Title VII protects employees from discrimination based on their protected class which includes religion. As such, employers are required to accommodate an employee’s religious observances as long as such accommodation does not cause an undue hardship for the employer. In determining undue hardship, the United States Supreme Court has found [pdf] that accommodations requiring more than a de minimus cost are not generally required.
Following the Supreme Court’s interpretation, a federal court in the District of Columbia recently dismissed [pdf] the Equal Employment Opportunity Commission’s lawsuit on behalf of an employee alleging religious discrimination when the employer, Rent-A-Center, refused to accommodate his religious beliefs and excuse him from working on Saturdays.
The employee, Mr. Charles, worked as a store manager for Rent-A-Center. In this position, Mr. Charles performed management tasks at the employer’s store where customers select merchandise and enter into rental agreements. As with many retail stores, Saturdays are the busiest day as many customers are only available to visit the store on such day. Due to demand and business needs, all employees including store managers are required to work on Saturdays.
Mr. Charles, a Seventh Day Adventist, requested an accommodation from the Company’s policy requiring employees to work on Saturdays based upon his religious observations. Initially, Rent‑A‑Center accommodated such request. However, after realignment, Rent-A-Center could no longer accommodate the request. Shortly thereafter, the Company terminated Mr. Charles’s employment when he refused to work on Saturday.
The federal court dismissed the religious discrimination lawsuit finding that “allowing its most important employee at a particular store to be regularly absent on the most important day of the week at that store” is not a de minimus cost. Instead, it is an undue hardship that “would deprive the store of significant supervisory, managerial, customer-care and other functions” on a critical day when such tasks were necessary to the business.
As noted in the decision, the analysis regarding any accommodation is case specific and employers should not use this case to support a decision to regularly deny requests by all employees to not work on a mandatory Saturday. The court highlighted that its decision was based upon the employee’s critical role and business needs. However, employers should take heed that the court upheld the employer’s business needs at a time when employers struggle to meet demands in what continues to be a tough economy.