42 U.S.C. § 2000e

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

Davis v. Department of the Air Force · filed 2023-02-02(j)

Both Title VII and the Americans with Disabilities Act (ADA) require employers to make “reasonable accommodations” for their employees absent “undue hardship.”

Section 2000e(j) does not require an employer to provide a religious accommodation that would cause undue hardship by risking the safety of nursing home residents.

Villareal v. Rocky Knoll Health Care Center · filed 2022-11-21(j)

Therefore, it has met its burden of demonstrating that Villareal’s request to forego testing but continue working in its nursing home would have caused it undue hardship because it would have risked the health and safety of its residents.

Section 2000e(j) requires employers to reasonably accommodate religious practices unless doing so would impose an undue hardship, including by requiring the employer to violate state law.

LOWE v. MILLS · filed 2022-08-18(j)

Title VII does not mandate that employers provide the specific accommodation requested by an employee, nor does it require employers to provide accommodations that would require the employer to violate state law.

Section 2000e(j) does not require an employer to grant a religious accommodation that would impose undue hardship by requiring it to violate state law.

Does v. Hochul · filed 2022-09-30(j)

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

Section 2000e(j) places the burden on an employer to show that accommodating an employee’s religious practice would cause undue hardship to its business.

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

If a plaintiff makes out a prima facie case, the burden of proof then shifts to the employer to show that accommodating the religious observance or practice would have created an “undue hardship on the conduct of the employer’s business.”

Section 2000e(j) requires reasonable accommodation of an employee’s religious practice unless the employer shows undue hardship; administrative inconvenience alone does not establish undue hardship.

Barton v. The Metropolitan Government of Nashville and Davidson County, Tennessee · filed 2022-03-31(j)

On a failure to accommodate claim of religious discrimination under Title VII, an undue hardship is something greater than hardship, and an employer does not sustain its burden of proof merely by showing that an accommodation would be bothersome to administer or disruptive of the operating routine.

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

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

Because DIRECTV has not established as a matter of law that providing the unpaid leave accommodation to Mr. Sutton would cause “undue hardship on the conduct of [DIRECTV]’s business,” 42 U.S.C. § 2000e(j), a jury must decide whether the proposed accommodation would cause DIRECTV undue hardship.

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.

Creger v. United Launch Alliance LLC · filed 2021-11-30(j)

In other words, United Launch is only required to have offered reasonable accommodations if such accommodations would not impose an undue burden on its business. ... The plaintiffs have not shown that they can overcome United Launch’s undue hardship defense, and they have therefore failed, at this stage, to prove a substantial likelihood of success on the merits of their Title VII claim.

Section 2000e(j) makes undue hardship part of the religious accommodation analysis, so a court must determine whether the requested accommodation would impose one.

Stanley v. ExpressJet Airlines, Inc. · filed 2020-04-08(j)

Given that the statutory text of Title VII clearly provides for an exception for accommodations that would be an “undue hardship” for the employer, a court presented with a Title VII claim must always examine whether the requested accommodation presents an undue hardship. 42 U.S.C. § 2000e(j). Contrary to Stanley’s claims, undue hardship is not a defense raised to excuse a Title VII violation; rather, undue hardship is a part of the Title VII analysis, and a Title VII claim cannot be decided unless a court determines whether the accommodation would in fact impose an undue hardship.

Section 2000e(j) requires reasonable accommodation of religious practice unless the accommodation would cause undue hardship to the employer’s business; changing a staffing schedule can impose such hardship.

Rojas v. GMD Airlines Services, Inc. · filed 2015-09-09(j)

GMD would suffer undue hardship if it were required to change its scheduling system because of the difficulty of finding a replacement employee of comparable skill, experience, and qualifications; because other employees would be required to work more often during the weekend; and because GMD would incur substantial payroll expenses to give Cruz all Sundays off.

Section 2000e(j) does not require an employer to override a collectively bargained seniority system to accommodate religious observance.

Bolden v. Caravan Facilities Management, LLC · filed 2015-06-08(j)

Caravan wasn’t required to make an exception to the neutral, rotating schedule that distributed weekend work as evenly as possible among Mr. Bolden and his coworkers or to override the seniority system that dictated- how the janitors bid on positions on shifts — both of which were designed and implemented by the CBA.

Section 2000e(j) requires reasonable religious accommodation unless it would impose undue hardship, including a real burden on coworkers’ seniority rights.

Harrell v. Donahue · filed 2011-03-31(j)

But if accommodating an employee’s religious beliefs also causes a “real” and “actual” imposition on co-workers, Brown II, 61 F.3d at 655, Title VII does not require an employer to make such an accommodation.

Section 2000e(j) requires an employee seeking religious accommodation to notify the employer of the conflict between the employee’s beliefs and a workplace requirement.

Massie v. IKON Office Solutions, Inc. · filed 2005-08-11(j)

It is undisputed that plaintiff did not report to IKON the purported conflict between his religion and what he alleges was the proselytization of John Watkins. By not doing so, he did not give IKON sufficient notice to permit it to work out a satisfactory arrangement with him. Therefore, plaintiff failed to satisfy the notice element of a prima facie case.

Section 2000e(j) requires an employee seeking religious accommodation to give the employer fair warning about which job practices conflict with the employee's religion.

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

Title VII imposes a duty on the employer ... but also a reciprocal duty on the employee to give fair warning of the employment practices that will interfere with his religion and that he therefore wants waived or adjusted.

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

Johnson v. Sears Roebuck & Co · filed 2003-04-10(j)

The district court held that Sears could not reasonably accommodate Johnson’s beliefs without undue hardship on its business. See 42 U.S.C. § 2000e(j). Having reviewed the record and the parties’ briefs, the summary judgment was properly granted, essentially for the reasons stated by the district court.

Section 2000e(j)’s religious accommodation provision does not eliminate the requirement to allege an adverse employment action in a Title VII religious discrimination claim.

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

In other words, the accommoda- tion provision does not affect the basic statutory requirement for adverse employment action.

An employer need not accommodate an employee’s religious practice when doing so would impose an undue hardship on its business.

Quental v. Connecticut Commission on the Deaf & Hearing Impaired · filed 2000-08-17(j)

While it is reasonable to require the Commission to coordinate Quental’s work schedule in order to accommodate her religious practices, it would be an undue hardship for the Commission to allow her to promote her religious beliefs and share religious tracts with her clients.

Section 2000e(j) requires reasonable accommodation of an employee’s religious practice unless it would cause undue hardship; the employer need not violate a valid collective bargaining agreement to provide it.

Thomas v. National Ass'n of Letter Carriers · filed 2000-08-30(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). ... Requiring such a violation through any of Thomas’s suggested accommodations would result in an undue hardship on the conduct of the employer’s business.

Section 2000e(j) does not require an employer to accommodate a religious practice when doing so would violate federal tax reporting law and expose the employer to penalties.

Seaworth v. Bob Pearson Pearson Autobody · filed 2000-02-24(j)

We also agree with the District Court that defendants need not accommodate Seaworth’s religious beliefs. Requiring defendants to violate the Internal Revenue Code and subject themselves to potential penalties by not providing Sea-worth’s SSN on information returns results in undue hardship.

Once an employer offers a reasonable accommodation of an employee's religious beliefs, § 2000e(j) does not require it to show that the employee's proposed alternatives would cause undue hardship.

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

Because we hold that U.S. West offered Wilson a reasonable accommodation, our inquiry ends, and we need not consider Wilson's argument that her suggested accommodations would not cause undue hardship.

An employer does not reasonably accommodate a religious practice by telling an employee that an alternative job will require a long wait.

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

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

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

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

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

Section 2000e(j) does not require an employer to alter a bona fide, nondiscriminatory seniority-based shift-bidding system to accommodate an employee’s religious practices.

Balint v. Carson City · filed 1998-05-26(j)

An employer has a duty to accommodate a current or prospective employee’s religious practices unless the accommodation would cause “undue hardship on the conduct of the employer’s business.” 42 U.S.C. § 2000e(j). ... Because the Department had in place a nondiscriminatory seniority-based system for assigning shifts, it had no duty to accommodate Balint, even if such accommodation would have no more than a de minimis impact.

Section 2000e(j) does not require an employer to override a bona fide seniority system to accommodate an employee’s religious practice.

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

The TA and the TWU had a bona fide, seniority-based system in place for assigning jobs within particular civil service ranks. Accordingly, the TA had no duty to accommodate plaintiff by placing him in one of the choice Car Inspector’s jobs that did not require the wearing of a hard hat.

Section 2000e(j) requires an employer to reasonably accommodate an employee’s religious belief unless the accommodation would cause undue hardship; an accommodation requiring the employer to violate tax laws causes undue hardship.

Don M. Weber, II v. Leaseway Dedicated Logistics, Inc., Formerly Known as Leaseway Logistics Service, a California Corpo · filed 1999-01-07(j)

Once the plaintiff has established a prima facie case, the burden shifts to the employer to show that a reasonable accommodation would result in undue hardship to the employer. ... Requiring Defendant to violate these laws in order to accommodate Plaintiff would result in undue hardship to Defendant.

Section 2000e(j) does not require further accommodation of an employee’s religious practice when it would cause the employer undue hardship.

Bynum v. Fort Worth Independent School District · filed 1999-04-06(j)

The bottom line is that FWISD could not fully accommodate what Bynum professed his religious beliefs to be without undue hardship.

Section 2000e(j)’s religious accommodation requirement can be satisfied by selectively enforcing a workplace policy when the employee remains able to engage in the religious practice.

Anderson v. U.S.F. Logistics (Imc), Inc. · filed 2001-12-14(j)

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

Section 2000e(j)’s religious accommodation requirement validly applies to state employers.

Holmes v. Marion County Office of Family & Children · filed 2002-01-28(j)

The State is not immune from Plaintiffs failure to accommodate claim under Title VII because Congress validly exercised its authority under § 5 of the Fourteenth Amendment. Title VII’s religious accommodation requirement is congruent and proportional to the Free Exercise Clause of the First Amendment.

Section 2000e(j) requires a religious accommodation claimant to show that the belief or practice is religious and sincerely held.

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

In order to satisfy this element, the plaintiff must demonstrate both that the belief or practice is religious and that it is sincerely held.

Section 2000e(j) does not cover a hairstyle the employee describes as a personal choice, even if he also considers it an expression of his faith.

Eatman v. United Parcel Service · filed 2002-03-31(j)

There is no dispute that Eatman’s impulse to grow locks was not prompted by a dictate of his religious conscience or engendered by a divine command. ... In light of this testimony, it is not enough that Eatman also considers his locks a “testament” or an “outward expression” of his commitment to Protestantism and the principles of Nubianism.

Section 2000e(j) includes religious observance and practice within the definition of religion and requires a reasonable accommodation unless it would cause undue hardship.

Wilshin v. Allstate Insurance · filed 2002-05-10(j)

Upon receiving Plaintiffs letter stating that he could not work on Saturdays, Defendant informed Plaintiff in writing that he could maintain Sunday office hours instead of Saturday office hours to accommodate his religious beliefs. The Court finds that this option constitutes a reasonable religious accommodation under Title VII.

An employer may reasonably accommodate an employee’s religious observance through a position that eliminates the scheduling conflict, even if it reduces compensation along with work hours.

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

Defendant reasonably accommodated Vaughn’s request to be relieved of any work performed on his Sabbath, and the fact it resulted in reduced compensation does not render the accommodation unreasonable, especially considering that the number of hours which he was required to work were correspondingly reduced as well.

Section 2000e(j) does not require a police department to accommodate an officer’s religious objection by letting the officer refuse an assignment to protect the public.

Benjamin P. Endres, Jr., and United States of America, Intervening v. Indiana State Police · filed 2003-11-19(j)

Here, where no accommodation was attempted, we must decide whether the statute requires one, and we hold that it does not. Endres has made a demand that it would be unreasonable to require any police or fire department to tolerate.

Section 2000e(j) does not require an employer to provide a religious accommodation when the employee’s only acceptable options would impose undue hardship on its business.

Peterson v. Hewlett-Packard Co., a Corporation · filed 2004-01-06(j)

Because only two possible accommodations were acceptable to Peterson and implementing either would have imposed undue hardship upon Hewlett-Packard, we conclude that the company carried its burden of showing that no reasonable accommodation was possible, and we therefore reject Peterson’s failure-to-accommodate claim.

Section 2000e(j) permits an employer to satisfy its religious accommodation duty with a reasonable accommodation that balances the employee’s religious observance and the employer’s legitimate interests, even if the employee rejects it.

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

Title VII does not demand that this reasonable accommodation be favored, or even accepted, by plaintiff. So long as the accommodation reasonably balances the employee’s observance of her religion with the employer’s legitimate interest, it must be deemed acceptable.

A transfer that resolves a conflict between an employee’s religious convictions and job duties can be a reasonable accommodation if it reasonably preserves the employee’s compensation and other terms of employment.

Kelly v. County of Orange · filed 2004-06-08(j)

Because Kelly concedes that the transfer eliminated the conflict between her job duties and her religious convictions, our inquiry reduces to whether the accommodation reasonably preserved Kelly’s compensation, terms, conditions, and privileges of employment.

An accommodation is not reasonable under § 2000e(j) if it leaves the conflict between an employee’s religious practice and a work requirement unresolved.

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

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

Section 2000e(j)’s reasonable accommodation requirement can be satisfied by allowing shift swaps and offering other ways to resolve a scheduling conflict with an employee’s religious practice.

Morrissette-Brown v. Mobile Infirmary Medical Center · filed 2007-11-07(j)

On this record, we cannot conclude that the district court clearly erred by finding that Mobile Infirmary offered reasonable accommodations to Morrissette-Brown’s religious beliefs and observances during her employment.

A reasonable religious accommodation under § 2000e(j) depends on the circumstances and need not eliminate every conflict between religious practice and work.

Sturgill v. United Parcel Service, Inc. · filed 2008-01-15(j)

What is reasonable depends on the totality of the circumstances and therefore might, or might not, require elimination of a particular, fact-specific conflict.

Section 2000e(j) does not require every reasonable religious accommodation to eliminate the conflict between an employee’s beliefs and work requirements.

Sturgill v. UPS · filed 2008-01-15(j)

For these reasons, we conclude that the district court erred in instructing the jury that a reasonable accommodation must eliminate the religious conflict, an instruction that improperly took that issue from the jury.

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

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

Value City has established that accommodating Adams’s schedule would have caused the company undue hardship.

Section 2000e(j) does not require an employer to accommodate a religious practice when doing so would cause undue hardship.

Burdette v. FedEx Corporation · filed 2010-03-03(j)

Allowing her not to work during this peak time would have created an undue hardship for FedEx––a hardship the law does not require FedEx to bear.

Section 2000e(j) does not require an employment agency defending a religious discrimination claim to prove that a prospective employer would face undue hardship in accommodating a worker.

Equal Employment Opportunity Commission v. Kelly Services, Inc. · filed 2010-03-25(j)

But, in the present case, the EEOC sued Kelly in its capacity as an "employment agency," not an "employer," and nothing in § 2000e(j) suggests that an "employment agency," in defending itself against a claim of religious discrimination, must demonstrate that the employer to which it would be referring the temporary worker would suffer an undue hardship if it had to accommodate that worker.

A religious accommodation’s reasonableness depends on the circumstances of the case, not solely on how fully it resolves the employee’s religious conflict.

Haliye v. Celestica Corp. · filed 2010-06-10(j)

Instead, the determination of reasonableness is quintessentially a fact-bound inquiry that depends on the unique circumstances of each case. The Court therefore rejects defendants’ argument that the only relevant consideration is the extent to which an accommodation resolves an employee’s religious conflict.

Section 2000e(j) requires an employee seeking a religious accommodation to inform the employer of the need for it.

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

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

Section 2000e(j) makes reasonable preservation of compensation a significant consideration when an employer offers a transfer as a religious accommodation.

Sanchez-Rodriguez v. AT & T WIRELESS · filed 2010-08-05(j)

Based on its independent review of Title VII’s statutory provisions and existing case law, this Court finds reasonable preservation of compensation to be a significant aspect of a reasonable accommodation.

Section 2000e(j) requires an employer to reasonably accommodate an employee’s religious practice; offering help to find another position within the company can satisfy that duty.

Walden v. Centers for Disease Control & Prevention · filed 2012-02-07(j)

But CSC reasonably accommodated Ms. Walden when it encouraged her to obtain new employment with the company and offered her assistance in obtaining a new position.

Section 2000e(j) requires reasonable accommodation of an employee’s religious practices unless it causes undue hardship to the employer’s business; co-worker inconvenience alone is insufficient.

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

Title VII does not exempt accommodation which creates undue hardship on the employees; it requires reasonable accommodation “without undue hardship on the conduct of the employer’s business.” 42 U.S.C. § 2000e(j) (emphasis added).

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

Kilpatrick v. Hyundai Motor Manufacturing Alabama, LLC · filed 2012-11-27(j)

As noted above, the employer bears the burden of proving that it “is unable to reasonably accommodate [the] employee’s ... religious observance or practice without undue hardship on the conduct of the employer’s business.” 42 U.S.C. § 2000e(j). Thus, on the present motion, HMMA must present evidence affirmatively establishing that reasonable accommodation would have caused HMMA undue hardship.

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

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

Leaving the store without a Store Manager on Saturdays would cause an “undue hardship” to RAC by “impair[ing] [critical] functions”—it would deprive the store of the significant supervisory, managerial, customer-care and other functions that RAC Store Managers are charged with at the very time when these functions are most needed.

Section 2000e(j) requires an employer claiming undue hardship from a religious accommodation to show more than minor inconvenience.

Adeyeye v. Heartland Sweeteners, LLC · filed 2013-07-31(j)

Title VII requires proof not of minor inconveniences but of hardship, and “undue” hardship at that.

Section 2000e(j) does not require an employer to accommodate an employee’s religious practice when doing so would violate federal law.

Tagore v. USA · filed 2013-11-13(j)

Title VII prohibits an employer from discriminating against an employee on the basis of her religion, unless the employer is unable to reasonably accommodate the employee’s religious exercise without undue hardship to its business. 42 U.S.C. §§ 2000e-2(a)(1), 2000e(j). ... An employer need not accommodate an employee’s religous practice by violating other laws.

Section 2000e(j) requires a reasonable accommodation of an employee’s religious practice unless the employer shows undue hardship; a transfer that significantly diminishes the employee’s status or benefits may be unreasonable.

Muhammad v. New York City Transit Authority · filed 2014-09-30(j)

Muhammad has adduced proof which, if credited, would establish that she experienced a significant diminution of status and benefits when she was transferred to the bus depot. Although the Transit Authority asserts that the transfer was not a burden, this is an open question of fact for the jury. Accordingly, a genuine issue of fact remains whether the Transit Authority failed to accommodate Muhammad’s religious beliefs, as required by Title VII.

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

Webster v. Dollar General, Inc. · filed 2016-07-14(j)

The statutory definition of “religion,” in turn, includes “all aspects of religious observance and practice, as well as belief, unless an employer demonstrates that [it] 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) (emphases added). ... Against that backdrop, the determination of whether a laundry-list of preferences qualifies as an undue burden rests with the jury, not this Court on summary judgment.

Section 2000e(j) includes religious observance and practice within the definition of religion and allows an employer to meet its accommodation obligation by offering a reasonable alternative position.

Camara v. Epps Air Serv., Inc. · filed 2017-11-13(j)

For the reasons set forth in the Defendant's Response to the Plaintiff's Objections, the Magistrate Judge correctly recommended granting summary judgment on all of the Plaintiff's claims after he determined that it was undisputed that the Defendant offered the Plaintiff a reasonable accommodation for the exercise of her religious beliefs. The Plaintiff has now abandoned her reasonable accommodation claim. Accordingly, the Court approves and adopts the Report and Recommendation as the judgment of the Court.

Section 2000e(j) requires reasonable accommodation of an employee’s religious practice absent undue hardship; whether an accommodation is reasonable depends on the facts and does not always require eliminating every conflict with work requirements.

Tabura v. Kellogg USA · filed 2018-01-17(j)

In any event, we see no need to adopt a per se rule requiring that an accommodation, to be reasonable, must eliminate, or totally eliminate, or completely eliminate, any conflict between an employee’s religious practice and his work requirements. The statute requires the accommodation to be reasonable and ultimately the question of whether an accommodation is reasonable must be made on a case-by-case basis, grounded on the specific facts presented by a particular situation.

An employer can reasonably accommodate an employee’s Sabbath observance by allowing shift swaps with willing coworkers.

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

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

Section 2000e(j) covers religious practices even when a religion does not require them, if they are sincerely connected to the employee’s beliefs.

Mial v. Foxhoven · filed 2018-04-04(j)

Title VII protects "all aspects of religious observance and practice, as well as belief." 42 U.S.C. § 2000e(j). In considering whether a particular practice or belief of an employee is covered by Title VII, a court may neither determine what the tenets of a particular religion are, nor determine whether a particular practice is or is not required by the tenets of the religion.

Section 2000e(j)'s reasonable accommodation requirement can be satisfied by allowing an employee to use accrued vacation for religious observance.

Scott v. Carter Roag Coal Company · filed 2020-02-27(j)

This Court finds, as a matter of law, that allowing the plaintiff to take two days off by using accrued vacation was a reasonable accommodation of his religious beliefs.

Section 2000e(j) permits an employer to satisfy its religious accommodation duty by helping an employee apply for another position, even without guaranteeing a transfer.

Jean-Pierre v. Naples Community Hospital, Inc. · filed 2020-06-12(j)

We are persuaded that offering to help Mr. Jean-Pierre apply for a new position is a reasonable accommodation based on our opinion in Walden.

Section 2000e(j) does not require an employer to accommodate a religious practice when doing so would cause undue hardship, including by requiring the employer to violate federal SSN reporting law.

Lowman v. NVI LLC · filed 2020-07-22(j)

Because NVI’s SSN disclosure policy is mandated by federal law, NVI cannot depart from the policy to accommodate Lowman without suffering an undue hardship.

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

Groff v. DeJoy · filed 2022-05-25(j)

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

Section 2000e(j) allows an employer to deny a religious accommodation that would impose an undue hardship on its business.

D'Cunha v. Northwell Health Systems · filed 2023-02-28(j)

But an employer does not discriminate on the basis of religion if he demonstrates “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). ... Moreover, the Complaint and attached exhibits evidence that accommodating D’Cunha’s request would have posed “an undue hardship” for Northwell.

A religious accommodation claim under § 2000e(j) can proceed when factual disputes remain over the employer’s efforts to accommodate without undue hardship.

Smith v. Mesa, City of · filed 2023-03-10(j)

Plaintiff has made a prima facie case showing he was denied a religious accommodation, and there are genuine disputes of material fact regarding the City’s efforts to accommodate Plaintiff without facing undue hardship.

Religion under Title VII includes religious observance and practice, which an employer must reasonably accommodate unless doing so would cause undue hardship.

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

The statute defines “religion” 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 on the conduct of the employer’s business.” ... Defendant does not address the availability of and/or potential hardship of permitting plaintiff to participate in these events remotely as an accommodation to her religious beliefs.

Section 2000e(j) requires an employer to accommodate an employee’s religious practice unless the accommodation would cause undue hardship; an accommodation that requires the employer to violate binding law causes undue hardship.

Corrales v. Montefiore Medical Center · filed 2023-03-30(j)

In addition, Title VII imposes an affirmative obligation on the employer to accommodate an employee’s religious observance or practice unless doing so would cause “undue hardship on the conduct of the employer’s business.” ... Montefiore could not have granted Corrales’s requested exemption without undue hardship because granting the exemption would have required Montefiore to violate binding law.

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

Kluge v. Brownsburg Community School Co · filed 2023-04-07(j)

The burden then shifts to Brownsburg to demonstrate that it could not reasonably accommodate Kluge “without undue hardship on the conduct of the employer’s business.” 42 U.S.C. § 2000e(j).

Section 2000e(j) does not require a religious accommodation that would force an employer to violate state law, because that would impose an undue hardship.

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

But dismissal of an employee's Title VII claim because of undue hardship is appropriate where, in granting the employee's accommodation request, the employer would be required to violate state or federal law. ... Therefore, the Court finds that accommodating Plaintiff’s religious-based vaccine and weekly testing exemption requests would have imposed an undue hardship as a matter of law.

Section 2000e(j) requires employers to accommodate an employee’s religious practice unless doing so would cause undue hardship; an accommodation that would violate a binding vaccination mandate causes undue hardship.

Dennison v. Bon Secours Charity Health System Medical Group, P.C. · filed 2023-05-15(j)

By granting Plaintiffs’ request – to exempt them from the vaccination requirement and allow them to continue in their positions as patient-facing nurses – Defendants would be violating the State Mandate, thus suffering an undue hardship.

Section 2000e(j) does not require an employer to provide a religious accommodation that would impose an undue hardship, including increased COVID-19 exposure risk to hospital patients and staff.

Beuca v. Washington State University · filed 2023-05-19(j)

The Court concludes Defendant’s proffered reason for not accommodating Plaintiff’s request is sufficient to establish an undue hardship, particularly given the increased risk of COVID-19 infection during the time of Plaintiff’s termination.

Section 2000e(j) does not require a religious accommodation that would expose an employer to a substantial risk of license suspension for violating state law.

Lowe v. Mills · filed 2023-05-25(j)

The risk of license suspension for violating the Mandate would have constituted an "undue hardship on the conduct of the [Providers'] business" under any plausible interpretation of that phrase.

Section 2000e(j) includes religious observance, practice, and belief within Title VII’s definition of religion unless the employer demonstrates that reasonable accommodation would cause undue hardship.

Shane v. Bio-Techne Corporation · filed 2023-06-09(j)

Under federal law, “religion” includes “all aspects of religious observance and practice, as well as belief, unless an employer demonstrates that he is unable to reasonably accommodate [the] religious observance or practice without undue hardship on the conduct of the employer’s business.” 42 U.S.C. § 2000e(j). ... Under these circumstances, Bio-Techne’s undue hardship defense cannot be resolved at the pleading stage.

Section 2000e(j) requires an employer denying a religious accommodation to show that granting it would cause substantial increased costs in relation to its particular business.

Groff v. DeJoy · filed 2023-06-29(j)

We think it is enough to say that an employer must show that the burden of granting an accommodation would result in substantial increased costs in relation to the conduct of its particular business.

An employer need not accommodate an employee’s religious practice when the accommodation would require the employer to violate state law.

Cagle v. Weill Cornell Medicine · filed 2023-06-30(j)

Those cases have uniformly rejected claims that an employer is required by Title VII to accommodate a request for a religious exemption from the Mandate at the cost of violating Section 2.61 and thus New York law. ... Those cases are indistinguishable from Plaintiff’s. Accordingly, Plaintiff’s Complaint also fails to state a claim for relief under Title VII.

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

Johnson v. York Academy Regional Charter School · filed 2023-10-03(j)

... this claim will proceed forward, as the defendant has failed to argue that accommodating Johnson’s request would impose an undue hardship.

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

Moore v. Montefiore Medical Center · filed 2023-11-03(j)

Accordingly, Montefiore has demonstrated that exempting Moore from the vaccination requirement would constitute an undue hardship.

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

SMITH v. CITY OF ATLANTIC CITY · filed 2023-11-28(j)

Under 42 U.S.C. § 2000e(j), an employer is required to make reasonable accommodations for an employee’s religious beliefs and practices unless doing so would create an “undue hardship” for the employer. ... Granting Plaintiff’s request for accommodation would come at a substantial non-economic cost for the ACFD.

Section 2000e(j) requires an employer claiming undue hardship from a religious accommodation to show a substantial burden on its business.

Smith v. Mesa, City of · filed 2023-12-03(j)

Although the Court precluded summary judgment due to issues of facts as to whether the City’s claimed hardship would pose more than a de minimis cost, it finds the City cannot meet its burden of showing Plaintiff’s request for 1.5 days of unpaid leave would substantially affect its overall business.

Section 2000e(j) excuses an employer from accommodating a religious practice when the accommodation would impose substantial costs, including serious health and safety risks, on its business.

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

Even if Dr. Bushra has a sincerely held religious belief, there is no violation of Title VII or the PHRA if MLH can establish that any religious accommodation would have imposed “undue hardship on the conduct of [its] business.” See 42 U.S.C. § 2000e(j). ... In sum, there can be no doubt that MLH would have incurred undue hardship in the form of substantial social, if not economic, costs if it had been required to accommodate Dr. Bushra’s religious beliefs.

Section 2000e(j) does not require an employer to grant a religious accommodation that would violate a state regulation.

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

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

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

St. Hillaire v. Montefiore Medical Center · filed 2024-01-16(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.” 42 U.S.C. § 2000e(j). ... Had Defendant granted Plaintiff’s request for an exemption, it would have been in direct violation of New York State law, thus suffering an undue hardship.

Section 2000e(j) excuses an employer from accommodating an employee’s religious practice when the accommodation would impose an undue hardship on its business.

Peterson v. Snohomish Regional Fire and Rescue · filed 2024-01-25(j)

The “undue hardship” defense is a complete defense to WLAD and Title VII failure-to-accommodate claims.

A religious exemption from a vaccination requirement can impose undue hardship where the employee’s job requires contact with patients and staff.

Smith v. NYS OMH South Beach Psychiatric Center · filed 2024-02-22(j)

As her job required her to interact with patients and staff at Defendant’s facility, any such exemption would have clearly caused Defendant undue hardship.

Section 2000e(j) does not require an employer to grant a religious accommodation that would impose an undue hardship by requiring it to violate a state vaccination mandate.

Parks v. Montefiore Medical Center · filed 2024-03-04(j)

The Court grants Montefiore’s motion to dismiss Parks’s claims under Title VII because requiring Montefiore to allow Parks to continue working without receiving the COVID-19 vaccine would have “impose[d] an undue hardship” on Montefiore “because it would require [it] to violate state law” in the form of the mandate.

Section 2000e(j) permits an employer to ask about an employee’s religious beliefs to identify a conflict when evaluating a religious accommodation request.

Gunkel v. OU Medical Inc · filed 2024-02-26(j)

The mere act of inquiring about an employee’s religious beliefs to identify conflicts with a work requirement is not itself discriminatory or an invidious “religious test.” In many cases it is a necessary part of the religious accommodation process.

Section 2000e(j) does not require an employer to grant a religious accommodation that would force it to violate state law.

Adamowicz v. Northwell Health Systems · filed 2024-03-12(j)

Therefore, the Court finds that the Defendant would have suffered an undue hardship if it accommodated Plaintiffs’ religious Covid-19 vaccine exemption request because doing so would have required Defendant to violate the law.

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

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

Be that as it may—and as explained above—Title VII only requires an employer to provide a reasonable accommodation if doing so would not cause an undue hardship.

Section 2000e(j) makes undue hardship a complete defense to a Title VII religious accommodation claim.

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

Therefore, “undue hardship” is a complete defense to Title VII failure-to-accommodate claims. ... The record at this stage amply demonstrates the existence of an undue hardship.

Undue hardship is an affirmative defense to a Title VII religious accommodation claim and depends on the employer’s context.

Gallagher v. Hawaii Symphony Orchestra · filed 2024-03-27(j)

Undue hardship is an affirmative defense and “a context-specific standard.” Groff, 143 S. Ct. at 2297.

A religious accommodation claim fails when the requested exemption would impose an undue burden on the employer.

Bandalos v. Stony Brook University Medical Center · filed 2024-03-27(j)

The plaintiff’s claim fails because her exemption request would have imposed an undue burden on defendant.

Section 2000e(j) allows an employer to defeat a religious accommodation claim by showing that the accommodation would cause undue hardship.

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

As discussed above, an employer’s showing that a given policy or refusal of an employee’s accommodation request constitutes an “undue hardship” defeats a claim of religious discrimination. See 42 U.S.C. § 2000e(j); see also Groff, 600 U.S. at 471.

A religious accommodation imposes undue hardship under § 2000e(j) when granting it would require the employer to violate state law.

Booth v. New York Presbyterian Hospital - Behavioral Health Center · filed 2024-03-29(j)

In light of the foregoing, the Court accords with the 2d Circuit in both D’Cunha and We The Patriots II and holds that to grant such an exemption would constitute an undue hardship because it would require NYP violate a state law, Section 2.61.

Section 2000e(j) permits an employer to deny a religious accommodation that would cause undue hardship; the employer need not show that the adverse event creating that hardship is certain to occur.

Bordeaux v. Lions Gate Entertainment, Inc. · filed 2025-02-28(j)

However, an employer need not establish that an adverse health or safety event is certain to result from an accommodation to establish undue hardship under Title VII.

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

Marucci v. Greater Baltimore Medical Center, Inc. · filed 2025-03-18(j)

Ms. Marucci’s failure-to-accommodate claim fails because the undisputed evidence establishes that GBMC could not have accommodated Ms. Marucci’s vaccination exemption without undue hardship.

Section 2000e(j) excuses an employer from accommodating an employee’s religious practice when the accommodation would impose an undue hardship on its business.

Bushra v. Main Line Health Inc · filed 2025-04-10(j)

We agree with the District Court that this substantial, undisputed evidence establishes undue hardship.

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.

Haczynska v. Mount Sinai Health System, Inc. · filed 2025-05-13(j)

Mount Sinai Defendants could not have accommodated Plaintiffs’ religious beliefs without undue hardship and Plaintiffs’ conclusory allegations that they could have worked fully remotely do not persuade the Court otherwise.

Section 2000e(j) does not require an employer to grant a religious accommodation that would create an undue hardship through substantial health and safety risks.

Dodson v. Lutheran Village at Miller's Grant · filed 2025-05-22(j)

Summary judgment in favor of Lutheran Village is appropriate because the undisputed material facts establish that Ms. Dodson’s requested accommodation presented a threat to the health and safety of Lutheran Village’s residents and employees, thus presenting an undue hardship to the conduct of its business.

Section 2000e(j) provides no separate good-faith exception to an employer’s duty to accommodate an employee’s religious practice; the employer must show undue hardship.

Smith v. City of Atlantic City · filed 2025-05-30(j)

There is no separate ‘good faith’ exception: a well- meaning employer can fail to accommodate, and a bad-faith employer can lack the ability to accommodate without undue hardship.

Section 2000e(j) allows an employer to deny a religious accommodation that would impose substantial increased costs on its business, including health and safety risks.

Geronimo v. Melrose-Wakefield Healthcare Corporation · filed 2025-07-22(j)

To prevail on the defense, “an employer must show that the burden of granting an accommodation would result in substantial increased costs in relation to the conduct of its particular business.” Groff v. DeJoy, 600 U.S. 447, 470 (2023). The undue hardship standard is fact and context specific; it “requires courts to take ‘into account all relevant factors in the case at hand, including the particular accommodations at issue and their practical impact in light of the nature, size and operating cost of an employer.’” Bazinet, 113 F.4th at 18 (quoting Groff, 600 U.S. at 470-71). Economic and non- economic costs—including health and safety risks, as well as the risk of reputational injury—are relevant.

Section 2000e(j) requires an employer defending a religious accommodation claim to prove undue hardship; a good-faith but mistaken reason for its decision is insufficient.

Kluge v. Brownsburg Community School Corporation · filed 2025-08-05(j)

For this reason, it is the em- ployer’s burden to prove undue hardship arising from the ac- commodation, not to merely offer a good-faith—yet ... mistaken—reason for taking an adverse employment action.

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

Beckles v. New York City Department of Education · filed 2025-08-04(j)

Then, the burden shifts to the employer to show it could not accommodate the employee’s religious belief without suffering an “undue hardship.” Groff v. DeJoy, 600 U.S. 447, 454 (2023) (quoting 42 U.S.C. § 2000e(j)). ... Both accommodations, however, would have imposed substantial costs on the DOE.

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

Trusov v. Oregon Health & Science University · filed 2025-08-26(j)

The Court therefore grants summary judgment to OHSU because there is no genuine dispute that Trusov’s proposed accommodations would cause OHSU to suffer a substantial and undue hardship.

Section 2000e(j) does not require an employer to provide a religious accommodation that would leave an employee covered by a state vaccine mandate and impose an undue hardship.

Bandalos v. Stony Brook University Medical Center · filed 2025-08-18(j)

Accordingly, the plaintiff does not state a claim for failure to accommodate because the requested accommodations would not have removed the plaintiff from the Mandate’s definition of “personnel” and therefore would have imposed an undue burden on the defendant.

Section 2000e(j) requires an employer claiming undue hardship from a religious accommodation to show a substantial, rather than speculative, burden on its business.

Naylor v. County of Muscatine · filed 2025-08-19(j)

To establish undue hardship, “an employer must show that the burden of granting an accommodation would result in substantial increased costs in relation to the conduct of its particular business.” Groff v. DeJoy, 600 U.S. 447, 470 (2023) (abrogating case law requiring only a showing of “more than a de minimis cost”). ... On this record, there remain genuine issues of material fact as to whether Naylor’s continued employment would pose an undue hardship to the County.

Section 2000e(j) permits denial of a requested religious accommodation when the employer cannot provide it without undue hardship.

Petersen v. Snohomish Regional Fire and Rescue · filed 2025-09-02(j)

All of this amounts to a showing that SRFR could not reasonably have accommodated Plaintiffs without undue hardship in October 2021.

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

Maresca v. Richmond University Medical Center · filed 2025-08-28(j)

RUMC could not have granted Maresca’s requested accommodation without violating state law — an undue hardship by definition.

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

Lisoski v. King County · filed 2025-09-02(j)

Title VII requires that employers “reasonably accommodate... an employee’s or prospective employee’s religious observance or practice” unless the employer is “unable” to do so “without undue hardship on the conduct of the employer’s business.”

Section 2000e(j) requires an employer to reasonably accommodate an employee’s religious practice unless doing so would impose an undue hardship; an accommodation that eliminates the religious conflict is reasonable.

Carlson · filed 2025-11-07(j)

The undisputed evidence shows that following Plaintiffs’ request for a religious exemption, CoBank agreed they would not have to receive the COVID-19 vaccine and could instead wear masks, social distance, and periodically test for COVID-19. This accommodation eliminated any religious conflict for the Plaintiffs regarding the vaccine, and therefore, it was reasonable.

Section 2000e(j) requires an employer to reasonably accommodate an employee’s religious practice unless doing so would impose undue hardship; weekly nasal swab testing, masking, and social distancing can reasonably accommodate a religious objection to vaccination.

Wons · filed 2025-12-09(j)

But the Court also finds that Defendant offered a reasonable accommodation to the vaccination requirement: weekly nasal swab testing along with masking and social distancing.

Section 2000e(j) requires a religious accommodation to be reasonable in its effect on the employee and allows an employer to show undue hardship.

Federoff v. Geisinger Clinic · filed 2026-01-26(j)

Thus, the term ‘reasonably’ examines the impact of the accommodation on the employee, and the undue-hardship defense accounts for the employer’s interests.

Section 2000e(j)’s religious accommodation duty can be satisfied by offering a comparable internal position that resolves the religious conflict, even if the employee must apply for it.

Thill · filed 2026-02-23(j)

But even accepting that 3M would have required Thill to apply for the position in the Purification division, the Court still concludes that 3M offered Thill a reasonable accommodation as a matter of law.

Section 2000e(j) allows an employer to deny a religious accommodation that would impose undue hardship on its business, including substantial risks to patient safety.

Lindahl · filed 2026-03-03(j)

Plaintiff has failed to adduce evidence creating a genuine dispute of material fact whether accommodating Plaintiff’s religious exemption request would have imposed an undue hardship for Sheppard Pratt.

Section 2000e(j) includes religious practices within Title VII’s protection unless the employer shows it cannot reasonably accommodate them without undue hardship.

O'Neal · filed 2026-03-06(j)

Here, there is a genuine dispute of material fact as to whether accommodating O’Neal’s religious practice posed an undue hardship to the City (or more specifically the Fire Department).

Section 2000e(j) excuses a religious accommodation when it would substantially burden the employer’s business; realistic health and safety risks can establish that burden.

Williams v. Legacy Health · filed 2026-05-06(j)

Taken together, Legacy’s “realistic” concerns threatened a “substantial” burden on its business of providing quality healthcare. See Petersen, 150 F.4th at 1222. It is true, as Employees point out, that Legacy did not assert that vaccine exemptions would cause prohibitive financial hardship. But while that type of hardship may be sufficient, it is not ... necessary. “Health and safety costs” matter, too.

Section 2000e(j) uses a different undue hardship standard from the ADA’s “significant difficulty or expense” test.

Navarrete · filed 2026-05-31(j)

“Significant difficulty or expense” is the undue hardship standard under the ADA, not Title VII.

Section 2000e(j) permits an employer to establish undue hardship from the substantial health, operational, and financial burdens of a proposed religious accommodation.

Hunter · filed 2026-05-31(j)

For these reasons, the Court concludes that, on this record, there is no issue of material fact that accommodating Plaintiff—and hundreds of other unvaccinated coworkers—with N95 respirators and “regular testing” in lieu of vaccination would have imposed undue hardship under Title VII and Oregon law.

Section 2000e(j) requires an employer to accommodate an employee’s religious practice unless doing so would impose undue hardship, meaning substantial increased costs in relation to the employer’s business.

Trimmier · filed 2026-05-31(j)

“Significant difficulty or expense” is the undue hardship standard under the ADA, not Title VII. See 42 U.S.C. § 12111 (10) (ADA); 42 U.S.C. § 2000e(j) (Title VII). Plaintiff’s reliance on the ADA cases is misplaced. The Supreme Court recently clarified Title VII’s undue hardship standard, see Groff, 600 U.S. at 470–71 (“substantial increased costs in relation to the conduct of [an employer’s] particular business”) and the Ninth Circuit has applied that standard to COVID-19 Title VII accommodation cases like this one. See, e.g., Williams, 2026 WL 1239760, at *4.

Section 2000e(j) protects religious observance but does not require an accommodation that would impose undue hardship on the employer’s business.

Cross v. Bailar · filed 1979-10-15(j)

Religion is defined as “all aspects of religious observance and practice, as well as belief.” 42 U.S.C. § 2000e(j). ... I conclude that it would have been an undue hardship to the defendant’s business to guarantee the plaintiff’s sabbath off.

Whether an employer reasonably accommodated an employee’s religious practice under § 2000e(j) can be a question of fact.

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

In this Court’s opinion, the issue of whether or not the employer provided a reasonable accommodation is a question of fact.

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

Protos v. Volkswagen of America, Inc. · filed 1985-08-27(j)

In 1972, Congress amended the Civil Rights Act of 1964 to require that an employer must reasonably accomodate the religious observances of an employee except when “undue hardship on the conduct of the employer’s business” will result. 42 U.S.C. § 2000e(j) (1982).

Section 2000e(j) requires a religious-discharge plaintiff to show that the practice is religious, the employer knew of it, and the practice caused the discharge.

Beasley v. Health Care Service Corp., D/B/A Blue Cross/blue Shield of Marion, Illinois · filed 1991-08-20(j)

To establish a prima facie case, a plaintiff must show that (1) the practices are religious in nature; (2) the employee called the religious practices to the employer’s attention, and (3) the religious practices were the basis of the discharge.

Section 2000e(j) covers religiously motivated limits on work assignments and requires reasonable accommodation unless it would cause undue hardship.

Ryan v. United States Department of Justice · filed 1991-12-09(j)

Religiously motivated selectivity in the work one is willing to perform is an “aspect of religious observance and practice” that the employer must disregard unless it demonstrates that it is “unable to reasonably accommodate ... without undue hardship”.

Section 2000e(j) requires an employer to explore reasonable ways to accommodate an employee's religious practice, including a voluntary waiver of seniority rights, before claiming undue hardship.

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

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

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

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

This section of Title VII must be read in conjunction with the section which defines religion to include all aspects of religious observance and practice, as well as beliefs, the employer must reasonably accommodate unless s/he can demonstrate undue hardship in so doing. 42 U.S.C. § 2000e(j). ... However, given the particular circumstances of this case, the Court concludes that defendants Chrysler and the Union satisfied their "reasonable accommodation" obligation as required by Title VII.

Section 2000e(j)’s religious accommodation framework does not apply when an employee alleges that she was fired for failing to share her employer’s religious beliefs.

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

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

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

Vandersand v. Wal-Mart Stores, Inc. · filed 2007-07-31(j)

In this case, it is unclear at this stage whether Wal-Mart could comply with the Rule, and still accommodate Vandersand’s beliefs, without an undue hardship. The Rule requires Division I pharmacies, such as the Pharmacy, to dispense Emergency Contraceptives without delay. The Rule does not say that each licensed pharmacist must dispense Emergency Contraceptives without delay. Thus, Wal-Mart might have been able to dispense Emergency Contraceptives without delay by other means.

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

Stanley v. Expressjet Airlines, Inc. · filed 2018-12-07(j)

The phrase "unless the employer demonstrates that it is unable to reasonably accommodate that observance or practice without undue hardship," creates ... a defense for the employer and "place[s] upon the employer the burden of establishing an 'undue hardship' defense."

Section 2000e(j) requires an employer to accommodate religious practices unless it shows that doing so would impose an undue hardship on its business.

Hebrew v. TDCJ · filed 2023-09-15(j)

Title VII requires employers to accommodate “all aspects of religious observance and practice” unless the employer demonstrates that he cannot accommodate the employee’s religious observance or practice “without undue hardship on the conduct of the employer’s business.” 42 U.S.C. § 2000e(j); see Antoine v. First Student, Inc., 713 F.3d 824, 831 (5th Cir. 2013). ... We (1) hold TDCJ cannot meet the undue hardship standard, and (2) the Department’s counterarguments are unavailing.

Section 2000e(j) requires reasonable accommodation of an employee’s religious practice unless the employer demonstrates undue hardship; undue hardship is an affirmative defense.

Brown v. NW Permanente, PC · filed 2023-09-20(j)

In addition, the absence of an undue hardship on a defendant is not an essential element of a plaintiff’s claim under Title VII; it is an affirmative defense.

Section 2000e(b)’s definition of employer excludes individual employees from direct Title VII liability.

McMurry v. Neiders Company LLC · filed 2025-09-26(b)

Thus, they are not “an employer” and are not directly subject to Title VII or the ADA.

Section 2000e(d)’s reference to an agent of a labor organization incorporates respondeat superior liability; it does not make the agent personally liable under Title VII.

Atencio v. Torres · filed 2020-03-25(d)

Use of the word “agent” in the definitions is simply to incorporate respondeat superior liability into Title VII. Id. ... This same reasoning applies to labor unions and agents. ... Because Atencio filed his Title VII claim against both Local 20 and Torres, its agent, the court dismisses his claims against Torres as redundant.

Section 2000e(b) includes an employer’s agents in its definition of employer; a Title VII claim against a supervisor in an official capacity duplicates a claim against the employer.

Carter v. Military Department of Arkansas · filed 2019-09-27(b)

“Employer” as defined in Title VII includes “a person engaged in an industry affecting commerce. . . and any agent of such a person.” 42 U.S.C. § 2000e(b). ... As a result, this Court dismisses Ms. Carter’s Title VII claims against General Berry, Ms. Porterfield, and Mr. Crisp in their official capacities as duplicative of her claims against AMD.

Section 2000e(b) makes the employer, rather than individual supervisors, the proper defendant in a Title VII claim.

Burks v. Wisconsin Department of Transportation · filed 2005-05-11(b)

As plaintiffs former employer, the Wisconsin Department of Transportation rather than defendants Traska and Forlenza is the proper defendant for plaintiffs Title VII claim.

Section 2000e(b)'s definition of employer does not make individual supervisors and managers liable under Title VII when they do not otherwise qualify as employers.

Branham v. Home Depot U.S.A., Inc. · filed 2002-09-27(b)

Based upon an examination of the statutory scheme and remedial provisions of Title VII, the Wathen court concluded that Congress did not intend to provide for individual employee/supervisor liability under the federal statute. ... The foregoing Sixth Circuit precedent establishes that Plaintiffs’ Title VII claims against the individual Defendants are not legally cognizable. Therefore, these claims will be dismissed.

Section 2000e(b)’s definition of “employer” excludes individual supervisors who lack authority to fire an employee on their own.

Weeks v. Coury · filed 1996-03-29(b)

The individual Defendants in this case do not meet Title VII’s definition of “employer.”