Failure to reasonably accommodate religious observance or practice (§§ 2000e-2(a)(1), 2000e(j))

AND · 42usc2000e-2:x-failure-to-accommodate

Religious accommodation claim combining § 2000e-2(a)(1) with the definition of "religion" in § 2000e(j); once the prima facie case is shown, the employer may show it offered a reasonable accommodation (such as voluntary shift swaps) or that accommodation would impose an undue hardship.

Exact element source

religion
Source: docroot/ir/usc/title42.jsonl#title42_sec2000e-2; Unicode character offsets [362:370] (end exclusive); SHA-256 7b026a9ac957c5491602d868578271db8730b4c98650f1a4007b2e7430194c8b.

All variants

Recorded DB variant labels, including zero-count variants
VariantDescriptionMerits instance blocksDistinct casesExample cases (up to 3 per group)
reasonable-accommodation-offered/shift-swaps-vacation-days-and-declined-lower-paid-transfer1
Satisfied 0; not satisfied 1; excluded context 0
1/f-supp/962/1447-01 — United States District Court for the Southern District of Alabama · 1997 — not
religious-accommodationBona fide religious belief conflicting with an employment requirement, notice to employer, and discharge/penalty without reasonable accommodation0
Satisfied 0; not satisfied 0; excluded context 0
0No annotation uses in this snapshot

How courts decided this element

Annotation blocks, including explicitly excluded context
CaseElementHolding and scopeVariantExact source quotations
/f-supp/962/1447-01 — United States District Court for the Southern District of Alabama · 1997Failure to reasonably accommodate religious observance or practice (§§ 2000e-2(a)(1), 2000e(j))not
Counted merits instance
applied / merits

basis: no-evidence; claim: (a)(1),(c)(3),(m); 2000e(j); 2000e-3(a); party: APC; theory: failure to accommodate under 2000e(j); subject: party=APC; theory=failure to accommodate under 2000e(j)

The court skips the accommodation prima facie case and decides on the employer's burden: once any reasonable accommodation is offered the inquiry ends (Philbrook); undue hardship not reached; employee has a duty to cooperate with offered means.
reasonable-accommodation-offered/shift-swaps-vacation-days-and-declined-lower-paid-transfer
Breech met with Shelby Walker on November 26, 1990, at which time Breech informed Walker that he was no longer going to work between sundown Friday and sundown Saturday in observance of his religious beliefs.
Source: docroot/ir/caselaw/f_supp_962.jsonl#/f-supp/962/1447-01; Unicode character offsets [7612:7820] (end exclusive); SHA-256 c9d3cf4a8e3b5373cb13844fbe0d43429324dce0876d20c5fdba3f4d459c1acf.

Evidence kind: fact; polarity: supports; absent flag: 0; quoted-rule flag: 0 (1 = tagged; 0 = not tagged)

As a result of the December 7th meeting, APC accommodated Breech by allowing him to make shift swaps which would result in the doubling of shifts.
Source: docroot/ir/caselaw/f_supp_962.jsonl#/f-supp/962/1447-01; Unicode character offsets [8379:8525] (end exclusive); SHA-256 c9d3cf4a8e3b5373cb13844fbe0d43429324dce0876d20c5fdba3f4d459c1acf.

Evidence kind: fact; polarity: cuts-against; absent flag: 0; quoted-rule flag: 0 (1 = tagged; 0 = not tagged)

None of the Plant Control Operators who were scheduled with Fridays and Saturdays as their off days were willing to swap schedules with Breech.
Source: docroot/ir/caselaw/f_supp_962.jsonl#/f-supp/962/1447-01; Unicode character offsets [6648:6791] (end exclusive); SHA-256 c9d3cf4a8e3b5373cb13844fbe0d43429324dce0876d20c5fdba3f4d459c1acf.

Evidence kind: fact; polarity: supports; absent flag: 0; quoted-rule flag: 0 (1 = tagged; 0 = not tagged)

Finally, APC offered Breech a reasonable accommodation — which Breech declined because he did not want to take a pay cut — when it repeatedly offered to allow him to take a different position, such as Helper or Assistant Control Operator.
Source: docroot/ir/caselaw/f_supp_962.jsonl#/f-supp/962/1447-01; Unicode character offsets [37897:38135] (end exclusive); SHA-256 c9d3cf4a8e3b5373cb13844fbe0d43429324dce0876d20c5fdba3f4d459c1acf.

Evidence kind: fact; polarity: cuts-against; absent flag: 0; quoted-rule flag: 0 (1 = tagged; 0 = not tagged)

To establish a prima facie ease of failure to accommodate, Breech must prove: (1) that he had a bona fide belief that compliance with an employment requirement would be contrary to his religious belief or practice, (2) that he informed his employer about the conflict, and (3) that he was discharged or penalized for failing to comply with the conflicting employment requirement.
Source: docroot/ir/caselaw/f_supp_962.jsonl#/f-supp/962/1447-01; Unicode character offsets [35041:35420] (end exclusive); SHA-256 c9d3cf4a8e3b5373cb13844fbe0d43429324dce0876d20c5fdba3f4d459c1acf.

Evidence kind: rule; polarity: not recorded; absent flag: 0; quoted-rule flag: 0 (1 = tagged; 0 = not tagged)

Employer authorizations of such voluntary shift swaps constitute reasonable accommodations under Title VII.
Source: docroot/ir/caselaw/f_supp_962.jsonl#/f-supp/962/1447-01; Unicode character offsets [37277:37384] (end exclusive); SHA-256 c9d3cf4a8e3b5373cb13844fbe0d43429324dce0876d20c5fdba3f4d459c1acf.

Evidence kind: rule; polarity: not recorded; absent flag: 0; quoted-rule flag: 0 (1 = tagged; 0 = not tagged)

In this case, APC has demonstrated as a matter of law that it reasonably accommodated Breech’s religious beliefs.
Source: docroot/ir/caselaw/f_supp_962.jsonl#/f-supp/962/1447-01; Unicode character offsets [37034:37147] (end exclusive); SHA-256 c9d3cf4a8e3b5373cb13844fbe0d43429324dce0876d20c5fdba3f4d459c1acf.

Evidence kind: held; polarity: not recorded; absent flag: 0; quoted-rule flag: 0 (1 = tagged; 0 = not tagged)

Court interpretations

interpretation

To establish a prima facie ease of failure to accommodate, Breech must prove: (1) that he had a bona fide belief that compliance with an employment requirement would be contrary to his religious belief or practice, (2) that he informed his employer about the conflict, and (3) that he was discharged or penalized for failing to comply with the conflicting employment requirement.

/f-supp/962/1447-01 — United States District Court for the Southern District of Alabama · 1997

To establish a prima facie ease of failure to accommodate, Breech must prove: (1) that he had a bona fide belief that compliance with an employment requirement would be contrary to his religious belief or practice, (2) that he informed his employer about the conflict, and (3) that he was discharged or penalized for failing to comply with the conflicting employment requirement.
Source: docroot/ir/caselaw/f_supp_962.jsonl#/f-supp/962/1447-01; Unicode character offsets [35041:35420] (end exclusive); SHA-256 c9d3cf4a8e3b5373cb13844fbe0d43429324dce0876d20c5fdba3f4d459c1acf.

Religious accommodation claim combining § 2000e-2(a)(1) with the definition of "religion" in § 2000e(j); once the prima facie case is shown, the employer may show it offered a reasonable accommodation (such as voluntary shift swaps) or that accommodation would impose an undue hardship.

interpretation

Employer authorizations of such voluntary shift swaps constitute reasonable accommodations under Title VII.

/f-supp/962/1447-01 — United States District Court for the Southern District of Alabama · 1997

Employer authorizations of such voluntary shift swaps constitute reasonable accommodations under Title VII.
Source: docroot/ir/caselaw/f_supp_962.jsonl#/f-supp/962/1447-01; Unicode character offsets [37277:37384] (end exclusive); SHA-256 c9d3cf4a8e3b5373cb13844fbe0d43429324dce0876d20c5fdba3f4d459c1acf.

Religious accommodation claim combining § 2000e-2(a)(1) with the definition of "religion" in § 2000e(j); once the prima facie case is shown, the employer may show it offered a reasonable accommodation (such as voluntary shift swaps) or that accommodation would impose an undue hardship.