Foster cannot now allege failure to accommodate when she never requested an accommodation in the first place under procedures available to do so.
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Section 2000e(j) requires employers to accommodate religious observances, practices, and beliefs unless doing so would impose an undue hardship on their business.

Richardson v. The National Basketball Association · filed 2025-08-18(j)

Employers are required to accommodate an employee’s religious observances, practices, and beliefs unless doing so would constitute an “undue hardship on the conduct of the employer’s business.” 42 U.S.C. § 2000e(j).
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Section 2000e(j) requires a reasonable accommodation of an employee’s religious practice; an employer need not offer another accommodation when the employee rejects one that resolves the religious conflict solely for secular reasons.

Waggoner v. American Medical Response Northwest, Inc. · filed 2025-08-27(j)

If a proposed accommodation eliminates the employee’s religious conflict and the employee rejects the accommodation “solely on secular grounds,” Title VII does not require the employer to accept an alternative proposed accommodation.
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Section 2000e(j) requires employers to accommodate an employee’s religious observance and practice unless doing so would cause undue hardship.

Ibrahim v. Johnson · filed 2025-08-28(j)

Title VII requires employers to accommodate “all aspects of religious observance and practice” unless the employer demonstrates that it cannot accommodate the employee’s religious observance or practice “without undue hardship on the conduct of the employer’s business.” ... But it does not identify what religious belief the employer failed to accommodate or allege facts that, if true, would show that the belief conflicted with a requirement of Ibrahim’s employment, that the employer was informed of the belief, or that Ibrahim suffered an adverse employment action for failing to comply with the requirement.
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Section 2000e(j) requires an employer to reasonably accommodate an employee’s sincerely held religious belief unless doing so would cause undue hardship; an employee’s failure to request an accommodation can defeat the claim.

Cooper v. White Mountain Community Health Center · filed 2025-09-03(j)

“Under Title VII, an employer must offer a reasonable accommodation to resolve a conflict between an employee’s sincerely held religious belief and a condition of employment, unless such an accommodation would create an undue hardship for the employer’s business.” Cloutier v. Costco Wholesale Corp., 390 F.3d 126, 133 (1st Cir. 2004) (citing 42 U.S.C. § 2000e(j)). ... These facts simply do not excuse Linda’s failure to submit a request for a religious accommodation, and the plaintiffs make no cogent argument that they do.
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Section 2000e(j) requires employers to accommodate employees’ religious practices unless accommodation would impose an undue hardship on the business.

Taylor v. New Haven · filed 2025-09-30(j)

“Title VII of the Civil Rights Act of 1964 requires employers to accommodate the religious practice of their employees unless doing so would impose an ‘undue hardship on the conduct of the employer’s business.’” Groff v. DeJoy, 600 U.S. 447, 453–54 (2023) (quoting 78 Stat. 253, as amended, 42 U.S.C. § 2000e(j)). ... The City also contends that Taylor has failed to do so with respect to whether the City could accommodate his religious beliefs without undue hardship. Taylor contends that there are genuine issues of material fact with respect to each of these points. The court agrees.
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Section 2000e(j) requires an employer to reasonably accommodate an employee’s religious practice unless the accommodation would cause undue hardship to its business.

BOODOO v. AMP HOME CARE LLC · filed 2025-10-07(j)

In sum, Plaintiff has come forward with genuine issues of material fact that AMP could have accommodated Boodoo without undue hardship.
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Section 2000e(j) requires employers to reasonably accommodate an employee’s sincerely held religious beliefs.

HILL v. APP-TEC INCORPORATED · filed 2025-10-09(j)

Title VII and the NJLAD further forbid employers from failing to reasonably accommodate an employee’s sincerely held religious beliefs. N.J. Stat. Ann. § 10:5-12(q)(1); see also Fallon v. Mercy Cath. Med. Ctr, 877 F.3d 487, 490 (3d Cir. 2017) (citing 42 U.S.C. § 2000e(j)).
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Section 2000e(j) requires an employer to accommodate an employee’s religious practice unless doing so would impose an undue hardship on its business.

Murphy v. New York City Police Department · filed 2025-12-05(j)

Title VII imposes an obligation on an employer “to accommodate the religious practice of their employees unless doing so would impose an ‘undue hardship on the conduct of the employer’s business.’”
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Section 2000e(j) requires reasonable accommodation of religious observance; shift swaps combined with paid and unpaid leave can satisfy that duty.

Sandberg · filed 2025-12-11(j)

Here, much like in Firestone Fibers, DHS informed Plaintiff that he could swap shifts and use paid and unpaid leave. As with the employee in Firestone Fibers, Plaintiff relied on paid and then unpaid leave to avoid working on the Sabbath. DHS did not restrict paid or unpaid leave to nonreligious absences. Just as in Firestone Fibers, then, Plaintiff’s accommodations were clearly reasonable.
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Section 2000e(j) requires employers to accommodate employees’ religious practices unless doing so would impose an undue hardship; a claim must allege that the employer knew accommodation was needed.

Shah · filed 2026-01-28(j)

Title VII certainly requires “employers to accommodate the religious practice of their employees unless doing so would impose an ‘undue hardship,’” Groff v. DeJoy, 600 U.S. 447, 453–54 (2023) (quoting 42 U.S.C. § 2000e(j)), but Mr. Shah does not allege that he ever requested such breaks, or that his employer was otherwise aware that he required accommodations for religious activity.
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Section 2000e(j) requires a reasonable accommodation of religious practice, but does not require the employee’s preferred accommodation.

Diallo · filed 2026-03-30(j)

The test is a “reasonable” accommodation, not the employee’s most preferred method of accommodation.
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Section 2000e(j) requires employers to accommodate employees’ religious practices unless doing so would impose an undue hardship on the conduct of the employer’s business.

Mohamed v. Full Life Care · filed 2026-06-16(j)

Accordingly, the district court correctly held there is no genuine dispute of material fact that accommodating Mohamed’s request for religious exemption from the vaccine policy would impose an undue hardship on the conduct of Full Life Care’s business.
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Notes 1801–1950 of 3,833, oldest cases first.

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