Accommodating religious beliefs in the workplace
Philbrook was forced to take unauthorized leave without pay or to schedule required hospital visits on his holy days to fully observe those days.After exhausting available avenues of administrative relief, the teacher filed suit against the school board and others in the United States District Court for the District of Connecticut, alleging that prohibiting the use of personal leave for religious purposes violated Title VII. Court of Appeals for the Second Circuit reversed the district court. Court of Appeals for the Seventh Circuit ruled in , that two written requests from an employee for unpaid leave to attend funeral rites for his father in Africa created a genuine issue of material fact regarding notice of the religious nature of the request for accommodation purposes under Title VII.Four days after starting her employment with UTK, Crider notified her supervisor that she is a Seventh Day Adventist and her religious beliefs prevented her from performing work-related tasks from sundown on Fridays until sundown on Saturdays.This proposal was provided to the other two coordinators who indicated they were unwilling to accept the arrangement because it prevented them from travel on the weekend and from disengaging from work.The district court granted summary judgment to Fort Bend on Davis’s claims of retaliation and religious discrimination under Title VII by finding that the absence from work was due to a personal commitment, not a religious conviction because she described the obligation as a request from her pastor.
The Seventh Circuit noted the statutory definition of religion in Title VII is an unusual blend, combining a broad substantive definition of religion with an implied duty to accommodate an employee’s religious beliefs and practices., which held the key inquiry in a religious accommodation case “is whether a given belief that is sincere and meaningful occupies a place in the life of its possessor parallel to that filled by the orthodox belief in God.” The Seventh Circuit described three factors to consider when determining whether a belief is in fact religious for purpose of Title VII: “(1) the belief necessitating the accommodation must actually be religious, (2) that the religious belief must be sincerely held, and (3) accommodation of the sincerely held belief must not impose an undue hardship.” The court specifically noted that Adeyeye in his two requests for leave referenced the “funeral ceremony” and “funeral rite,” as well as the animal sacrifices and spiritual repercussions of his failure to attend.
The EEOC recognized this conflict and in March 2014 issued “Religious Garb and Grooming in the Workplace: Rights and Responsibilities,” which focuses on how Title VII applies to religious dress and grooming practices.
This article will review how religious accommodation came to be in Title VII of the Civil Rights Act and how courts are interpreting employers’ accommodation duties. Religious Accommodation and Title VII Religious freedom is a foundational civil liberty enshrined in the First Amendment to The United States Constitution. Court of Appeals for the Sixth Circuit reversed the district court’s decision finding that the legislative history of Title VII was clear that it was aimed only at discriminatory practices., an amendment to Title VII was proposed by Senator Jennings Randolph (D-W. The Senator was a member of the Seventh Day Baptist Church whose Saturday Sabbath often conflicted with work requirements.
These references, it said, would allow a reasonable jury to find that Adeyeye gave sufficient notice of the religious nature of his request for unpaid leave.
The Seventh Circuit also found that the information provided by Adeyeye evidenced his own personal and sincerely held religious beliefs.