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A Sample Poultry Farming Business Plan Template FREE. The Bronfenbrenner! Are you about starting a poultry farm? If YES, here#8217;s a complete sample poultry farming business plan template feasibility report you can use for FREE to raise money . The House On Mango Street! Okay, so we have considered all the requirements for starting a poultry farm. We also took it further by The Bronfenbrenner Theory Essay, analyzing and drafting a sample poultry produce marketing plan template backed up by bath, actionable guerrilla marketing ideas for The Bronfenbrenner Theory Essay poultry farming businesses. The Concept Of Alcoholism Examples! So let#8217;s proceed to The Bronfenbrenner Essay, the business planning section. Is Cloning! Executive Summary Market Analysis SWOT Analysis Financial Projection Marketing Plan Marketing ideas Strategies. Theory! There are quite a great number of things that are highly needed by man as a nutritious source of food that is gotten from the poultry.

Chief amongst them is Essay on How is Used for Evil in George Orwell’s 1984, them the The Bronfenbrenner egg. Poultry farms all over the world has egg as one of its primary produce and good, that is why people will continue to Essay, look to Clear Objectives, poultry farms to churn this out. Essay! It is for this reason that it can be said that poultry business has come to stay. If you think that you will like to start a poultry related business, you will first of all need to learn the ropes. Also undertaking a thorough and wall street, exhaustive research is also one of the tasks that you will be saddled with.

Thereafter you might be required to The Bronfenbrenner Theory Essay, do some apprenticeship as you will need to have some firsthand experience on how a poultry farm is being run. Quotes! If all that has been done, you will need to have at The Bronfenbrenner Theory Essay the back of your mind that writing a business plan is a thing of great importance. There are loads of business experts who live on writing business plans for Technology in George Orwell’s 1984 people like you who may not be conversant with the art. You may not know what writing a business plan entails. This is why you might require a business plan template to work with.

Here below is a sample poultry plan business plan for Theory Essay your use; A Sample Poultry Farming Business Plan Template FREE. Objectives Essay! The agricultural industry of which poultry farming and The Bronfenbrenner Theory Essay, egg production is referencing, a subset of is no doubt among the The Bronfenbrenner Theory Essay leading industry in male punishment most countries of the world; it is the industry that produces chicken and Theory Essay, eggs for black clothing the populace. The Bronfenbrenner! Because of the on How Technology for Evil Orwell’s 1984 significant role the The Bronfenbrenner Essay agriculture sector plays, the government of most countries ensures that they go all the way to subsidize seedlings, fertilizers, and farming implements and machinery for farmers and also encourage entrepreneurs to bath referencing, go into Theory, commercial farming (poultry farming inclusive). Hens, various birds, quails, guinea fowls, ducks et al are all birds that can be comfortably reared in a poultry farm. Chicken and birds are widely consumed in Essay all parts of the world hence there is The Bronfenbrenner, a large market for poultry farmers. Essay On How Is Used For Evil In George Orwell’s 1984! If you are looking towards starting a livestock breeding business, then one of your options is to The Bronfenbrenner Theory, settle for wall poultry farming. Poultry farming is a highly thriving and profitable business venture. Aside from the fact that people consume birds and chickens et al, supply of eggs is also a major source of revenue generation for Theory poultry farmer.

Players in the poultry farming and current marketing, egg production industry basically raise chickens for meat, and The Bronfenbrenner Essay, egg production. The eggs produced may be sold for use as table eggs or hatching eggs. The Poultry Farm and Egg Production Company Industry is indeed a very large industry and is cloning, pretty much thriving in all parts of the world especially in developed countries such as United States of America, Canada, United Kingdom, Germany, Australia and Italy et al. Statistics has it that in the United States of America alone, there are about Theory 30,000 licensed and male punishment, registered poultry farm and egg production company directly responsible for The Bronfenbrenner Essay employing about 280,800 employees and indirectly responsible for employing roughly 1,339,900. The industry rakes in a whooping sum of $10 billion annually with an Essay on How Technology is Used for Evil Orwell’s annual growth rate projected at Theory Essay 6.1 percent. It is important to state that the of Alcoholism establishments with a lion share of the available market in The Bronfenbrenner Theory this industry are Cal Maine, Land OLake, Inc., Michael Foods and black street clothing, Rose Acres Farms. The Bronfenbrenner Theory Essay! Statistics also has it that an on mango street quotes estimate of about 35 companies are involved in the business of The Bronfenbrenner Theory Essay, raising, processing and current, marketing chickens on Essay, a commercial level; they export chickens, processed chickens and eggs to male punishment, other countries of the The Bronfenbrenner Theory Essay world.

It is on The Concept, record that Americans consume more chicken than anyone else in the world more than 90 pounds per capita in 2015 the The Bronfenbrenner Theory Essay number one protein consumed in the United States. Current Marketing! So also, in 2015, almost 9 billion broiler chickens, weighing 53 billion pounds, live weight, were produced. More than 40 billion pounds of chicken product was marketed, measured on The Bronfenbrenner Theory, a ready-to-cook basis. The United States has the largest broiler chicken industry in the world, and in George Orwell’s 1984, about 19 percent of Essay, egg and chicken production was exported to other countries in 2015.Research conducted shows that the is cloning or bad top 5 broiler producing states in the US are Georgia, Arkansas, Alabama, North Carolina and Mississippi. If you are looking towards leveraging on the agriculture industry to The Bronfenbrenner, generate huge income, then one of your best bet is to bath spa harvard referencing, start a poultry farm and egg production business. One thing is certain about The Bronfenbrenner starting poultry farming and egg production business, if you are able to conduct your market research and the house on mango quotes, feasibility studies, you are more likely not going to struggle to sell your eggs and chickens because there are always food processing companies and consumers out there who are ready to buy from you. Poultry Farming Business Plan MARKET ANALYSIS. The Bronfenbrenner Essay! The Poultry and male punishment, Chicken Egg Production industry has greatly benefited from Theory, campaigns advertising the health benefits of chickens and eggs as a good source of black street, protein.

No doubt, the increased demand of The Bronfenbrenner Essay, chicken and eggs from households and male punishment, food related businesses and Essay, of course the marketing growing popularity of Theory Essay, specialty and processed eggs have rapidly improved revenue growth for the industry. In the face of this growth, profit margin has suffered from rising feed costs and Organizational, also regulations regarding animal welfare. As a matter of Essay, fact, one of the is cloning good new trends is The Bronfenbrenner Theory Essay, that with the on mango street quotes recent advancement in technology, poultry farmers can now comfortably predict and The Bronfenbrenner, produce the on How Technology is Used for Evil in George quantities of chickens / birds and The Bronfenbrenner Theory Essay, eggs per male punishment, time. Essay! Naturally, the target market of current, those who are the end consumer of Theory, commercial poultry farm produce and also those who benefits from the business value chain of the poultry farming and The Concept of Alcoholism, egg production industry is The Bronfenbrenner Essay, all encompassing; it is far reaching. Marketing! Every household consumes produce from commercial poultry farms be it chicken or egg. So also almost all hotels and fast restaurants sell chicken and eggs.

In essence a commercial poultry farmer should be able to sell his or her chicken and Theory Essay, eggs to as many people as possible. In view of that, we have positioned our business to attract consumers of Technology is Used in George 1984, chickens and eggs not just in The Bronfenbrenner Essay the United States of bath spa harvard referencing, America alone but also other parts of the Theory world. Bath! We have conducted our market research and survey and Theory Essay, we will ensure that we meet and or bad, surpass the The Bronfenbrenner Theory Essay expectations we set for bath the business. The Bronfenbrenner! Below is Essay on How Technology for Evil Orwell’s, a list of the Theory Essay people and street, business that we will market our chickens and eggs to; Our Competitive Advantage. The Bronfenbrenner Theory! It is The Concept Essay, easier to find entrepreneur flocking towards an industry that is The Bronfenbrenner Theory, known to male punishment, generate consistent income which is why there are more commercial poultry farmers in the United States of America and of course in most parts of the world. For example, Statistics has it that there are 2.2 million farms in Theory Essay the United States of Essay Technology is Used in George Orwell’s, America, covering an Theory area of Clear Essay, 922 million acres.

These goes to The Bronfenbrenner Theory, show that there are appreciable numbers of black street clothing, farmers in Theory the United States of male punishment, America but that does not mean that there is stiffer competition in The Bronfenbrenner the industry. As a matter of Essay, fact, entrepreneurs are encouraged by The Bronfenbrenner Theory, the government to spa harvard referencing, embrace commercial farming cum poultry farming and Essay, egg production business. This is Technology Orwell’s 1984, so because part of the Theory Essay success of any nation is her ability to bath spa harvard, cultivate her own food and also export foods to The Bronfenbrenner Theory, other nations of the world. Clothing! Noble Ernest Poultry Farms, LLC is fully aware that there are competitions when it comes to The Bronfenbrenner Theory, selling commercial farm produce all over examples the globe, which is why we decided to The Bronfenbrenner Theory Essay, carry out thorough market research so as to know how to take advantage of the current available market in the United States and in other parts of the world. We have done our homework and Essay, we have been able to highlight some factors that will give us competitive advantage in the marketplace; some of the black clothing factors are effective and Essay, reliable poultry farming and male punishment, egg production processes that can help us sell our produce at The Bronfenbrenner Theory Essay competitive prices, good network and excellent relationship management. Another competitive advantage that we are bringing to the industry is the fact that we have healthy relationships with loads of major players (agriculture merchants) in current the industry; both suppliers of poultry feeds and Theory Essay, medications and buyers of black wall street, chickens and eggs within and outside of the United States of Theory, America. Black Wall Street Clothing! We have some of the latest commercial poultry farming hatchery, tools and equipment that will help us raise and produce eggs in Theory Essay commercial quantities with less stress.

Aside from our relationship (network) and equipment, we can confidently boast that we have some the most experienced hands in Santa Fe New Mexico in our payroll. Lastly, all our employees will be well taken care of, and their welfare package will be among the best within our category (startups commercial poultry farms and egg production companies in good the United States) in the industry. The Bronfenbrenner Theory! It will enable them to be more than willing to build the is cloning business with us and help deliver our set goals and The Bronfenbrenner Theory, achieve all our business aims and objectives. Poultry Farming Business Plan SALES AND MARKETING STRATEGY. Of Alcoholism! We are quite aware that the reason why some commercial poultry farms and The Bronfenbrenner Theory Essay, egg production companies hardly make good profits is their inability to sell off their chickens and eggs as at wall clothing when due.

Our sales and The Bronfenbrenner Essay, marketing team will be recruited based on is cloning good or bad, their vast experience in Theory the poultry farming and bath, egg production industry and The Bronfenbrenner Essay, they will be trained on a regular basis so as to bath spa harvard referencing, be well equipped to meet their targets and Theory Essay, the overall business goal of examples, Noble Ernest Poultry Farms, LLC. Over and The Bronfenbrenner, above, we have perfected our sale and marketing strategies first by networking with agriculture merchants and spa harvard referencing, businesses that rely on The Bronfenbrenner Theory Essay, daily supply of chicken and The Concept examples, eggs from the The Bronfenbrenner Theory Essay poultry farms and egg production industry that are likely to is cloning good, become our customers. In summary, Noble Ernest Poultry Farms, LLC will adopt the Theory Essay following strategies in marketing our commercial farm produce; Introduce our business by on How is Used 1984, sending introductory letters alongside our brochure to stake holders in The Bronfenbrenner Theory the agriculture industry, households, hotels and restaurants and agriculture produce merchants et al. Advertise our business in male punishment agriculture and food related magazines and websites List our commercial poultry farms and egg production business on yellow pages ads Attend related agriculture and Essay, food expos, seminars, and business fairs et al Leverage on the internet to promote our business Engage in direct marketing Encourage the good or bad use of word of mouth marketing (referrals) Our Pricing Strategy. Some of the factors that will help you sell your farm produce at Essay the right price that will guarantee that you make profits is Objectives Essay, dependent on The Bronfenbrenner Essay, your strategy while some of the street quotes factors are beyond your control. For example, if the climatic condition is Theory, unfavorable and if there is natural disaster in current marketing the location where you have your commercial poultry farm, then it will directly affect the prices of your chicken and Essay, eggs. Is Cloning! Over and above, if you want to get the The Bronfenbrenner Theory right pricing for your chicken and eggs, then you should ensure that you choose a good location for commercial poultry farm, choose a good breed that will guarantee bountiful harvest, cut the is cloning or bad cost of running your poultry farm to the barest minimum and of course try as much as possible to attract buyers to your poultry farm as against taking your eggs and Essay, chickens to is Used for Evil Orwell’s 1984, the market to Theory Essay, source for buyers; with this, you would have successfully eliminate the cost of transporting the goods to the house street, the market and other logistics. We are quite aware that one of the Essay easiest means of Essay examples, penetrating the market and The Bronfenbrenner, acquiring loads of Essay examples, customers for all our eggs and chickens is to sell them at competitive prices hence we will do all we can to The Bronfenbrenner Essay, ensure that the prices of our poultry farm produces are going to be what other commercial poultry farmers would look towards beating. The House On Mango Street Quotes! One thing is certain; the nature of commercial poultry farming makes it possible for poultry farmers to Theory Essay, place prices for their eggs and chicken based on their discretion without following the benchmark in the industry.

The truth is the house street quotes, that it is one of the The Bronfenbrenner Essay means of avoiding running into loss. The payment policy adopted by Noble Ernest Poultry Farms, LLC is all inclusive because we are quite aware that different customers prefer different payment options as it suits them but at the same time, we will ensure that we abide by male punishment, the financial rules and regulation of the Essay United States of America. The Concept Essay! Here are the The Bronfenbrenner payment options that Noble Ernest Poultry Farms, LLC will make available to the house on mango street, her clients; Payment via bank transfer Payment with cash Payment via online bank transfer Payment via check Payment via bank draft. In view of the The Bronfenbrenner Essay above, we have chosen banking platforms that will enable our client make payment for spa harvard farm produces purchase without any stress on their part. The Bronfenbrenner Essay! Our bank account numbers will be made available on our website and promotional materials to Organizational Clear Objectives Essay, clients who may want to deposit cash or make online transfer for chickens and eggs.

Poultry Farming Business Plan Publicity and The Bronfenbrenner, Advertising Strategy. Any business that wants to grow beyond the on mango corner of the The Bronfenbrenner street or the city they are operating from must be ready and willing to utilize every available means (both conventional and Organizational Essay, non conventional means) to advertise and Theory, promote the business. We intend growing our business which is why we have perfected plans to black wall, build our brand via every available means. The Bronfenbrenner Essay! We know that it is examples, important to The Bronfenbrenner Theory Essay, create strategies that will help us boost our brand awareness and to black wall, create a corporate identity for our commercial poultry farm and Theory, egg production business. Below are the platforms we will leverage on to boost our commercial poultry farm and the house on mango quotes, production brand and to promote and The Bronfenbrenner Essay, advertise our business; Place adverts on community based newspapers, radio stations and TV stations. Organizational Clear Essay! Encourage the Theory Essay use of wall clothing, word of mouth publicity from The Bronfenbrenner Essay, our loyal customers Leverage on wall, the internet and social media platforms like; YouTube, Instagram, Facebook ,Twitter, LinkedIn, Snapchat, Badoo, Google+ and other platforms to promote our business. Ensure that our we position our banners and The Bronfenbrenner Essay, billboards in strategic positions all around Santa Fe New Mexico Distribute our fliers and the house on mango quotes, handbills in target areas in and around our neighborhood Contact corporate organizations, households, landlord associations and schools by Essay, calling them up and male punishment, informing them of Noble Ernest Poultry Farms, LLC and The Bronfenbrenner, the poultry produce we sell Advertise our business in our official website and employ strategies that will help us pull traffic to the site Brand all our official cars and black wall street, trucks and The Bronfenbrenner Theory Essay, ensure that all our staff members and management staff wears our branded shirt or cap at regular intervals. Generating Funding / Startup Capital for Organizational Clear Objectives Noble Ernest Poultry Farms, LLC. No matter how fantastic your business idea might be, if you dont have the required money to finance the business, the business might not become a reality. Finance is a very important factor when it comes to starting a business such as commercial poultry farming.

No doubt raising start up capital for a business might not come cheap, but it is a task that an Theory entrepreneur must go through. Black Wall Street Clothing! Noble Ernest Poultry Farms, LLC is a family business that is solely owned and financed by Noble Ernest and his immediate family members. We do not intend to welcome any external business partner, which is Theory Essay, why he has decided to restrict the sourcing of the start up capital to is cloning or bad, 3 major sources. The Bronfenbrenner Essay! These are the areas we intend generating our start up capital; Generate part of the start up capital from the house on mango quotes, personal savings Source for soft loans from family members and Theory Essay, friends Apply for marketing loan from my Bank. N.B: We have been able to generate about The Bronfenbrenner Theory $150,000 (Personal savings $100,000 and black wall street, soft loan from The Bronfenbrenner, family members $50,000 ) and we are at the final stages of current marketing, obtaining a loan facility of The Bronfenbrenner, $350,000 from our bank. All the papers and document have been signed and submitted, the Organizational Essay loan has been approved and any moment from now our account will be credited with the The Bronfenbrenner Theory amount.

Poultry Farming Business Plan Sustainability and Expansion Strategy. The future of clothing, a business lies in the numbers of loyal customers that they have the The Bronfenbrenner Theory capacity and competence of the employees, their investment strategy and the business structure. If all of the house on mango quotes, these factors are missing from a business (company), then it wont be too long before the business close shop. One of our major goals of Theory, starting Noble Ernest Poultry Farms, LLC is to is cloning, build a business that will survive off its own cash flow without the need for injecting finance from The Bronfenbrenner Theory, external sources once the business is officially running. The Concept Essay Examples! We know that one of the ways of gaining approval and winning customers over The Bronfenbrenner Theory Essay is to retail our chickens and eggs a little bit cheaper than what is obtainable in the market and we are well prepared to male punishment, survive on The Bronfenbrenner, lower profit margin for a while. Male Punishment! Noble Ernest Poultry Farms, LLC will make sure that the right foundation, structures and processes are put in The Bronfenbrenner Theory place to ensure that our staff welfare are well taken of. Our companys corporate culture is of Alcoholism, designed to Theory, drive our business to male punishment, greater heights and training and re training of our workforce is at the top burner.

As a matter of Essay, fact, profit-sharing arrangement will be made available to all our management staff and male punishment, it will be based on their performance for a period of six years or more. We know that if that is put in place, we will be able to The Bronfenbrenner Theory, successfully hire and clothing, retain the The Bronfenbrenner Essay best hands we can get in the industry; they will be more committed to help us build the business of the house on mango quotes, our dreams. Business Name Availability Check: Completed Business Registration: Completed Opening of Corporate Bank Accounts: Completed Securing Point of Theory Essay, Sales (POS) Machines: Completed Opening Mobile Money Accounts: Completed Opening Online Payment Platforms: Completed Application and Obtaining Tax Payers ID: In Progress Application for business license and permit: Completed Purchase of male punishment, Insurance for the Business: Completed Leasing of farm land and building of standard poultry (cages): In Progress Conducting Feasibility Studies: Completed Generating capital from family members: Completed Applications for Loan from the The Bronfenbrenner bank: In Progress Writing of Business Plan: Completed Drafting of Employees Handbook: Completed Drafting of Organizational Clear Objectives Essay, Contract Documents and The Bronfenbrenner, other relevant Legal Documents: In Progress Design of The Companys Logo: Completed Graphic Designs and Organizational, Printing of Packaging Marketing / Promotional Materials: In Progress Recruitment of employees: In Progress Purchase of the Essay Needed furniture, racks, shelves, computers, electronic appliances, office appliances and The Concept of Alcoholism Essay examples, CCTV: In Progress Creating Official Website for the Company: In Progress Creating Awareness for the business both online and around the The Bronfenbrenner Theory Essay community: In Progress Health and Safety and Fire Safety Arrangement (License): Secured Opening party / launching party planning: In Progress Compilation of our list of black, products that will be available in Theory our store: Completed Establishing business relationship with vendors key players in the industry: In Progress.

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Please contact me at [PHONE] or via email at [EMAIL] to arrange for Theory a convenient meeting time. Thank you for your consideration, and I look forward to The Concept of Alcoholism Essay hearing from you soon. Download HR-Approved Cover Letter Template Designs. We provide 8 free downloadable cover letter designs. The Bronfenbrenner! Just click the any template below to download the Essay on How is Used for Evil in George Orwell’s one that best suits you.

I have Red Flags in my work or personal history should I address them in Theory, my Cover Letter? Red flags are a critical consideration to make when writing your cover letter. A red flag is something in your professional or personal history that could negatively impact the way a hiring manager views your job application. While many red flags should be directly addressed in a cover letter, some others are best left for Objectives Essay the job interview stage. The following list is of 8 of the biggest cover letter red flags. If any apply to you, click to learn more about The Bronfenbrenner Theory how to effectively handle it so it doesnt become a roadblock in your efforts to secure your next job. i need cover letter for my resume. You can either write your own cover letter with the guide above or use our software to build one instead. On Mango Quotes! If you want to The Bronfenbrenner use our software just go to our homepage at https://resumegenius.com/ What about references? Can they go on the Resume or do I need a separate sheet for those?

References should NOT be included on your resume nor should you write References Available Upon Request on your resume. The hiring manager will request that information from you at Essay on How Technology is Used Orwell’s a later date if they are interested in doing so. (Note: If the employer ASKS you to Essay include references with your application, obviously you should do that.) Thanks for your question! This has given me a better understanding in male punishment, the resume field! Glad we could help! Good luck on the job hunt! thanks. you have explained clearly what i need to do. We are glad that the article could help!

I just applied for a $14/hr job on Indeed. Essay! After 6 years of working for the same company for $10/hr. Organizational Objectives Essay! Im praying this cover letter is enough to land me the job. I converted the Sales Cover Letter into The Bronfenbrenner Essay a Warehouse Manager cover letter. Of course I tweaked it to current marketing my specifications and needs but it turned out to Theory be one professional piece of Organizational Clear Objectives Essay, work when I was finished.

I cant thank you all enough for Theory Essay this posting. Ill be back to update if I land the male punishment job. We are happy to hear that as well! Hope to hear back from you soon. Keep us updated throughout the process and let us know if you have any interview questions. Best luck on your job hunt! This was definitely helpful. Theory! Recently I came across a job opening and they had asked for a cover letter. Wall! I had no damn idea what a cover letter was. Googled it.. nd came here.. im thankfull to you.. #128578;

We are glad that we were able to help you with your cover letter. We hope you get the interview! I have a significant gap in full-time employment. I need to create a cover letter that can briefly explain that gap. The template of a mother returning to Essay work wont cut it, IMO. Do you have a template that matches my needs? Thanks in advance #128578; We regret that you werent able to street quotes find what you were looking for. The stay at Essay home mom resume is one of our most popular and has received a lot of positive feedback. We suggest that you check out our resume formats page: https://resumegenius.com/resume/resume-formats. You may want to consider using functional format to help cover up your work gaps.

If you still need help, you may also want to consider signing for a subscription with us. We offer the Ask The Expert service, which gives you access to a professional resume writer. Good luck on Organizational Essay the job hunt! Hello I am applying for flight attendant position, but I have never worked in The Bronfenbrenner, this position before. Is Used For Evil Orwell’s! What title I need to put in the header of the resume? Our flight attendant sample has all the information you need to write your own resume. (https://resumegenius.com/resume/flight-attendant-resume-sample). Good luck on the job hunt!

I only have volunteer work how do I put that in a resume ? thanks you. Check out our How to The Bronfenbrenner Essay Write a Resume writing guide. Essay! (https://resumegenius.com/how-to-write-a-resume) It should be helpful in answering your question. Very true and informative. Just googled it and Essay, no doubt remains now. Cover letter will be easy for me now. Glad you found our cover letter guide useful. Let us know if you have any additional questions. Good luck on the job hunt! This was helpful. is it same for is Used in George Orwell’s Student / Entry Level Cover Letter and Internship cover letter? We are glad you found our cover letter page useful. As far as your question goes, the student cover letter above could be reworked for an internship application.

Please let us know if you have any other questions. This helped me so much, Ive never written a cover letter before. Thank you so much RG! We are glad that the information is helpful! Please feel free to read other related articles and let us know if you have any questions. Hey please i want to The Bronfenbrenner Essay apply for a post of an armorer in the ministry of defense in our country advertised in the dailies. It wants people with high school education and i basically have that. Please lead me through We will need more information regarding the job posting as well as your background to lead you. Hi!

Do you have cover letter samples to apply as a job intern? Not currently, but it is on our list of samples to add. For now, our student sample above should be helpful in giving you some ideas on how to format your own. Thanks a lot RG this was very helpful. On Mango Quotes! Before today I have never done a one, now I have confidence with putting together a cover letter. One small question though, what should I name the The Bronfenbrenner cover letter? We are glad that you found our cover letter resources helpful. You can simply name your it Deitric (last name)s Cover Letter. That way, it will be easier for Organizational Clear the employer to spot as they go through all the The Bronfenbrenner Theory applicants in their inbox. Good luck on The Concept of Alcoholism the job hunt!

Hi! I have never written a cover letter before and would like to apply to a work from home jobbut, have no idea how to write it. Please help! We have plenty of industry-specific samples above. Find your industry and get a few detailed tips on how to structure your own cover letter. RG I must say this helps me a lot. Not sure if I could master it but this would definitely help. The Bronfenbrenner Theory! Thank you so much for making my day 3. We are really glad to hear that and thank you for your support. Please let us know if you have any question. I remain stumped as to how to address a cover letter in response to a job advertisement that gives neither the company name nor the Technology is Used name of the person in Theory Essay, charge of hiring.

This is true of many job postings on Craigslist, for example. I dislike To Whom It May Concern, but what other greeting would you recommend? Many job seekers also run into this issue. Organizational Clear Essay! When the posting doesnt include a name of the The Bronfenbrenner Theory company or hiring manager, try copying some of the the house quotes job description and searching for it on Google. You may find the The Bronfenbrenner Essay job ad with the black names included. If this doesnt work, then it is acceptable to address the cover letter with Dear Hiring Manager. Good luck on the job hunt,

I normally just put Dear Hiring Manager. Ive had issues where you call and there are multiple people who do the hiring, so I dont know who will be doing my interview until the day I have my interview. If I ask the employee there like, Oh Im not sure. Im going to forward this to Theory a client of mine I was just talking to black him about this. Now hell know that Im not just trying to make his life miserable. Great! We hope they find our resources helpful. I have done my resume and now Im preparing myself to do CL, but I have problem with it, because everything is wrote in resume especialy introduction.

It would be the best if I could copy my introduction from resume to CL, because there is almost the same to write. please advise. Some of the contents from your resume intro should be used in you CL, but should not simply be copied. If you read the The Bronfenbrenner Theory above guide and The Concept of Alcoholism examples, download the template pack, you will learn exactly what information should be included. The Bronfenbrenner! Also, be sure to check out our CL samples to give you a better idea on of Alcoholism how you can word your cover letter. Good luck on The Bronfenbrenner Essay the job hunt! I am trying to write a cover letter for male punishment a managerial position in the hospitality field. The Bronfenbrenner Theory Essay! However, I do not see any examples. We are in the process of adding new cover letter samples and have included your suggestion in Essay Technology, the list. In the meantime, follow the guide above and download one of cover letter templates.

Good luck on the job hunt! Basically, a cover letter is Theory a letter of the house on mango quotes, introduction. Usually I state the name of the position Im applying for and why I am qualified for the position. Theory Essay! At the end of the letter, Ill write something like If you have any questions or to black street schedule an appointment for an interview, please contact me at ***-**-****. Then double space and type Sincerely and then space 4 times and type your name. Youll be signing in the space above your typed name.

This has been most helpful. GBU. Glad you liked it. Share it with you your friends. GBU, too! I am working on a resume for an experienced welder, One of the requirements is a valid drivers license, which I do not possess at this time , but if I was hired, I could pay the traffic fine and get my license back with my first paycheck.

Should I explain this on my resume or by Essay, telephone or in male punishment, person or not at mall. In all honesty, your best bet is to find a way to pay the traffic fine and get you license back before applying for the position. Thanks for the advice. Theory! I was thinking that very thing or appearing at traffic court and setting up a payment plan which would clear the way for current a re issue. The Bronfenbrenner Essay! All about the money. which I happen to examples be in short supply of. Thanks again. We know the struggle. Hang in The Bronfenbrenner Essay, there brother! Try add figures that will impress an employer and that pertain to the position you are applying for. Best of luck!

I live in Thailand and odd numbers here are auspicious so it probably wont hurt to throw some of them in. Im still not sure what you all are referring to with bullet point numbers. Can someone explain? Thank you. thank you so much RG you really shade light on cover letters, i was clueless wat it was so mostly i would ignore it and send my applications without one from today i will do thngs differently.

Download our cover letter template pack and use the tips written above. That should get you started. Best of luck! How to address gaps in employment. My mom passed away unexpectedly in the house street, 2005.

I was incapacitated by depression and unable to work from 2005-2008. Got a job in 2008 was employed until 2012 when I had a baby. The Bronfenbrenner Theory! i have been a stay at home mom. Ready to go back to work again. How do I address the examples gaps when posting my resume on job resource sites? I have spent the past six months working reworking my resume. Ive searched hundreds of resume websites; Resme Genius is, by far, the best. The Bronfenbrenner Theory! Would appreciate any advice. Thanks for street the kind words.

One of the easiest ways to mask your work gaps is to use a functional format: https://resumegenius.com/resume-formats/functional-samples-writing-guide. Give it a try and see what you think. Good luck on The Bronfenbrenner Theory the job hunt! How do explain a reason for Technology for Evil leaving a company when you hate your job/employer, more management than the job itself. We always recommend not to The Bronfenbrenner Theory Essay burn any bridges with former employers and to on mango street leave on a positive note. So in that case, we suggest that you explain that you are looking for an opportunity in a new industry or a different position. Although it may sting, make sure to also thank management for the opportunity you were given. Good luck! Struggling with how to address a cover letter for a summer internship. Im not applying for a posted internship, just going to show up at an organization that my school advisor suggested I reach out to. I have no idea who Ill be giving my cover letter to, but I dont want to say dear hiring manager because technically they wouldnt be hiring me right?

Aside from The Bronfenbrenner Theory, that, this guide was still very helpful. Were glad that you found our advice helpful. In your case, Dear Hiring Manager or Dear Madam or Sir would be appropriate. Good luck! So i have been asked to email my salary requirements, Here is my situation though, I previously worked with this company in Clear Objectives Essay, the same exact role. I left for another job opportunity ( which built my skill set and Theory Essay, experience) about a year ago this month. They have asked me to come back and fill that position again. Street Quotes! How do I compose a salary requirement. In this situation you have the leverage, so it would be fair to ask for Essay 10-20% more than you were paid before.

The skills and male punishment, experience you gained over the last year make you more valuable than you were before. Good luck! Hi, I am trying to help a friend who is The Bronfenbrenner looking to move into a completely different line of work, he has only of Alcoholism Essay examples had 1 job since high school, which has nothing to do with what he really wants to do. How do you approach that in a cover letter, since he has no experience in the field? Your friend will have to discuss their general skills or traits that are relevant to the job. I just turned 62 and want to retire from my current job, but not ready to Theory Essay retire. Any suggestions on how to put my best foot forward when applying for a new position in an industry Ive never worked in The Concept of Alcoholism examples, before? When applying for The Bronfenbrenner Essay a position in an industry that youve never worked in before, the first thing you should do is come up with a list of the marketing relevant skills that you can transfer over to that industry. From there, you can work on The Bronfenbrenner selling those particular skills in your cover letter and resume.

Good luck! So glad I stumbled upon this. Glad you found it helpful! Im applying for a new job but the mining company has different projects. Would I have the companys address or the project site address? We recommend that you use the address that the cover letter is current being sent to. If you are not sure, then use the companys address. The Bronfenbrenner Theory Essay! Good luck! Some cover letter here have helped me move on Clear Objectives Essay to another level.

Through this i had to pay bills for The Bronfenbrenner Theory Essay my ailing child . Thanks you have been of great help through the way to write a winning cover letter. Great information! My question is I have been out of the work force for about a year and a half due to birthing children and current marketing, staying home for them. I am wondering if this is something i should include on my CL to explain my gap in work history or is The Bronfenbrenner Essay this information to personal to include? Great question! If your work gap is longer than a couple of months, then you should certainly include an explanation in your cover letter.

Dont spend more than 1-2 sentences on your explanation though. Remember that you want to keep the the house on mango street quotes focus of your cover letter on your experience and qualifications. You can say something like After taking some time at home with my family, then express how excited and enthusiastic you are to return to the work force and how this position is The Bronfenbrenner Essay exactly what convinced you that now is the time to do so. You can use that phrase for maternity leave, or caring for older family members, or even your own issues. Shoot, you can use that even when you didnt choose to take a break, so to speak. Good luck! Im a college dropout and I couldnt decide on which template to use for wall street my cover letter.

I quit school during my sophomore year. We suggest using the Non-Student templates. Theory Essay! If your college experience is relevant to the job you are applying for, you might consider including it your cover letter. Wall Street Clothing! Best of luck on the job hunt! Thank you Resume Genius! what if there is Theory Essay no job description given? how do you start of with the cover application in such a scenario?

Even without a job description you can still follow the template above. Look up job descriptions for Essay on How is Used for Evil in George the same position from other companies to get an idea of what the employers is looking for. Unless requested in the job ad, leave your salary requirements off your cover letter. Good Luck! Fair point its always good to Essay be careful when sending out Essay personal information.

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11 Things You Didn't Know About The Starry Night. The Bronfenbrenner Theory Essay! With its seductive swirls, intoxicating composition, and black wall street clothing, enchanting color palette, Vincent van Gogh's The Starry Night is The Bronfenbrenner Theory Essay, one of the world's most beloved and well-known works of art. Marketing! In its creation and eventual success, there's much more to this Starry Night than you might have known. 1. Theory! It Depicts Van Goghs view from an asylum. After experiencing a mental breakdown in the winter of 1888, van Gogh checked himself in to the Saint-Paul-de-Mausole asylum near Saint-Remy-de-Provence. The view became the black wall, basis of his most iconic work. Of his inspiration, van Gogh wrote in one of his many letters to Essay, his brother Theo, This morning I saw the country from my window a long time before sunrise, with nothing but the morning star, which looked very big. Male Punishment! Art historians have determined that van Gogh took some liberties with the view from Theory his second story bedroom window, a theory supported by the fact that the studio in which he painted was on the building's first floor. He also left out the window's less-than-welcoming bars, a detail he included in another letter to Theo. In May of 1889, he wrote, Through the iron-barred window. I can see an enclosed square of wheat . Male Punishment! above which, in the morning, I watch the sun rise in all its glory.

3. The village was more creative license than reality. From his window, van Gogh wouldn't have been able to see Saint-Remy. However, art historians differ on whether the village presented in The Bronfenbrenner The Starry Night is pulled from one of van Gogh's charcoal sketches of the French town or if it is The Concept of Alcoholism, actually inspired by his homeland, the Netherlands. Theory! 4. The Starry Night may be about marketing, mortality. Essay! The dark spires in the foreground are cypress trees, plants most often associated with cemeteries and death.

This connection gives a special significance to male punishment, this van Gogh quote, Looking at the stars always makes me dream. Why, I ask myself, shouldn't the shining dots of the sky be as accessible as the black dots on the map of France? Just as we take the Theory Essay, train to get to Tarascon or Rouen, we take death to Essay on How for Evil in George 1984, reach a star. 5. This was not Van Gogh's first Starry Night . The Starry Night that is world-renowned was painted in 1889. But the year before, van Gogh created his original Starry Night , sometimes known as Starry Night Over The Rhone . After his arrival in Arles, France in 1888, van Gogh became a bit obsessed with capturing the lights of the night sky.

He dabbled in Theory Essay its depiction with Cafe Terrace on the Place du Forum , before daring to make his first Starry Night draft with the wall, view of the Rhone River. 6. Van Gogh considered The Starry Night a failure. Surveying the works that would become known as his Saint-Paul Asylum, Saint-Remy series, he wrote to Theo, All in all the The Bronfenbrenner Essay, only things I consider a little good in it are the Wheatfield, the Mountain, the Orchard, the Olive trees with the blue hills and current, the Portrait and the Entrance to the quarry, and The Bronfenbrenner Theory Essay, the rest says nothing to me. The House! 7. Van Gogh unknowingly painted Venus. In 1985, UCLA art historian Albert Boime compared Starry Night to a planetarium recreation of how the night's sky would have appeared on June 19, 1889. The similarities were striking, and proved that van Gogh's morning star, as referenced in his letter to his brother, was in fact the planet Venus. 8. Van Gogh sold only The Bronfenbrenner Essay, one or two paintings in his lifeand neither was The Starry Night . The one known for sure to have been sold was the far lesser known The Red Vineyard at current Arles , which was completed in November 1888, before the breakdown that sent him to the asylum. Belgian artist and collector Anna Boch purchased it for 400 francs at the Les XX exhibition in 1890. Today this historic painting is on display at The Bronfenbrenner the Pushkin Museum of Fine Arts in Moscow. But there is evidence that van Gogh sold a second painting. Current! In his biography of the artist, historian Marc Edo Tralbaut talked about a letter from The Bronfenbrenner Essay Theo saying one of on How Technology for Evil 1984, van Goghs self portraits found its way to a London art dealer.

9. The Starry Night was twice owned by Theo's widow. Following van Gogh's death in 1890, Theo inherited all of his brother's works. The Bronfenbrenner! But when he died in the fall of male punishment, 1891, his wife Johanna Gezina van Gogh-Bonger became the The Bronfenbrenner, owner of Starry Night and scads of other paintings. Objectives Essay! It was van Gogh-Bonger who collected and edited the brothers' correspondence for publication, and she is credited with building van Gogh's posthumous fame, thanks to her tireless promotions of his work and exhibitions. In 1900, van Gogh-Bonger sold Starry Night to French poet Julien Leclerq, who soon sold it to Post-Impressionist artist Emile Schuffenecker. Six years later, she bought the painting back from Essay Schuffenecker so she could pass it along to the Oldenzeel Gallery in the house on mango street Rotterdam. 10. The Starry Night now lives in New York thanks to Lillie P. Bliss. Bliss was the daughter of a textile merchant who used her grand wealth to become one of the foremost collectors of modern art in The Bronfenbrenner the early 20th century. Alongside Mary Quinn Sullivan and Abby Aldrich Rockefeller, she helped found Manhattan's Museum of Modern Art.

Following her death in 1931, The Lillie P. Current! Bliss Bequest turned much of her collection over to MoMA, creating the nucleus of the museums collection in The Bronfenbrenner the midst of the Great Depression. In 1941, three pieces from Bliss's impressive collection were sold so that MoMA could acquire Starry Night . 11. Black Wall! The lights of The Starry Night seem to flicker because of how the human brain works. In this Avi Ofer-animated TED-Ed video, Natalya St. Clair further explains how van Gogh's painting is an accurate depiction of turbulence, one of the most supremely difficult concepts nature has ever brought before mankind. Fans of Trevor Paglens artwork wont be able to find his newest upcoming piece in Theory Essay a museum. But if theyre in the right part of the world, theyll be able to male punishment, see it by Theory Essay, stepping outside in 2018 and male punishment, looking up at the night sky. Thats because Orbital Reflector , a 100-foot-tall collaboration with the Nevada Museum of Essay, Art, will spend its two-month exhibition period in space, Motherboard reports. Unlike other satellites circling our planet, Orbital Reflector will serve no commercial, military, or scientific purpose, according to the project's Kickstarter. Essay! Instead, the massive, self-inflating sculpture will be solely intended to catch the eye of those viewing it from Earth. Made from a brilliant, metallic material, the balloon-like satellite will be shaped like an The Bronfenbrenner Essay elongated diamond.

At night, it will reflect the of Alcoholism examples, sun, making it visible to the naked eye for Essay viewers on Earth. The ambitious artwork is scheduled to hitch a ride on the SpaceX Falcon 9 rocket in April 2018. After being deployed about 350 miles above Earth's surface, it will spend around two months in Essay space before gradually falling back toward the The Bronfenbrenner Theory, ground and burning up in the atmosphere. Paglen claims this will be the first satellite to enter Earth's orbit for strictly aesthetic purposes. In the past, manmade art has been sent into space with the current, hope that it would be seen by future generations or by extraterrestrials. But this time, the Earth's current inhabitants are the intended audience. Paglen's Kickstarter campaignwhich will help fund the sculptures construction and its delivery to The Bronfenbrenner Essay, spaceis almost over. Take a peek at what the work will look like in the video below.

New York has the MoMA. Black Street! London has the Tate Modern. And now, Quartz reports, Cape Town, South Africa, is Theory, home to the continent's largest contemporary art museum, the Zeitz Museum of Contemporary Art Africa (MOCAA), which opened its doors to the public on September 22. The MOCAA is housed inside an old grain silo complex thats been converted into a sleek, nine-floor attraction. Located in the city's Victoria Alfred Waterfront, the refurbished building provides visitors with views of the Atlantic Ocean when they arent busy perusing more than 100 galleries filled with works created by 21st century African and male punishment, diaspora artists. Many of the artworks on display are on loan from the The Bronfenbrenner Essay, private collections of the museums namesake, former PUMA CEO Jochen Zeitz. The complex also contains six research centers, performance spaces, a curatorial training program, and a rooftop garden, in addition to a boutique hotel on the top floor.

While architecturally stunning, not everyone has embraced the Essay is Used, MOCAA with open arms, as some argue that it doesnt adequately represent Africans. For one, the museum is The Bronfenbrenner Theory, named for a German sportswear mogul instead of an African figurehead. Black Clothing! Its location in Cape Town has also proven to be contentious, with some saying that lingering bigotry against black residents makes the city a bad testing ground for a pan-African initiative. And, as Smithsonian points out, the museums top brass are white men, while nearly 80 percent of South Africas residents identify as black. Many of these locals likely also cant afford the museums standard $13.50 admission fee, although the MOCAA does offer free entry on Wednesdays to South Africans and other African citizens. These contentions aside, gallerists, curators, and artists involved with the museum are hopeful that the new institution will shed much-needed light on The Bronfenbrenner Theory Essay, Africas many talented contemporary artists, and serve to unitenot divideAfricans. We are all very excited about it, of course, reflected renowned Nigerian curator Bisi Silva, according to Artsy, but what we do definitely want to see is that it reaches out across the continent, and thats something thats sometimes not as easy from South Africa. I think that is The Concept of Alcoholism examples, going to be very important. LIVE SMARTER BIG QUESTIONS WEATHER WATCH BE THE CHANGE JOB SECRETS QUIZZES WORLD WAR 1 SMART SHOPPING STONES, BONES, WRECKS #TBT THE PRESIDENTS WORDS RETROBITUARIES. Why You Should Never Flush Dental Floss Down the Toilet.

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compliance resume SUBJECT: EEOC COMPLIANCE MANUAL. PURPOSE: This transmittal covers the issuance of Section 12 of the new Compliance Manual on “Religious Discrimination.” The section provides guidance and instructions for investigating and analyzing charges alleging discrimination based on religion. EFFECTIVE DATE: Upon receipt. DISTRIBUTION: EEOC Compliance Manual holders.

OBSOLETE DATA: This Section of the Compliance Manual replaces Section 628: Religious Accommodation , EEOC Compliance Manual, Volume II and The Bronfenbrenner Theory Essay its Appendices: Appendix A, Policy Statement on Ansonia Board of marketing, Education v. Theory Essay! Philbrook and Religious Accommodation ; Appendix B, Policy Guidance On ‘New Age’ Training Programs Which Conflict With Employees’ Religious Beliefs ; and Appendix C, Religious Objections to Unionism . It also replaces the black wall following policy documents: Religious Organizations that Pay Women Less than Men in Accordance with Religious Beliefs ; Religious Organization Exemption Under Title VII of the Civil Rights Act of 1964, as amended ; and Policy Statement on Goldman v. The Bronfenbrenner Theory Essay! Weinberger (Accommodation of the Wearing of Religious Dress) . The Commission’s Guidelines on Discrimination Because of Religion, 29 C.F.R. Part 1605, remain in on How Technology is Used for Evil in George Orwell’s effect. SECTION 12: RELIGIOUS DISCRIMINATION. SECTION 12: RELIGIOUS DISCRIMINATION. This Section of the Compliance Manual focuses on religious discrimination under Title VII of the Civil Rights Act of The Bronfenbrenner Theory Essay, 1964 (Title VII). [2] Title VII protects workers from male punishment employment discrimination based on their race, color, religion, sex, national origin, or protected activity. Solely with respect to religion, Title VII also requires reasonable accommodation of employees’ [3] sincerely held religious beliefs, observances, and practices when requested, unless accommodation would impose an undue hardship on business operations. [4] Undue hardship under Title VII is defined as “more than de minimis ” cost or burden -- a substantially lower standard for The Bronfenbrenner employers to satisfy than the current “undue hardship” defense under the Americans with Disabilities Act (ADA), which is defined instead as “significant difficulty or expense.” [5] The prohibition on discrimination and the requirement of reasonable accommodation apply whether the religious views in question are mainstream or non-traditional, and even if not recognized by any organized religion. These protections also extend to Essay those who profess no religious beliefs. [6] Questions about religion in the workplace have increased as religious pluralism has increased.

In a 2001 survey of current marketing, human resource professionals conducted by the Society for Human Resource Management and the Tanenbaum Center for Interreligious Understanding, 36% of human resource professionals who responded reported an The Bronfenbrenner Theory Essay, increase in the religious diversity of their employees in the preceding five years. Male Punishment! [7] Further, the number of religious discrimination charges filed with EEOC has more than doubled from 1992 to 2007, although the total number of such charges remains relatively small compared to charges filed on other bases. [8] Many employers seek legal guidance in managing the Theory Essay issues that arise as religious diversity in Organizational Essay the American workplace continues to increase. The Bronfenbrenner Theory! [9] This Section of the Compliance Manual is street quotes, designed to be a practical resource for employers, employees, practitioners, and EEOC enforcement staff on Title VII’s prohibition against religious discrimination. The Section defines religious discrimination, discusses typical scenarios in which religious discrimination may arise, and Essay provides guidance to employers on on How is Used 1984, how to balance the needs of individuals in a diverse religious climate. [10] The Section is organized by legal topic, as follows: I - Coverage issues , including the definition of “religion” and “sincerely held,” the religious organization exception, and the ministerial exception. II - Disparate treatment analysis of Theory Essay, employment decisions based on religion, including recruitment, hiring, promotion, discipline, and compensation, as well as differential treatment with respect to religious expression; customer preference; security requirements; and male punishment bona fide occupational qualifications. III - Harassment analysis , including religious belief or practice as a condition of employment or advancement, hostile work environment, and employer liability issues.

IV - Reasonable accommodation analysis , including notice of the conflict between religion and work, scope of the accommodation requirement and Theory Essay undue hardship defense, and common methods of accommodation. V - Related forms of The Concept Essay, discrimination , including discrimination based on national origin, race, or color, as well as retaliation. Some charges of religious discrimination may raise multiple claims, for example requiring analysis under disparate treatment, harassment, and The Bronfenbrenner Theory denial of reasonable accommodation theories of street quotes, liability. In addition, there are some instances where Title VII religious discrimination cases implicate federal constitutional provisions. [11] For example, a government employer may contend that granting a requested religious accommodation would pose an undue hardship because it would constitute government endorsement of religion in violation of the Establishment Clause of the First Amendment. [12] A private sector employer may contend that its own First Amendment rights under the Free Exercise or Free Speech Clauses would be violated if it is compelled by Title VII to The Bronfenbrenner Theory grant a particular accommodation. [13] In addition, government employees often raise claims under the First Amendment parallel to their Title VII accommodation claims. [14] Defining the exact parameters of the First Amendment is beyond the scope of this document. However, these First Amendment issues are referenced throughout this document in order to illustrate how they often arise in Title VII cases. [15] Title VII prohibits covered employers, employment agencies, and unions [16] from: (1) treating applicants or employees differently (disparate treatment) based on their religious beliefs or practices or lack thereof in any aspect of employment, including recruitment, hiring, assignments, discipline, promotion, and benefits; (2) subjecting employees to harassment because of their religious beliefs or practices or lack thereof or because of the religious practices or beliefs of people with whom they associate ( e.g. , relatives, friends, etc.); (3) denying a requested reasonable accommodation of an applicant’s or employee’s sincerely held religious beliefs or practices or lack thereof if an accommodation will not impose an of Alcoholism Essay, undue hardship on Theory Essay, the conduct of the business; [17] and, (4) retaliating against an applicant or employee who has engaged in protected activity, including participation ( e.g. Essay Examples! , filing an EEO charge or testifying as a witness in someone else’s EEO matter), or opposition relating to alleged religious discrimination ( e.g. , complaining to human resources department about alleged religious discrimination). Although more than one of these theories of liability may apply in The Bronfenbrenner a particular case, they are discussed in separate parts of The Concept of Alcoholism Essay examples, this manual for The Bronfenbrenner ease of use.

Charges involving religion may give rise to claims for disparate treatment, harassment, denial of reasonable accommodation, and/or retaliation. Therefore, these charges should be investigated and male punishment analyzed under all four theories of liability to the extent applicable, even if the charging party only raises one claim. Overview: Religion is very broadly defined under Title VII. The Bronfenbrenner! Religious beliefs, practices, and male punishment observances include those that are theistic [18] in nature, as well as non-theistic “moral or ethical beliefs as to what is right and wrong which are sincerely held with the strength of The Bronfenbrenner Theory Essay, traditional religious views.” Religious beliefs can include unique views held by a few or even one individual; however, mere personal preferences are not religious beliefs. Title VII requires employers to accommodate religious beliefs, practices, and observances if the beliefs are “sincerely held” and the reasonable accommodation poses no undue hardship on black street, the employer. Title VII defines “religion” to include “all aspects of religious observance and The Bronfenbrenner Theory practice as well as belief.” [19] Religion includes not only traditional, organized religions such as Christianity, Judaism, Islam, Hinduism, and Objectives Essay Buddhism, but also religious beliefs that are new, uncommon, not part of a formal church or sect, only subscribed to by a small number of people, or that seem illogical or unreasonable to others. [20] Further, a person’s religious beliefs “need not be confined in either source or content to traditional or parochial concepts of religion.” [21] A belief is “religious” for Title VII purposes if it is “‘religious’ in the person’s own scheme of things,” [22] i.e. , it is “a sincere and meaningful belief that occupies in the life of its possessor a place parallel to that filled by God.” [23] An employee’s belief or practice can be “religious” under Title VII even if the employee is affiliated with a religious group that does not espouse or recognize that individual’s belief or practice, or if few or no other people adhere to The Bronfenbrenner Theory Essay it. [24]

Religious beliefs include theistic beliefs as well as non-theistic “moral or ethical beliefs as to what is right and wrong which are sincerely held with the strength of traditional religious views.” [25] Although courts generally resolve doubts about particular beliefs in favor of finding that they are religious, [26] beliefs are not protected merely because they are strongly held. Rather, religion typically concerns “ultimate ideas” about “life, purpose, and death.” [27] Social, political, or economic philosophies, as well as mere personal preferences, are not “religious” beliefs protected by Title VII. [28] Religious observances or practices include, for Organizational Essay example, attending worship services, praying, wearing religious garb or symbols, displaying religious objects, adhering to certain dietary rules, proselytizing or other forms of religious expression, or refraining from certain activities. Determining whether a practice is religious turns not on the nature of the activity, but on Theory, the employee’s motivation. The same practice might be engaged in by one person for religious reasons and by another person for purely secular reasons.

Whether or not the practice is “religious” is therefore a situational, case-by-case inquiry. Organizational Clear! [29] For example, one employee might observe certain dietary restrictions for religious reasons while another employee adheres to the very same dietary restrictions but for secular ( e.g. , health or environmental) reasons. [30] In that instance, the same practice might in one case be subject to reasonable accommodation under Title VII because an employee engages in the practice for religious reasons, and in Theory Essay another case might not be subject to reasonable accommodation because the practice is engaged in for secular reasons. The following examples illustrate these concepts: Employment Decisions Based on “Religion” An otherwise qualified applicant is not hired because he is current marketing, a self-described evangelical Christian. A qualified non-Jewish employee is denied promotion because the supervisor wishes to give a preference based on religion to The Bronfenbrenner a fellow Jewish employee. Male Punishment! An employer terminates an employee based on his disclosure to the employer that he has recently converted to the Baha’i Faith. Each of these is an example of an employment decision based on the religious affiliation of the The Bronfenbrenner Essay applicant or employee, and therefore is based on “religion” within the meaning of Title VII.

Religious Practice versus Secular Practice. A Seventh-day Adventist employee follows a vegetarian diet because she believes it is religiously prescribed by the scriptural passage “[b]ut flesh with the life thereof, which is the blood thereof, shall ye not eat,” (Genesis 9:4). On Mango! Her vegetarianism is a religious practice, even though not all Seventh-day Adventists share this belief or follow this practice, and even though many individuals adhere to a vegetarian diet for The Bronfenbrenner Theory purely secular reasons. Types of Religious Practice or Observance. A Catholic employee requests a schedule change so that he can attend church services on Good Friday. Wall Clothing! A Muslim employee requests an exception to the company’s dress and grooming code allowing her to wear her headscarf, or a Hindu employee requests an exception allowing her to wear her bindi (religious forehead marking). An atheist asks to be excused from the The Bronfenbrenner Theory religious invocation offered at Organizational Clear Essay, the beginning of staff meetings. An adherent to Native American spiritual beliefs seeks unpaid leave to attend a ritual ceremony. An employee who identifies as Christian but is not affiliated with a particular sect or denomination requests accommodation of his religious belief that working on his Sabbath is The Bronfenbrenner Essay, prohibited.

Each of these accommodation requests relates to a “religious” belief or practice within the meaning of Title VII. By contrast, a request for a schedule change to help set up decorations or prepare food for a church event, for instance, typically does not involve a “religious” belief or practice within the meaning of black wall street, Title VII. [31] Supervisor Considers Belief Illogical. Morgana asks for time off on October 31 to The Bronfenbrenner Theory attend the “Samhain Sabbat,” the New Year observance of marketing, Wicca, her religion. Her supervisor refuses, saying that Wicca is not a “real” religion but an “illogical conglomeration” of “various aspects of the occult, such as faith healing, self?hypnosis, tarot card reading, and spell casting, which are not religious practices.” The supervisor’s refusal to Essay accommodate her on the ground that he believes her religion is marketing, illogical violates Title VII unless the employer can show her request would impose an undue hardship.

The law applies to religious beliefs even though others may find them “incorrect” or “incomprehensible.” [32] Unique Belief Can Be Religious. Edward practices the Kemetic religion, based on ancient Egyptian faith, and affiliates himself with a tribe numbering fewer than ten members.He states that he believes in various deities, and follows the faith’s concept of Ma’at, a guiding principle regarding truth and order that represents physical and Theory moral balance in male punishment the universe. The Bronfenbrenner Theory Essay! During a religious ceremony he received small tattoos encircling his wrist, written in the Coptic language, which express his servitude to of Alcoholism Essay examples Ra, the Egyptian god of the sun. When his employer asks him to cover the tattoos, he explains that it is a sin to cover them intentionally because doing so would signify a rejection of The Bronfenbrenner Essay, Ra. These can be religious beliefs and practices even if no one else or few other people subscribe to them. [33] Personal Preference That is Not a Religious Belief. Sylvia wears several tattoos and has recently had her nose and Organizational Clear Objectives eyebrows pierced. The Bronfenbrenner! A newly hired manager implements a dress code that requires that employees have no visible piercings or tattoos. Sylvia says that her tattoos and piercings are religious because they reflect her belief in The Concept of Alcoholism Essay examples body art as self-expression and should be accommodated.

However, the Theory evidence demonstrates that her tattoos and piercings are not related to any religious belief system. For example, they do not function as a symbol of any religious belief, and do not relate to street quotes any “ultimate concerns” such as life, purpose, death, humanity’s place in the universe, or right and wrong, and they are not part of Theory Essay, a moral or ethical belief system. Therefore, her belief is a personal preference that is not religious in nature. [34] Title VII requires employers to accommodate only those religious beliefs that are “sincerely held.” [35] Therefore, whether or not a religious belief is on How for Evil, “sincerely held” by an applicant or employee is The Bronfenbrenner Theory, only relevant to religious accommodation, not to claims of disparate treatment or harassment because of religion. In those claims, it is the motivation of the discriminating official, not the actual beliefs of the individual alleging discrimination, that are typically relevant in determining if the discrimination that occurred was because of religion. A detailed discussion of reasonable accommodation of sincerely held religious beliefs appears in marketing § IV, but the Theory meaning of “sincerely held” is addressed here. Like the the house on mango street “religious” nature of a belief or practice, the “sincerity” of an The Bronfenbrenner, employee’s stated religious belief is usually not in dispute. The Concept Of Alcoholism Essay! Nevertheless, there are some circumstances in which an employer may assert as a defense that it was not required to The Bronfenbrenner Theory Essay provide accommodation because the employee’s asserted religious belief was not sincerely held.

Factors that either alone or in combination might undermine an employee’s assertion that he sincerely holds the religious belief at issue include: whether the employee has behaved in a manner markedly inconsistent with the current professed belief; [36] whether the accommodation sought is a particularly desirable benefit that is The Bronfenbrenner Essay, likely to be sought for male punishment secular reasons; whether the timing of the request renders it suspect ( e.g. The Bronfenbrenner! , it follows an earlier request by the employee for the same benefit for secular reasons); and whether the employer otherwise has reason to believe the accommodation is not sought for black street religious reasons. However, none of these factors is Essay, dispositive. For example, although prior inconsistent conduct is relevant to the question of Organizational Clear Objectives, sincerity, an individual’s beliefs or degree of adherence may change over time, and therefore an employee’s newly adopted or inconsistently observed religious practice may nevertheless be sincerely held. [37] An employer also should not assume that an employee is insincere simply because some of his or her practices deviate from the commonly followed tenets of his or her religion. [38] 3. Employer Inquiries into Religious Nature or Sincerity of Belief. Because the definition of religion is broad and protects beliefs and practices with which the employer may be unfamiliar, the employer should ordinarily assume that an employee’s request for religious accommodation is based on a sincerely-held religious belief. The Bronfenbrenner! If, however, an current, employee requests religious accommodation, and an employer has an objective basis for questioning either the religious nature or the sincerity of a particular belief or practice, the Essay employer would be justified in seeking additional supporting information. See infra § IV-A-2. If the Respondent (R) disputes that the Charging Party’s (“CP’s”) belief is “religious,” consider the following: Begin with the male punishment CP’s statements. Essay! What religious belief or practice does the CP claim to have? In some cases, the CP’s credible testimony regarding his belief or practice will be sufficient to demonstrate that it is religious.

In other cases, however, the investigator may need to ask follow-up questions about the the house on mango nature and tenets of the asserted religious beliefs, and/or any associated practices, rituals, clergy, observances, etc., in order to identify a specific religious belief or practice or determine if one is at issue. Since religious beliefs can be unique to an individual, evidence from others is not always necessary. However, if the CP believes such evidence will support his or her claim, the investigator should seek evidence such as oral statements, affidavits, or other documents from CP’s religious leader(s) if applicable, or others whom CP identifies as knowledgeable regarding the The Bronfenbrenner Essay religious belief or practice in question. Remember, where an male punishment, alleged religious practice or belief is at issue, a case-by-case analysis is required. Investigators should not make assumptions about a religious practice or belief. In some cases, to determine whether CP’s asserted practice or belief is The Bronfenbrenner Theory Essay, “religious” as defined under Title VII, the male punishment investigator’s general knowledge will be insufficient, and additional objective information will have to Theory Essay be obtained, while nevertheless recognizing the intensely personal characteristics of adherence to a religious belief. If the current Respondent disputes that CP’s belief is “sincerely held,” the following evidence may be relevant:

Oral statements, an affidavit, or other documents from The Bronfenbrenner Theory CP describing his or her beliefs and practices, including information regarding when CP embraced the current marketing belief or practice, as well as when, where, and how CP has adhered to the belief or practice; and/or, Oral statements, affidavits, or other documents from potential witnesses identified by CP or R as having knowledge of Theory Essay, whether CP adheres or does not adhere to the belief or practice at issue ( e.g ., CP’s religious leader (if applicable), fellow adherents (if applicable), family, friends, neighbors, managers, or co-workers who may have observed his past adherence or lack thereof, or discussed it with him). Overview: Title VII jurisdictional rules apply to all religious discrimination claims under the statute. Essay On How Technology Is Used For Evil! However, specially-defined “religious organizations” and “religious educational institutions” are exempt from certain religious discrimination provisions, and a “ministerial exception” bars Title VII claims by employees who serve in clergy roles. Title VII’s prohibitions apply to employers, employment agencies, and unions, [39] subject to the statute’s jurisdictional requirements.

See EEOC Compliance Manual, “Threshold Issues,” https://www.eeoc.gov/policy/docs/threshold.html. Those covered entities must carry out their activities in The Bronfenbrenner Theory a nondiscriminatory manner and The Concept examples provide reasonable accommodation unless doing so would impose an Essay, undue hardship. [40] Unions also can be liable if they knowingly acquiesce in employment discrimination against their members, join or tolerate employers’ discriminatory practices, or discriminatorily refuse to represent employees’ interests. [41] Under Title VII, religious organizations are permitted to The Concept Essay examples give employment preference to members of their own religion. [42] The exception applies only to those institutions whose “purpose and character are primarily religious.” [43] That determination is to be based on The Bronfenbrenner, “[a]ll significant religious and secular characteristics.” [44] Although no one factor is on mango street quotes, dispositive, significant factors to consider that would indicate whether an entity is religious include: Do its articles of incorporation state a religious purpose? Are its day-to-day operations religious ( e.g. , are the services the entity performs, the product it produces, or the educational curriculum it provides directed toward propagation of the religion)? Is it not-for-profit? Is it affiliated with or supported by a church or other religious organization? [45] This exception is not limited to religious activities of the organization. [46] However, it only The Bronfenbrenner Theory, allows religious organizations to on mango street quotes prefer to employ individuals who share their religion. [47] The exception does not allow religious organizations otherwise to discriminate in employment on Essay, protected bases other than religion, such as race, color, national origin, sex, age, or disability. [48] Thus, a religious organization is not permitted to engage in racially discriminatory hiring by asserting that a tenet of wall clothing, its religious beliefs is not associating with people of other races. The Bronfenbrenner Essay! Similarly, a religious organization is not permitted to deny fringe benefits to married women but not to married men by asserting a religiously based view that only men can be the the house on mango quotes head of a household. Sex Discrimination Not Excused.

Justina works at Tots Day Care Center. Tots is run by Essay, a religious organization that believes that, while women may work outside of the home if they are single or have their husband’s permission, men should be the heads of current marketing, their households and Essay the primary providers for their families. Wall Street! Believing that men shoulder a greater financial responsibility than women, the The Bronfenbrenner Essay organization pays female teachers less than male teachers. The organization’s practice of The Concept of Alcoholism examples, unequal pay based on sex constitutes unlawful discrimination. The Bronfenbrenner Theory! [49] Courts have held, based on First Amendment constitutional considerations, that clergy members cannot bring claims under the federal employment discrimination laws, including Title VII, the Age Discrimination in Employment Act, the current marketing Equal Pay Act, and the Americans with Disabilities Act, because “[t]he relationship between an organized church and its ministers is its lifeblood.” [50] This “ministerial exception” comes not from the text of the statutes, but from the First Amendment principle that governmental regulation of church administration, including the appointment of clergy, impedes the free exercise of religion and The Bronfenbrenner constitutes impermissible government entanglement with church authority. [51] Thus, courts will not ordinarily consider whether a church’s employment decision concerning one of its ministers was based on the house on mango street quotes, discriminatory grounds, although some courts have allowed ministers to bring sexual harassment claims. [52] The ministerial exception applies only to those employees who perform essentially religious functions, namely those whose primary duties consist of engaging in church governance, supervising a religious order, or conducting religious ritual, worship, or instruction. [53] The exception is not limited to ordained clergy, [54] and has been applied by The Bronfenbrenner Theory, courts to others involved in clergy-like roles who conduct services or provide pastoral counseling. However, the is Used 1984 exception does not necessarily apply to everyone with a title typically conferred upon clergy ( e.g. , minister). The Bronfenbrenner Theory Essay! [55] In short, in each case it is necessary to make a factual determination of of Alcoholism, whether the The Bronfenbrenner Essay function of the position is current marketing, one to which the exception applies. Title VII’s prohibition against disparate treatment based on religion generally functions like its prohibition against disparate treatment based on race, color, sex, or national origin.

Disparate treatment violates the The Bronfenbrenner Theory statute whether motivated by bias against or preference toward an applicant or employee due to his religious beliefs, practices, or observances or lack thereof. Thus, for example, except to the extent permitted by the religious organization and ministerial exceptions, an employer may not refuse to recruit, hire, or promote individuals of a certain religion, may not impose stricter promotion requirements for Organizational Objectives persons of a certain religion, and may not impose more or different work requirements on Essay, an employee because of that employee’s religious beliefs or practices. [56] The following sub-sections address work scenarios that may lead to claims of religious discrimination. 1. Recruitment, Hiring, and Promotion. Employers that are not religious organizations may neither recruit individuals of a particular religion nor adopt recruitment practices, such as word-of-mouth recruitment, that have the purpose or effect of discriminating based on religion. Title VII permits employers that are not religious organizations to hire and marketing employ employees on the basis of religion only if religion is Essay, “a bona fide occupational qualification reasonably necessary to the normal operation of that particular business or enterprise.” [57]

For example, an employer may not refuse to hire an applicant simply because he does not share the employer’s religious beliefs, and conversely may not select one applicant over another based on a preference for employees of a particular religion. Black Street! [58] Similarly, employment agencies may not comply with requests from employers to engage in discriminatory recruitment or referral practices, for example by screening out applicants who have names often associated with a particular religion ( e.g., Mohammed). Moreover, an employer may not exclude an applicant from The Bronfenbrenner hire merely because he or she may need a reasonable accommodation that could be provided absent undue hardship. [59] Charles, the Clear Essay president of a company that owns several gas stations, needs managers for The Bronfenbrenner Essay the new convenience stores he has decided to add to the stations. He posts a job announcement at the Hindu Temple he attends and asks other members of the male punishment temple to refer only Hindu friends or family members who may be interested in the position. He does no other recruitment. By limiting his recruitment to Hindus, Charles is Theory Essay, engaging in unlawful discrimination. Mary is a human resources officer who is filling a vacant administrative position at her company. During the Essay on How Technology in George application process, she performs an Internet search on the candidates and learns that one applicant, Jonathan, has written an article for the local chapter of the Ethical Society setting forth his view that religion has been historically divisive and explaining why he subscribes to no religious beliefs or practices.

Although Mary believes he is the most qualified candidate, she does not hire him because she knows that many current company employees are observant Christians like her, and she believes they would be more comfortable working with someone like-minded. The Bronfenbrenner Theory Essay! By not hiring Jonathan because of his lack of religious identification, the company violated Title VII. Darpak, who practices Buddhism, holds a Ph.D. degree in engineering and applied for a managerial position at the research firm where he has worked for ten years. He was rejected in favor of a non-Buddhist candidate who was less qualified. On Mango Quotes! The company vice president who made the promotion decision advised Darpak that he was not selected because “we decided to go in a different direction.” However, the The Bronfenbrenner vice president confided to co-workers at a social function that he did not select Darpak because he thought a Christian manager could make better personal connections with the of Alcoholism firm’s clients, many of whom are Christian. The vice president’s statement, combined with the lack of any legitimate non-discriminatory reason for selecting the less qualified candidate, as well as the evidence that Darpak was the best qualified candidate for Theory the position, suggests that the proffered reason was a pretext for discrimination against Darpak because of his religious views. [60] Title VII also prohibits employers from disciplining or discharging employees because of Essay examples, their religion. [61] Joanne, a retail store clerk, is The Bronfenbrenner Essay, frequently 10-15 minutes late for her shift on several days per week when she attends Mass at Clear Objectives Essay, a Catholic Church across town. Her manager, Donald, has never disciplined her for this tardiness, and instead filled in for her at the cash register until she arrived, stating that he understood her situation. Theory! On the other hand, Yusef, a newly hired clerk who is Muslim, is disciplined by Donald for arriving 10 minutes late for his shift even though Donald knows it is due to his attendance at services at Essay Technology is Used, the local Mosque.

While Donald can require all similarly situated employees to be punctual, he is The Bronfenbrenner Essay, engaging in wall disparate treatment based on The Bronfenbrenner Essay, religion by disciplining only Yusef and not Joanne absent a legitimate nondiscriminatory reason for treating them differently. A charge alleging the above facts might also present a claim for denial of reasonable accommodation. While the employer may require employees to Clear be punctual, it may have to accommodate an employee who seeks leave or a schedule change to resolve the conflict between religious services and The Bronfenbrenner Theory Essay a work schedule, unless the accommodation would pose an undue hardship. Wall Street! [62] 3. Compensation and Other Terms, Conditions, or Privileges of Employment. Title VII prohibits discrimination on a protected basis “with respect to . . . compensation, terms, conditions, or privileges of The Bronfenbrenner Theory Essay, employment,” for example, setting or adjusting wages, granting benefits, and/or providing leave in a discriminatory fashion. [63] Wages and Benefits. Janet, who practices Native American spirituality, is a newly hired social worker for an agency. The Concept Essay! As a benefit to its employees, the agency provides tuition reimbursement for professional continuing education courses offered by The Bronfenbrenner Theory, selected providers. Janet applied for tuition reimbursement for an approved course that was within permitted cost limit. Wall Street! Janet’s supervisor denied her request for tuition reimbursement, stating that since Janet believes in “voodoo” she “won’t make a very good caseworker.” By refusing, because of Janet’s religious beliefs, to provide the tuition reimbursement to The Bronfenbrenner Theory which Janet was otherwise entitled as a benefit of her employment, Janet’s supervisor has discriminated against Essay on How Technology 1984, Janet on the basis of religion. Title VII’s prohibition on disparate treatment based on religious beliefs also can apply to disparate treatment of religious expression in the workplace. [64]

Eve is Theory, a secretary who displays a Bible on her desk at the house street quotes, work. Xavier, a secretary in the same workplace, begins displaying a Quran on his desk at work. Their supervisor allows Eve to retain the Bible but directs Xavier to The Bronfenbrenner put the Quran out of view because, he states, co-workers “will think you are making a political statement, and with everything going on on mango street quotes, in the world right now we don’t need that around here.” This differential treatment of similarly situated employees with respect to the display of a religious item at work constitutes disparate treatment based on The Bronfenbrenner Theory, religion in violation of male punishment, Title VII. [65] Charges involving religious expression may present claims not only of disparate treatment, but also of harassment and/or denial of reasonable accommodation. Investigation of claims of harassment and The Bronfenbrenner Theory denial of reasonable accommodation are addressed respectively in the house on mango quotes §§ III and IV of this document. As discussed in greater detail in those sections, Title VII requires employers to accommodate expression that is based on a sincerely held religious practice or belief, unless it threatens to constitute harassment or otherwise poses an undue hardship on the conduct of the business. Thus, for example, an employer can restrict religious expression where it would cause customers or co-workers reasonably to perceive the materials to express the The Bronfenbrenner employer’s own message, or where the item or message in question is harassing or otherwise disruptive. [66] For further discussion of how to Essay analyze when accommodation of religious expression would pose an undue hardship, refer to Theory Essay the sections on Harassment at § III-C and Accommodation at The Concept Essay examples, § IV-C-6. If an employer takes an action based on the discriminatory preferences of others, including co-workers or clients, the employer is unlawfully discriminating. Employment Decision Based on Customer Preference. Harinder, who wears a turban as part of his Sikh religion, is hired to The Bronfenbrenner Theory Essay work at the counter in a coffee shop. On How For Evil! A few weeks after Harinder begins working, the manager notices that the work crew from the construction site near the The Bronfenbrenner shop no longer comes in for Technology for Evil in George coffee in the mornings.

When he inquires, the crew complains that Harinder, whom they mistakenly believe is Theory Essay, Muslim, makes them uncomfortable in Organizational light of the September 11 th attacks. The manager tells Harinder that he has to let him go because the customers’ discomfort is understandable. The manager has subjected Harinder to unlawful religious discrimination by taking an adverse action based on customers’ preference not to have a cashier of Harinder’s perceived religion. Harinder’s termination based on customer preference would violate Title VII regardless of The Bronfenbrenner Theory, whether he was Muslim, Sikh, or any other religion. In general, an employer may adopt security requirements for its employees or applicants, provided they are adopted for nondiscriminatory reasons and are applied in a nondiscriminatory manner. For example, an employer may not require Muslim applicants to undergo a background investigation or more extensive security procedures because of the house on mango street quotes, their religion while not imposing the same requirements on similarly situated applicants who are non-Muslim, unless such job requirements are imposed by federal statute or Executive Order in Theory Essay the interest of national security. [67]

D. Black Street Clothing! Bona Fide Occupational Qualification. Title VII permits employers to hire and employ employees on the basis of religion if religion is “a bona fide occupational qualification [“BFOQ”] reasonably necessary to the normal operation of that particular business or enterprise.” [68] Religious organizations do not typically need to Essay rely on this BFOQ defense, however, because the “religious organization” exception in Title VII permits them to on mango street quotes prefer their co-religionists. See supra § I-C. The Bronfenbrenner Theory! It is well settled that for employers that are not religious organizations and The Concept therefore seek to rely on the BFOQ defense to justify a religious preference, the The Bronfenbrenner Essay defense is marketing, a narrow one and can rarely be successfully invoked. [69] Employers can reduce the risk of discriminatory employment decisions by Theory Essay, establishing written objective criteria for evaluating candidates for hire or promotion and applying those criteria consistently to all candidates. In conducting job interviews, employers can ensure nondiscriminatory treatment by current marketing, asking the same questions of all applicants for Theory a particular job or category of job and inquiring about matters directly related to the position in question. Employers can reduce the the house street risk of The Bronfenbrenner Theory, religious discrimination claims by carefully and timely recording the accurate business reasons for disciplinary or performance?related actions and sharing these reasons with the affected employees. When management decisions require the on How Technology is Used Orwell’s exercise of subjective judgment, employers can reduce the risk of Theory, discriminatory decisions by providing training to inexperienced managers and current encouraging them to consult with more experienced managers or human resources personnel when addressing difficult issues.

If an employer is confronted with customer biases, e.g., an adverse reaction to being served by an employee due to Essay religious garb, the employer should consider engaging with and educating the customers regarding any misperceptions they may have and/or the equal employment opportunity laws. Overview: Religious harassment is analyzed and proved in the same manner as harassment on on How is Used Orwell’s 1984, other Title VII bases, e.g., race, color, sex, or national origin. [70] However, the facts of religious harassment cases may present unique considerations, especially where the alleged harassment is based on another employee’s religious practices a situation that may require an Essay, employer to reconcile its dual obligations to take prompt remedial action in response to alleged harassment and to accommodate certain employee religious expression. Religious harassment in violation of Title VII occurs when employees are: (1) required or coerced to Technology for Evil in George Orwell’s abandon, alter, or adopt a religious practice as a condition of employment (this type of Theory Essay, “quid pro quo” harassment may also give rise to a disparate treatment or denial of accommodation claim in of Alcoholism Essay examples some circumstances), [71] or (2) subjected to unwelcome statements or conduct that is based on religion and The Bronfenbrenner Theory is so severe or pervasive that the individual being harassed reasonably finds the work environment to be hostile or abusive, and there is a basis for current holding the employer liable. [72] 1. Religious Coercion That Constitutes a Tangible Employment Action. Title VII is violated when an employer or supervisor explicitly or implicitly coerces an Essay, employee to abandon, alter, or adopt a religious practice as a condition of receiving a job benefit or avoiding an adverse action. [73] Religious Conformance Required for Promotion. Wamiq was raised as a Muslim but no longer practices Islam. His supervisor, Arif, is wall street clothing, a very devout Muslim who tries to persuade Wamiq not to abandon Islam and The Bronfenbrenner Essay advises him to follow the teachings of the Quran. Arif also says that if Wamiq expects to advance in on mango street quotes the company, he should join Arif and other Muslims for Theory Essay weekly prayer sessions in current Arif’s office. Notwithstanding this pressure to conform his religious practices in order to be promoted, Wamiq refused to attend the The Bronfenbrenner Theory weekly prayer sessions, and the house on mango street quotes was subsequently denied the promotion for which he applies even though he was the most qualified. Arif’s conduct indicates that the The Bronfenbrenner Theory Essay promotion would have been granted if Wamiq had participated in the prayer sessions and had become an observant Muslim.

Absent contrary evidence, the employer will be liable for harassment for conditioning Wamiq’s promotion on his adherence to Arif’s views of male punishment, appropriate religious practice. [74] This would also be actionable as disparate treatment based on religion. In addition, if the prayer sessions were made mandatory and Wamiq had asked to be excused on religious grounds, Arif would have been required to excuse him from the prayer sessions as a reasonable accommodation. A claim of harassment based on Essay, coerced religious participation or non-participation, however, only arises where it was intended to make the employee conform to or abandon a religious belief or practice. By contrast, an employer would not be engaging in coercion if it required an employee to participate in on mango a workplace activity that conflicts with the employee’s sincerely held religious belief, so long as the employer demonstrates that it would impose an The Bronfenbrenner Theory, undue hardship to accommodate the current marketing employee’s request to be excused. However, the same fact pattern may give rise to claims of disparate treatment, harassment, and/or denial of The Bronfenbrenner Theory, accommodation. For example, terminating rather than accommodating an employee may give rise to both denial of examples, accommodation and discriminatory discharge claims. [75] For discussion of the Theory Essay accommodation issue, see § IV, infra .[76] Title VII’s prohibition against religious discrimination can also be violated if the employee is subjected to a hostile work environment because of religion. [77] An unlawful hostile environment based on religion might take the street form of either verbal or physical harassment or unwelcome imposition of religious views or practices on an employee. A hostile work environment is The Bronfenbrenner Theory, created when the marketing “workplace is permeated with discriminatory intimidation, ridicule, and insult that is sufficiently severe or pervasive to alter the conditions of the victim’s employment and create an The Bronfenbrenner Theory Essay, abusive working environment.” [78] To establish a case of religious harassment, an employee must show that the current harassment was: (1) based on his religion; (2) unwelcome; (3) sufficiently severe or pervasive to alter the The Bronfenbrenner Theory Essay conditions of Essay on How for Evil Orwell’s 1984, employment by creating an intimidating, hostile, or offensive work environment; and, (4) that there is a basis for employer liability. The Bronfenbrenner Essay! [79] To support a religious harassment claim, the adverse treatment must be based on male punishment, religion. Theory Essay! [80] This standard can be satisfied regardless of whether the harassment is motivated by the religious belief or observance or lack thereof of on How is Used Orwell’s 1984, either the harasser or the targeted employee.

Moreover, while verbally harassing conduct clearly is based on Theory Essay, religion if it has religious content, harassment can also be based on religion even if religion is not explicitly mentioned. [81] Harassing Conduct Based on Religion Religion Mentioned. Mohammed is an Indian-born Muslim employed at a car dealership. Because he takes scheduled prayer breaks during the work day and observes Muslim dietary restrictions, his co-workers are aware of his religious beliefs. Upset about the the house on mango street quotes 9/11 terrorist attacks, his co-workers and managers began making mocking comments about his religious dietary restrictions and need to pray during the Theory workday. They repeatedly referred to him as “Taliban” or “Arab” and male punishment asked him “why don’t you just go back where you came from Theory since you believe what you believe?” When Mohammed questioned why it was mandatory for all employees to attend a United Way meeting, his supervisor said: “This is America.

That’s the current marketing way things work over here. Theory Essay! This is current, not the Islamic country where you come from.” After this confrontation, the supervisor issued Mohammed a written warning stating that he “was acting like a Muslim extremist” and that the supervisor could not work with him because of The Bronfenbrenner Theory, his “militant stance.” This harassment is male punishment, “based on” religion and national origin. [82] Harassing Conduct Based on Essay, Religion Religion Not Mentioned. Shoshanna is a Seventh-day Adventist whose work schedule was adjusted to accommodate her Sabbath observance, which begins at on How Technology for Evil in George Orwell’s, sundown each Friday. When Nicholas , the new head of Shoshanna’s department, was informed that he must accommodate her, he told a colleague that “anybody who cannot work regular hours should work elsewhere.” Nicholas then moved the regular Monday morning staff meetings to late Friday afternoon, repeatedly scheduled staff and client meetings on Theory Essay, Friday afternoons, and often marked Shoshanna AWOL when she was not scheduled to work.

In addition, Nicholas treated her differently than her colleagues by, for example, denying her training opportunities and loudly berating her with little or no provocation. Although Nicholas did not mention Shoshanna’s religion, the evidence shows that his conduct was because of Shoshanna’s need for religious accommodation, and therefore was “based on” religion. [83] To be unlawful, harassing conduct must be unwelcome. Essay! Conduct is Essay, “unwelcome” when the employee did not solicit or incite it and current marketing regards it as undesirable or offensive. [84] It is necessary to evaluate all of the surrounding circumstances to determine whether or not particular conduct or remarks are unwelcome. Theory! [85] For example, where an employee is upset by repeated mocking use of derogatory terms or comments [86] about his religious beliefs or observance by a colleague, it may be evident that the conduct is unwelcome. This would stand in male punishment stark contrast to a situation where the same two employees were engaged in The Bronfenbrenner a consensual conversation that involves a spirited debate of religious views, and neither employee indicates that he was upset by it. The distinction between welcome and unwelcome conduct is especially important in the religious context in situations involving proselytizing of employees who have not invited such conduct. The House! [87] Where a religious employee attempts to The Bronfenbrenner Essay persuade a non-religious employee of the correctness of his belief, or vice versa, the conduct may or may not be welcome. When an Organizational Clear, employee objects to The Bronfenbrenner Theory particular religious expression, unwelcomeness is evident. [88] Beth’s colleague, Bill, repeatedly talked to her at work about her prospects for salvation. On How Technology Is Used For Evil In George 1984! For several months, she did not object and discussed the The Bronfenbrenner Essay matter with him. When he persisted even after she told him that he had “crossed the line” and should stop having non-work related conversations with her, the conduct was clearly unwelcome. [89] Even unwelcome religiously motivated conduct is not unlawful unless “the victim . . Essay Examples! . subjectively perceive[s] the environment to be abusive” and the conduct is The Bronfenbrenner, “severe or pervasive enough to create an objectively hostile or abusive work environment -- an environment that a reasonable person would find hostile or abusive.” [90] Whether a reasonable person would perceive the conduct as abusive turns on common sense and context, looking at the totality of the circumstances. [91] Relevant factors include whether the conduct was abusive, derogatory, or offensive; [92] whether the The Concept of Alcoholism Essay conduct was frequent; [93] and whether the Theory conduct was humiliating or physically threatening. [94]

Reasonable Person Perceives Conduct To Be Hostile. Although he hired employees of all religions, the Director of “Get Drug Free Today” required employees to black clothing sign a statement that they would support the values of the Church of Scientology. He regularly chastised those whose conduct did not conform to those values. A reasonable person would perceive this to be a religiously hostile work environment. [95] To “alter the conditions of employment,” conduct need not cause economic or psychological harm. [96] It need not impair work performance, discourage employees from remaining on The Bronfenbrenner Essay, the job, or impede their advancement. [97] The presence of current, one or more of those factors would buttress the claim, but is not required. [98] However, Title VII is not a general civility code, and does not render all insensitive or offensive comments, petty slights, and annoyances illegal. [99] Offhand or isolated incidents (unless extremely serious) will not rise to the level of illegality. [100] Insensitive Comments Not Enough To Constitute Hostile Environment. Marvin is an The Bronfenbrenner Theory, Orthodox Jew who was hired as a radio show host. Male Punishment! When he started work, a co-worker, Stacy, pointed to his yarmulke and The Bronfenbrenner asked, “Will your headset fit over wall street clothing that?” On a few occasions, Stacy, made other remarks about the yarmulke, such as: “Nice hat. Is that a beanie?” and “Do they come in different colors?” Although the co-worker’s comments about his yarmulke were insensitive, they were not sufficiently severe or pervasive to create a hostile work environment for Marvin. Essay! [101] Isolated Comments Not Enough to Constitute Hostile Environment.

Bob, a supervisor, occasionally allowed spontaneous and voluntary prayers by the house street quotes, employees during office meetings. During one meeting, he referenced Bible passages related to “slothfulness” and “work ethics.” Amy complained that Bob’s comments and the few instances of allowing voluntary prayers during office meetings created a hostile environment. The Bronfenbrenner Theory Essay! The comments do not create an actionable harassment claim. They were not severe, and because they occurred infrequently, they were not sufficiently pervasive to state a claim. [102] The severity and pervasiveness factors operate inversely. The more severe the harassment, the less frequently the incidents need to recur. At the wall street clothing same time, incidents that may not, individually, be severe may become unlawful if they occur frequently or in close proximity. [103] Although a single incident will seldom create an unlawfully hostile environment, it may do so if it is unusually severe, particularly if it involves physical threat. [104] One Instance of Physically Threatening Conduct Is Enough to Theory Essay Constitute Hostile Environment. Ihsaan is a Muslim.

Shortly after the terrorist attacks on September 11, 2001, Ihsaan came to work and found the The Concept of Alcoholism Essay words “You terrorists go back where you came from! We will avenge the victims!! Your life is next!” scrawled in red marker on his office door. Because of the The Bronfenbrenner Essay timing of the statement and the direct physical threat, this incident, alone, is sufficiently severe to constitute hostile environment harassment based on male punishment, religion and national origin. [105] Persistent Offensive Remarks Constitute Hostile Environment. Betty is The Bronfenbrenner Theory, a Mormon. During a disagreement regarding a joint project, a co-worker, Julian, tells Betty that she doesn’t know what she is talking about and Organizational Clear that she should “go back to The Bronfenbrenner Theory Essay Salt Lake City.” When Betty subsequently proposes a different approach to the project, Julian tells her that her suggestions are as “flaky” as he would expect from is Used for Evil Orwell’s 1984 “her kind.” When Betty tries to resolve the conflict, Julian tells her that if she is uncomfortable working with him, she can either ask to be transferred, or she can “just pray about it.” Over the next six months, Julian regularly makes similar negative references to Betty’s religion. The Bronfenbrenner Theory! His persistent offensive remarks create a hostile environment. Religious expression that is repeatedly directed at an employee can become severe or pervasive, whether or not the content is intended to be insulting or abusive. Thus, for example, persistently reiterating atheist views to a religious employee who has asked that it stop can create a hostile environment. However, the extent to which the expression is Organizational Clear Essay, directed at a particular employee is relevant to determining whether or when it could reasonably be perceived to be severe or pervasive by that employee. [106] For example, although it is conceivable that one employee may allege that he is Theory Essay, offended by a colleague’s wearing of religious garb, expressing one’s religion by current, wearing religious garb is not religious harassment.

It merely expresses an The Bronfenbrenner Theory, individual’s religious affiliation and does not demean other religious views. As such, it is not objectively hostile. Of Alcoholism Essay Examples! Nor is it directed at any particular individual. Similarly, workplace displays of religious artifacts or posters that do not demean other religious views generally would not constitute religious harassment. No Hostile Environment from Comments That Are Not Abusive and Not Directed at Complaining Employee. While eating lunch in the company cafeteria, Clarence often overhears conversations between his co-workers Dharma and Khema. Dharma, a Buddhist, is discussing meditation techniques with Khema, who is interested in Essay Buddhism. Clarence strongly believes that meditation is an occult practice that leads to devil worship and complains to their supervisor that Dharma and Essay Technology is Used Orwell’s Khema are creating a hostile environment for him.

Such conversations do not constitute severe or pervasive religious harassment of Clarence because they do not insult other religions and they were not directed at him. Overview: An employer is always liable for a supervisor’s harassment if it results in a tangible employment action. The Bronfenbrenner! However, if it does not, the employer may be able to avoid liability or limit damages by establishing an Clear Essay, affirmative defense that includes two necessary elements: (a) the employer exercised reasonable care to prevent and correct promptly any harassing behavior, and The Bronfenbrenner (b) the employee unreasonably failed to take advantage of any preventive or corrective opportunities provided by the employer or to avoid harm otherwise. In cases of harassment by a co-worker or a third party over whom the employer had some control, an employer is liable if it knew or should have known about the harassment and failed to take immediate and appropriate corrective action. 1. Harassment by Supervisors or Managers. Employers are automatically liable for supervisory harassment that results in a tangible employment action such as a denial of promotion, demotion, discharge, or constructive discharge. If the harassment does not result in the house street a tangible employment action, the employer can attempt to prove, as an affirmative defense to liability, that: (1) the employer exercised reasonable care to prevent and promptly correct any harassing behavior, and (2) the The Bronfenbrenner employee unreasonably failed to take advantage of any preventive or corrective opportunities provided by the employer or to otherwise avoid harm. [107] Supervisory Harassment with Tangible Employment Action. George, a high level official in a state agency, is an atheist who has frequently been heard to on How say that he thinks anyone who is deeply religious is a zealot with his own agenda and cannot be trusted to act in the best interests of the public.

George particularly ridicules Debra, a devoutly observant Jehovah’s Witness, and consistently withholds the most desirable assignments from her. He denies her request for a promotion to a more prestigious job in another division, saying that he can’t let her “spread that religious poppycock any further.” Debra files a religious harassment charge. Respondent asserts in its position statement that it is not liable because Debra never made a complaint under its internal anti-harassment policy and complaint procedures. Because the harassment culminated in a tangible employment action (failure to promote), the employer is liable for the harassment even if it has an The Bronfenbrenner Essay, effective anti-harassment policy, and even if Debra never complained. Current Marketing! Additionally, the denial of promotion would be actionable as disparate treatment based on religion. Supervisory Harassment Without Tangible Employment Action. Jennifer’s employer, XYZ, had an anti-harassment policy and complaint procedure that covered religious harassment.

All employees were aware of it, because XYZ widely and The Bronfenbrenner Theory Essay regularly publicized it. Despite his knowledge of the policy, Jennifer’s supervisor frequently mocked her religious beliefs. When Jennifer told him that his comments bothered her, he told her that he was just kidding and she should not take everything so seriously. Jennifer never reported the Organizational Clear problem. When one of Jennifer’s co-workers eventually reported the supervisor’s harassing conduct, the employer promptly investigated, and The Bronfenbrenner Essay acted effectively to Objectives stop the Theory Essay supervisor’s conduct. Jennifer then filed a religious harassment charge. Because the harassment of of Alcoholism examples, Jennifer did not culminate in a tangible employment action, XYZ may assert as an The Bronfenbrenner, affirmative defense that it is not liable because Jennifer failed to make a complaint under its internal anti-harassment policy and complaint procedures. On these facts, XYZ will not be liable for the harassment because Jennifer unreasonably failed to utilize XYZ’s available, effective complaint mechanisms, and because XYZ took prompt and The Concept of Alcoholism reasonable corrective measures once it did learn of the Theory harassment. An employer is clothing, liable for The Bronfenbrenner Theory harassment by co-workers where it: knew or should have known about the harassment, and failed to take prompt and appropriate corrective action. [108] Harassment by Co-Workers.

John, who is a Christian Scientist, shares an office with Rick, a Mormon. Rick repeatedly tells John that he is practicing a false religion, and that he should study Mormon literature. Despite John’s protestations that he is very happy with his religion and has no desire to convert, Rick regularly leaves religious pamphlets on on How for Evil in George Orwell’s 1984, John’s desk and tries to Essay talk to him about religion. Wall Street Clothing! After vainly asking Rick to stop the behavior, John complains to their immediate supervisor, who dismisses John’s complaint on the ground that Rick is a nice person who believes that he is just being helpful. If the harassment continues, the employer is liable because it knew, through the supervisor, about Rick’s harassing conduct but failed to take immediate and appropriate corrective action. [109] An employer is liable for The Bronfenbrenner Theory Essay harassment by non-employees where it: knew or should have known about the harassment, could control the harasser’s conduct or otherwise protect the employee, and failed to take prompt and appropriate corrective action. Essay On How Technology Is Used For Evil In George Orwell’s 1984! [110] Harassment by a Contractor. Tristan works for XYZ, a contractor that manages Crossroads Corporation’s mail room. Essay! When Tristan delivers the mail to Julia, the Crossroads receptionist, he gives her religious tracts, attempts to Essay examples convert her to his religion, and Essay persists even after she tells him to stop. Organizational Objectives Essay! Julia reports Tristan’s conduct to her supervisor, who tells her that he cannot do anything because Tristan does not work for Crossroads. If the harassment continues, the supervisor’s failure to act will subject Crossroads to liability because Tristan’s conduct is pervasive and Crossroads refused to take preventive action within its control.

Options available to The Bronfenbrenner Essay Julia’s supervisor or the appropriate individual in the supervisor’s chain of command might include initiating a meeting with Tristan and XYZ management regarding the Technology for Evil in George Orwell’s 1984 harassment and The Bronfenbrenner Theory Essay demanding that it cease, that appropriate disciplinary action be taken if it continues, and/or that a different mail carrier be assigned to Julia’s route. C. Special Considerations for Orwell’s Employers When Balancing Anti-Harassment and Accommodation Obligations With Respect to Religious Expression. While some employees believe that religion is intensely personal and private, others are open about their religion. The Bronfenbrenner Theory Essay! [111] There are employees who may believe that they have a religious obligation to share their views and to try to street quotes persuade co-workers of the truth of their religious beliefs, i.e. , to proselytize. Some employers, too, may wish to express their religious views and share their religion with their employees. [112] As noted above, however, some employees may perceive proselytizing or other religious expression as unwelcome harassment based on their own religious beliefs and observances, or lack thereof. This mix of Theory Essay, divergent beliefs and practices can give rise to conflicts requiring employers to balance the rights of employees who wish to express their religious beliefs with the rights of other employees to be free from street religious harassment under the foregoing Title VII harassment standards. [113] As discussed in more detail in § IV-C-6 of this document, an employer never has to accommodate expression of a religious belief in the workplace where such an accommodation could potentially constitute harassment of co-workers, because that would pose an undue hardship for the employer. Therefore, while Title VII requires employers to accommodate an employee’s sincerely held religious belief in engaging in religious expression ( e.g. , proselytizing) in the workplace, an employer does not have to allow such expression if it imposes an The Bronfenbrenner Theory Essay, undue hardship on the operation of the business. For example, it would be an undue hardship for an employer to accommodate proselytizing by an employee if it constituted potentially unlawful religious harassment of a co-worker who found it unwelcome, or if it otherwise interfered with the operation of the business. [114] Because employers are responsible for maintaining a nondiscriminatory work environment, they are liable for Essay Technology is Used in George Orwell’s 1984 perpetrating or tolerating religious harassment of their employees. An employer can reduce the chance that employees will engage in conduct that rises to The Bronfenbrenner Theory Essay the level of unlawful harassment by implementing an anti-harassment policy and an effective procedure for reporting, investigating, and correcting harassing conduct. [115] Even if the policy does not prevent all such conduct, it will likely limit the employer’s liability where the wall clothing affected employee allows the conduct to rise to the level of illegality by failing to report it. However, Title VII violations may result if an employer tries to avoid potential co-worker objections to employee religious expression by preemptively banning all religious communications in the workplace, since Title VII requires that employees’ sincerely held religious practices and beliefs be accommodated as long as no undue hardship is Theory, posed.

Employers should have a well-publicized and consistently applied anti-harassment policy that: (1) covers religious harassment; (2) clearly explains what is current, prohibited; (3) describes procedures for The Bronfenbrenner Theory Essay bringing harassment to management’s attention; and, (4) contains an assurance that complainants will be protected against retaliation. The procedures should include a complaint mechanism that includes multiple avenues for complaint; prompt, thorough, and impartial investigations; and prompt and appropriate corrective action. Employers should allow religious expression among employees to the same extent that they allow other types of personal expression that are not harassing or disruptive. Once an employer is on notice that an employee objects to religious conduct that is directed at him or her, the employer should take steps to end the conduct because even conduct that the employer does not regard as abusive can become sufficiently severe or pervasive to affect the current conditions of The Bronfenbrenner Essay, employment if allowed to persist in the face of the employee’s objection. If harassment is perpetrated by a non-employee assigned by a contractor, the supervisor or other appropriate individual in the chain of command should initiate a meeting with the contractor regarding the harassment and demand that it cease, that appropriate disciplinary action be taken if it continues, and/or that a different individual be assigned by the contractor.

To prevent conflicts from escalating to the level of a Title VII violation, employers should immediately intervene when they become aware of objectively abusive or insulting conduct, even absent a complaint. Employers should encourage managers to intervene proactively and discuss with subordinates whether particular religious expression is welcome if the manager believes the Organizational Clear Essay expression might be construed as harassing to a reasonable person. While supervisors are permitted to The Bronfenbrenner engage in certain religious expression, they should avoid expression that might due to their supervisory authority reasonably be perceived by Clear, subordinates as coercive, even when not so intended. Employees who are the recipients of unwelcome religious conduct should inform the The Bronfenbrenner Theory individual engaging in the conduct that they wish it to stop. If the conduct does not stop, employees should report it to their supervisor or other appropriate company official in accordance with the procedures established in the company’s anti-harassment policy. Employees who do not wish to personally confront an individual who is directing unwelcome religious or anti-religious conduct towards them should report the conduct to their supervisor or other appropriate company official in accordance with the company’s anti-harassment policy. Overview: Title VII requires an employer, once on notice, to wall reasonably accommodate an employee whose sincerely held religious belief, practice, or observance conflicts with a work requirement, unless providing the accommodation would create an undue hardship. [116] However, the The Bronfenbrenner Theory Essay Title VII “undue hardship” defense is defined very differently than the “undue hardship” defense for marketing disability accommodation under the Essay Americans with Disabilities Act (ADA). Under Title VII, the Clear Objectives undue hardship defense to providing religious accommodation requires a showing that the proposed accommodation in Theory a particular case poses a “more than de minimis” cost or burden, which is Objectives, a far lower standard for an employer to meet than undue hardship under the ADA, which is defined in that statute as “significant difficulty or expense.” [117] A religious accommodation claim is The Bronfenbrenner, distinct from Organizational Objectives Essay a disparate treatment claim, in which the question is whether employees are treated equally. An individual alleging denial of The Bronfenbrenner Theory Essay, religious accommodation is seeking an adjustment to a neutral work rule that infringes on the employee’s ability to practice his religion. The accommodation requirement is of Alcoholism examples, “plainly intended to relieve individuals of the burden of choosing between their jobs and their religious convictions, where such relief will not unduly burden others.” [118]

A reasonable religious accommodation is Theory, any adjustment to the work environment that will allow the employee to comply with his or her religious beliefs. Street! However, it is The Bronfenbrenner Theory, subject to Essay the limit of Theory Essay, more than de minimis cost or burden. The need for religious accommodation most frequently arises where an individual’s religious beliefs, observances, or practices conflict with a specific task or requirement of the job or the application process. The employer’s duty to on How in George Orwell’s accommodate will usually entail making a special exception from, or adjustment to, the particular requirement so that the The Bronfenbrenner Theory Essay employee or applicant will be able to male punishment practice his or her religion. Accommodation requests often relate to work schedules, dress and grooming, or religious expression or practice while at work. 1. Notice of the The Bronfenbrenner Essay Conflict Between Religion and Work.

An applicant or employee who seeks religious accommodation must make the employer aware both of the need for accommodation and that it is being requested due to a conflict between religion and work. Clothing! The employee is obligated to explain the religious nature of the belief or practice at Theory Essay, issue, and cannot assume that the employer will already know or understand it. Current! [119] Similarly, the employer should not assume that a request is invalid simply because it is based on The Bronfenbrenner, religious beliefs or practices with which the employer is unfamiliar, but should ask the employee to explain the religious nature of the practice and the way in which it conflicts with a work requirement. No “magic words” are required to place an employer on notice of an applicant’s or employee’s conflict between religious needs and a work requirement. Marketing! To request an Theory Essay, accommodation, an individual may use plain language and on mango street need not mention any particular terms such as “Title VII” or “religious accommodation.” However, the applicant or employee must provide enough information to Theory make the employer aware that there exists a conflict between the individual’s religious practice or belief and Objectives Essay a requirement for applying for or performing the job. Essay! [120] Failure to Advise Employer That Request Is Due to Religious Practice or Belief. Jim agreed to take his employer’s drug test but was terminated because he refused to sign the Clear Essay accompanying consent form.

After his termination, Jim filed a charge alleging that the Theory employer failed to accommodate his religious objection to Organizational Clear Objectives swearing an Essay, oath. Marketing! Until it received notice of the charge, the employer did not know that Jim’s refusal to sign the form was based on his religious beliefs. Because the The Bronfenbrenner employer was not notified of the Organizational Objectives conflict at the time Jim refused to sign the form, or at any time prior to Jim’s termination, it did not have an opportunity to offer to accommodate him. The employer has not violated Title VII. [121] While an employer is not required by Title VII to conduct a discussion with an employee before denying the Essay employee’s accommodation request, as a practical matter it can be important to do so. Marketing! Both the employer and the employee have roles to The Bronfenbrenner Theory play in of Alcoholism resolving an accommodation request. Theory! In addition to placing the male punishment employer on notice of the The Bronfenbrenner Theory Essay need for accommodation, the Clear employee should cooperate with the employer’s efforts to determine whether a reasonable accommodation can be granted.

Once the employer becomes aware of the employee’s religious conflict, the employer should obtain promptly whatever additional information is The Bronfenbrenner, needed to current determine whether an accommodation is The Bronfenbrenner Theory Essay, available that would eliminate the religious conflict without posing an undue hardship on the operation of the employer’s business. [122] This typically involves the employer and employee mutually sharing information necessary to process the accommodation request. Employer?employee cooperation and flexibility are key to the search for a reasonable accommodation. If the marketing accommodation solution is not immediately apparent, the employer should discuss the request with the employee to The Bronfenbrenner determine what accommodations might be effective. If the male punishment employer requests additional information reasonably needed to evaluate the request, the employee should provide it. Failure to confer with the employee is Theory Essay, not an Objectives, independent violation of Title VII but, as a practical matter, such failure can have adverse legal consequences for Theory Essay both an on mango quotes, employee and an employer. For example, in some cases where an The Bronfenbrenner Theory Essay, employer has made no effort to act on an accommodation request, courts have found that the employer lacked the Essay Technology for Evil Orwell’s 1984 evidence needed to meet its burden of Theory Essay, proof to establish that the plaintiff’s proposed accommodation would actually have posed an undue hardship. Organizational! [123] Likewise, courts have ruled against employees who refused to cooperate with an employer’s requests for The Bronfenbrenner reasonable information when, as a result, the employer was deprived of the information necessary to resolve the accommodation request. For example, if an employee requested a schedule change to examples accommodate daily prayers, the employer might need to ask for Theory Essay information about the religious observance, such as time and duration of the daily prayers, in order to determine if accommodation can be granted without posing an undue hardship on the operation of the employer’s business. [124] Moreover, even if the Essay Technology for Evil in George 1984 employer does not grant the employee’s preferred accommodation but instead provides an alternative accommodation, the employee must cooperate by attempting to meet his religious needs through the employer’s proposed accommodation if possible. [125] Where the accommodation request itself does not provide enough information to enable the The Bronfenbrenner employer to Clear Essay make a determination, and the employer has a bona fide doubt as to the basis for the accommodation request, it is entitled to Essay make a limited inquiry into the facts and black wall circumstances of the employee’s claim that the belief or practice at issue is religious and sincerely held, and Theory that the belief or practice gives rise to the need for the accommodation. See “Sincerely Held” and “Employer Inquiries into Religious Nature or Sincerity of Belief,” supra §§ I-A-2 and examples I-A-3. [126] Whether an employer has a reasonable basis for The Bronfenbrenner seeking to verify the The Concept of Alcoholism Essay examples employee’s stated beliefs will depend on The Bronfenbrenner, the facts of a particular case.

Sincerity of Religious Belief Questioned. Bob, who had been a dues-paying member of the wall street CDF union for fourteen years, had a work-related dispute with a union official and one week later asserted that union activities were contrary to Theory Essay his religion and Organizational Essay that he could no longer pay union dues. The union doubted whether Bob’s request was based on a sincerely held religious belief, given that it appeared to The Bronfenbrenner Essay be precipitated by an unrelated dispute with the the house on mango quotes union, and he had not sought this accommodation in his prior fourteen years of employment. In this situation, the The Bronfenbrenner Essay union can require him to provide additional information to support his assertion that he sincerely holds a religious conviction that precludes him from belonging to or financially supporting a union. [127] When an employer requests additional information, employees should provide information that addresses the employer’s reasonable doubts. That information need not, however, take any specific form. For example, written materials or the employee’s own first-hand explanation may be sufficient to alleviate the The Concept Essay employer’s doubts about the sincerity or religious nature of the Theory Essay employee’s professed belief such that third-party verification is unnecessary. Further, since idiosyncratic beliefs can be sincerely held and religious, even when third-party verification is needed, it does not have to come from a church official or member, but rather could be provided by others who are aware of the employee’s religious practice or belief. [128] An employee who fails to Essay on How Technology is Used for Evil in George Orwell’s 1984 cooperate with an employer’s reasonable request for Theory Essay verification of the sincerity or religious nature of a professed belief risks losing any subsequent claim that the employer improperly denied an accommodation. By the same token, employers who unreasonably request unnecessary or excessive corroborating evidence risk being held liable for denying a reasonable accommodation request, and having their actions challenged as retaliatory or as part of a pattern of harassment.

It also is quotes, important to remember that even if an The Bronfenbrenner Theory Essay, employer concludes that an individual’s professed belief is black wall street clothing, sincerely held and religious, it is The Bronfenbrenner Essay, only required to grant those requests for accommodation that do not pose an undue hardship on the conduct of marketing, its business. Clarifying a Request. Diane requests that her employer schedule her for The Bronfenbrenner “fewer hours” so that she can “attend church more frequently.” The employer denies the request because it is not clear what schedule Diane is requesting or whether the change is sought due to black street clothing a religious belief or practice. While Diane’s request lacked sufficient detail for the employer to make a final decision, it was sufficient to constitute a religious accommodation request. The Bronfenbrenner Theory Essay! Rather than denying the request outright, the employer should have obtained the information from Diane that it needed to make a decision. The employer could have inquired of Diane precisely what schedule change was sought and for what purpose, and how her current schedule conflicted with her religious practices or beliefs. Diane would then have had an obligation to provide sufficient information to permit her employer to make a reasonable assessment of whether her request was based on a sincerely held religious belief, the precise conflict that existed between her work schedule and church schedule, and whether granting the accommodation would pose more than a de minimis burden on the employer’s business. 3. What is a “Reasonable” Accommodation?

Although an employer never has to provide an accommodation that would pose an undue hardship, see infra § IV-B, the accommodation that is provided must be a reasonable one. An accommodation is not “reasonable” if it merely lessens rather than eliminates the conflict between religion and Essay is Used for Evil work, provided eliminating the The Bronfenbrenner Essay conflict would not impose an undue hardship. [129] Eliminating the wall conflict between a work rule and The Bronfenbrenner Theory Essay an employee’s religious belief, practice, or observance means accommodating the employee without unnecessarily disadvantaging the employee’s terms, conditions, or privileges of employment. [130] Where there is Essay, more than one reasonable accommodation that would not pose an undue hardship, the employer is not obliged to provide the accommodation preferred by the employee. [131] However, an employer’s proposed accommodation will not be “reasonable” if a more favorable accommodation is provided to other employees for The Bronfenbrenner Theory Essay non-religious purposes, [132] or, for example, if it requires the employee to accept a reduction in pay rate or some other loss of a benefit or privilege of employment and there is an alternative accommodation that does not do so. [133] Ultimately, reasonableness is a fact-specific determination. “The reasonableness of an employer’s attempt at accommodation cannot be determined in a vacuum. Instead, it must be determined on a case?by?case basis; what may be a reasonable accommodation for one employee may not be reasonable for another . . . . ‘The term ‘reasonable accommodation’ is a relative term and male punishment cannot be given a hard and The Bronfenbrenner Theory Essay fast meaning; each case . . . necessarily depends upon marketing its own facts and circumstances, and Theory Essay comes down to a determination of ‘reasonableness’ under the unique circumstances of the individual employer-employee relationship.’” [134] Employer Violates Title VII if it Offers Only Partial Accommodation Where Full Accommodation Would Not Pose an Undue Hardship. Rachel, who worked as a ticket agent at a sports arena, asked not to be scheduled for any Friday night or Saturday shifts, to permit her to observe the Jewish Sabbath from sunset on Friday through sunset on Saturday. The arena wanted to give Rachel only every other Saturday off.

The arena’s proposed accommodation is Clear Essay, not reasonable because it does not fully eliminate the religious conflict. The arena may deny the accommodation request only if giving Rachel every Saturday off poses an undue hardship for the arena. [135] Employer Not Obligated To Provide Employee’s Preferred Accommodation. Tina, a newly hired part-time store cashier whose sincerely held religious belief is The Bronfenbrenner, that she should refrain from work on Sunday as part of her Sabbath observance, asked her supervisor never to schedule her to work on Sundays. Tina specifically asked to be scheduled to work Saturdays instead. In response, her employer offered to allow her to work on Thursday, which she found inconvenient because she takes a college class on that day. Even if Tina preferred a different schedule, the employer is not required to grant Tina’s preferred accommodation. [136] Accommodation By Transfer Where Accommodation in male punishment Current Position Would Pose Undue Hardship. Yvonne, a member of the The Bronfenbrenner Pentecostal faith, was employed as a nurse at a hospital.

When she was assigned to the Labor and current marketing Delivery Unit, she advised the Theory Essay nurse manager that her faith forbids her from Clear Objectives participating “directly or indirectly in ending a life,” and that this proscription prevents her from The Bronfenbrenner Essay assisting with abortions. She asked the hospital to accommodate her religious beliefs by allowing her to trade assignments with other nurses in the Labor and Delivery Unit as needed. The hospital concluded that it could not accommodate Yvonne within the Labor and Delivery Unit because there were not enough staff members able and willing to trade with her. The hospital instead offered to permit Yvonne to transfer, without a reduction in pay or benefits, to a vacant nursing position in the Newborn Intensive Care Unit, which did not perform any such procedures. Street! The hospital’s solution complies with Title VII. The hospital is not required to grant Yvonne’s preferred accommodation where it has offered a reasonable alternative solution that eliminates the conflict between work and Essay a religious practice or belief under its existing policies and current marketing procedures. [137] If there had been no other position to which she could transfer, the employer would have been entitled to terminate her since it would pose an The Bronfenbrenner Essay, undue hardship to accommodate her in the Labor and Delivery Unit. Title VII is violated by black wall clothing, an employer’s failure to accommodate even if to avoid adverse consequences an employee continues to work after his accommodation request is denied. “An employee does not cease to be discriminated against The Bronfenbrenner Essay, because he temporarily gives up his religious practice and submits to of Alcoholism Essay the employment policy.” [138] Thus, the fact that an The Bronfenbrenner Theory Essay, employee acquiesces to current marketing the employer’s work rule, continuing to Theory Essay work without an accommodation after the employer has denied the request, should not defeat the employee’s legal claim. [139] In addition, the obligation to Technology in George 1984 provide reasonable accommodation absent undue hardship is a continuing obligation. Employers should be aware that an employee’s religious beliefs and practices may evolve over Essay time, and that this may result in Organizational Clear requests for additional or different accommodations. Essay! [140] Similarly, the Essay Technology is Used for Evil in George Orwell’s 1984 employer has the The Bronfenbrenner Essay right to discontinue a previously granted accommodation that is no longer utilized for religious purposes or poses an undue hardship. An employer can refuse to provide a reasonable accommodation if it would pose an undue hardship. The House Quotes! Undue hardship may be shown if the Theory Essay accommodation would impose “more than de minimis cost” on the operation of the employer’s business. [141] The concept of “more than de minimis cost” is discussed below in Clear Objectives sub-section 2. Although the employer’s showing of undue hardship under Title VII is easier than under the ADA, the burden of persuasion is still on the employer. [142] If an employee’s proposed accommodation would pose an undue hardship, the employer should explore alternative accommodations.

The determination of The Bronfenbrenner Theory, whether a particular proposed accommodation imposes an undue hardship “must be made by male punishment, considering the particular factual context of Theory, each case.” [143] Relevant factors may include the type of workplace, the nature of the employee’s duties, the identifiable cost of the accommodation in relation to the size and operating costs of the employer, and the number of employees who will in Organizational Essay fact need a particular accommodation. [144] For example, an employer with multiple facilities might be better able than another employer to accommodate a Muslim employee who seeks a transfer to a location with a nearby mosque that he can attend during his lunch break. To prove undue hardship, the employer will need to Essay demonstrate how much cost or disruption the employee’s proposed accommodation would involve. Clear Objectives! [145] An employer cannot rely on Essay, potential or hypothetical hardship when faced with a religious obligation that conflicts with scheduled work, but rather should rely on objective information. [146] A mere assumption that many more people with the same religious practices as the individual being accommodated may also seek accommodation is current marketing, not evidence of undue hardship. The determination of whether a proposed accommodation would pose an Essay, undue hardship is on How for Evil Orwell’s 1984, based on concrete, fact-specific considerations. [147] To establish undue hardship, the employer must demonstrate that the accommodation would require more than de minimis cost. [148] Factors to be considered are “the identifiable cost in relation to the size and operating costs of the employer, and the number of individuals who will in fact need a particular accommodation.” [149] Generally, the payment of Essay, administrative costs necessary for an accommodation, such as costs associated with rearranging schedules and recording substitutions for payroll purposes or infrequent or temporary payment of premium wages ( e.g. Wall Clothing! , overtime rates) while a more permanent accommodation is The Bronfenbrenner Essay, sought, will not constitute more than de minimis cost, whereas the regular payment of premium wages or the hiring of additional employees to provide an male punishment, accommodation will generally cause an undue hardship to the employer. [150] “[T]he Commission will presume that the infrequent payment of premium wages for a substitute or the payment of premium wages while a more permanent accommodation is being sought are costs which an employer can be required to bear as a means of Theory, providing reasonable accommodation.” [151] Costs to male punishment be considered include not only direct monetary costs but also the burden on the conduct of the employer’s business. The Bronfenbrenner Theory! For example, courts have found undue hardship where the accommodation diminishes efficiency in other jobs, [152] infringes on other employees’ job rights or benefits, [153] impairs workplace safety, or causes co-workers to carry the accommodated employee’s share of potentially hazardous or burdensome work. Objectives Essay! [154] Whether the Theory Essay proposed accommodation conflicts with another law will also be considered. [155] Religious Need Can Be Accommodated. David wears long hair pursuant to his Native American religious beliefs.

David applies for a job as a server at a restaurant which requires its male employees to the house quotes wear their hair “short and neat.” When the Theory Essay restaurant manager informs David that if offered the position he will have to cut his hair, David explains that he keeps his hair long based on his religious beliefs, and offers to wear it in a pony tail or held up with a clip. The manager refuses this accommodation, and male punishment denies David the position based on The Bronfenbrenner Essay, his long hair. The House On Mango Quotes! Since the evidence indicated that David could have been accommodated, without undue hardship, by wearing his hair in Essay a ponytail or held up with a clip, the employer will be liable for Essay Technology is Used for Evil 1984 denial of reasonable accommodation and discriminatory failure to hire. Safety Risk Poses Undue Hardship. Patricia alleges she was terminated from The Bronfenbrenner Theory her job as a steel mill laborer because of her religion (Pentecostal) after she notified her supervisor that her faith prohibits her from wearing pants, as required by the mill’s dress code, and requested as an accommodation to be permitted to wear a skirt. Management contends that the dress code is essential to the safe and efficient operation of the mill, and has evidence that it was imposed following several accidents in which skirts worn by employees were caught in black clothing the same type of mill machinery that Patricia operates. Because the evidence establishes that wearing pants is Theory Essay, truly necessary for safety reasons, the accommodation requested by Patricia poses an undue hardship. The House Street! [156]

3. Seniority Systems and Collectively Bargained Rights. A proposed religious accommodation poses an undue hardship if it would deprive another employee of a job preference or other benefit guaranteed by a bona fide seniority system or collective bargaining agreement (CBA). [157] Of course, the mere existence of a seniority system or CBA does not relieve the employer of the duty to attempt reasonable accommodation of its employees’ religious practices; the Essay question is whether an accommodation can be provided without violating the seniority system or CBA. Examples! [158] Allowing voluntary substitutes and swaps does not constitute an undue hardship to the extent the arrangements do not violate a bona fide seniority system or CBA. [159] Schedules Based on The Bronfenbrenner, a Seniority System or Collectively Bargained Rights. Susan, an employee of QRS Corp., asks not to work on her Sabbath. QRS and its employees’ union have negotiated a CBA which provides that weekend shifts will rotate evenly among employees. If Susan can find qualified co-workers voluntarily willing to swap shifts to accommodate her sincerely held religious beliefs, the employer could be found liable for denial of reasonable accommodation if it refuses to permit the swap to occur. Current Marketing! The existence of the collectively bargained system for determining weekend shifts should not result in the denial of accommodation if a voluntary swap can be arranged by the employee without violating the system or otherwise posing an undue hardship.

The result would be the same if QRS had a unilaterally imposed seniority system (rather than a CBA) pursuant to which weekend shifts are determined. However, if other employees were unwilling to swap shifts or were otherwise harmed by not requiring Susan to The Bronfenbrenner Essay work on the shift in question, or the employer would be subject to other operational costs that were more than de minimis by allowing Susan to swap shifts, then the employer can demonstrate undue hardship. [160] Although infringing on co-workers’ ability to current perform their duties [161] or subjecting co-workers to a hostile work environment will generally constitute undue hardship, [162] the general disgruntlement, resentment, or jealousy of co-workers will not. [163] Undue hardship requires more than proof that some co-workers complained; a showing of undue hardship based on co-worker interests generally requires evidence that the accommodation would actually infringe on the rights of co-workers or cause disruption of work. [164] See also §§ III-C and Essay IV-C-6 (discussing specifically complaints regarding proselytizing and other forms of religious expression), infra . If a religious practice actually conflicts with a legally mandated federal, state, or local security requirement, an employer need not accommodate the practice because doing so would create an undue hardship. If a security requirement has been unilaterally imposed by the employer and is not required by law or regulation, the employer will need to decide whether it would be an undue hardship to modify or eliminate the in George Orwell’s 1984 requirement to accommodate an employee who has a religious conflict. Accommodation Implicating Security Concerns. Patrick is employed as a correctional officer at a state prison, and Theory his brother William is employed as a grocery store manager. Both Patrick and William seek permission from their respective employers to the house quotes wear a fez at work as an The Bronfenbrenner Theory Essay, act of faith on a particular holy day as part of male punishment, their religious expression. Both employers deny the request, citing a uniformly applied workplace policy prohibiting employees from wearing any type of head covering. The prison’s policy is based on security concerns that head coverings may be used to conceal drugs, weapons, or other contraband, and may spark internal violence among prisoners.

The grocery store’s policy is based on The Bronfenbrenner, a stated desire that all employees wear uniform clothing so that they can be readily identified by customers. If both brothers file EEOC charges challenging the denial of black, their accommodation requests, Patrick will likely not prevail because the prison’s denial of his request was based on legitimate security considerations posed by the particular religious garb sought to be worn. William will likely prevail because there is The Bronfenbrenner Essay, no indication it would pose an street clothing, undue hardship for the grocery store to modify its policy with respect to Essay his request. [165] Harvinder, a baptized Sikh who works in a hospital, wears a small (4-inch), dull and sheathed kirpan (miniature sword) strapped and hidden underneath her clothing, as a symbol of her religious commitment to male punishment defend truth and moral values. When Harvinder’s supervisor, Bill, learned about her kirpan from a co-worker, he instructed Harvinder not to wear it at work because it violated the hospital policy against weapons in The Bronfenbrenner the workplace. Harvinder explained to Bill that her faith requires her to wear a kirpan in order to comply with the Sikh Code of Essay Technology is Used in George Orwell’s 1984, Conduct, and gave him literature explaining that the The Bronfenbrenner Essay kirpan is a religious artifact, not a weapon. She also showed him the kirpan, allowing him to see that it was no sharper than butter knives found in Essay on How Technology for Evil the hospital cafeteria. Theory Essay! Nevertheless, Bill told her that she would be terminated if she continued to wear the kirpan at work. Organizational Clear Objectives Essay! Absent any evidence that allowing Harvinder to wear the kirpan would pose an The Bronfenbrenner Theory, undue hardship in the factual circumstances of this case, the hospital is liable for denial of accommodation. [166] C. Common Methods of of Alcoholism, Accommodation in The Bronfenbrenner Theory the Workplace. Under Title VII, an employer or other covered entity may use a variety of methods to provide reasonable accommodations to its employees.

The most common methods are: (1) flexible scheduling; (2) voluntary substitutes or swaps of street, shifts and assignments; (3) lateral transfer and/or change of job assignment; and, (4) modifying workplace practices, policies, and/or procedures. An employer may be able to reasonably accommodate an Theory Essay, employee by allowing flexible arrival and departure times, floating or optional holidays, flexible work breaks, use of lunch time in exchange for clothing early departure, staggered work hours, and other means to enable an employee to make up time lost due to the observance of religious practices. [167] However, EEOC’s position is that it will be insufficient merely to eliminate part of the conflict, unless eliminating the conflict in its entirety will pose an undue hardship by disrupting business operations or impinging on other employees’ benefits or settled expectations. Break Schedules/Prayer at Work. Rashid, a janitor, tells his employer on his first day of work that he practices Islam and will need to The Bronfenbrenner Essay pray at The Concept, several prescribed times during the workday in order to adhere to his religious practice of praying at five specified times each day, for Essay several minutes, with hand washing beforehand. The employer objects because its written policy allows one fifteen-minute break in current the middle of each morning and afternoon.

Rashid’s requested change in break schedule will not exceed the 30 minutes of total break time otherwise allotted, nor will it affect his ability to perform his duties or otherwise cause an Essay, undue hardship for his employer. Thus, Rashid is entitled to accommodation. [168] Blanket Policies Prohibiting Time Off for current Religious Observance. A large employer operating a fleet of buses had a policy of Essay, refusing to black accept driver applications unless the applicant agreed that he or she was available to be scheduled to work any shift, seven days a week. This policy violates Title VII to the extent that it discriminates against applicants who refrain from work on certain days for religious reasons, by failing to allow for the provision of religious accommodation absent undue hardship. [169] 2. Voluntary Substitutes and Shift Swaps. Although it would pose an undue hardship to require employees involuntarily to The Bronfenbrenner Theory Essay substitute for the house on mango one another or swap shifts, the reasonable accommodation requirement can often be satisfied without undue hardship where a volunteer with substantially similar qualifications is available, either for a single absence or an extended period of time. The employer’s obligation is to make a good faith effort to allow voluntary substitutions and Theory shift swaps, under circumstances which do not discourage employees from substituting for one another or trading shifts to accommodate a religious conflict. Male Punishment! [170] However, if the employer is on notice that the employee’s religious beliefs preclude him not only from working on his Sabbath but also from inducing others to do so, reasonable accommodation requires more than merely permitting the The Bronfenbrenner Theory employee to the house street swap. [171] Nevertheless, an employer does not have to Theory permit a substitute or swap if it would pose more than de minimis cost or burden to business operations. As noted above, if a swap or substitution would result in the employer having to pay premium wages (such as overtime pay), the frequency of the arrangement will be relevant to determining if it poses an undue hardship; “the Commission will presume that the Essay examples infrequent payment of premium wages for a substitute or the payment of premium wages while a more permanent accommodation is The Bronfenbrenner Theory Essay, being sought are costs which an employer can be required to The Concept Essay bear as a means of providing reasonable accommodation.” [172] An employer may have to Theory make an exception to its scheduling policies, procedures, or practices in order to grant religious accommodation. Wall! [173] For example, if it does not pose an The Bronfenbrenner Theory, undue hardship, an employer must make an exception to its policy of requiring all employees, regardless of seniority, to work an “equal number of weekend, holiday, and night shifts,” and instead permit voluntary shift swaps between qualified co-workers in black wall street order to accommodate a particular employee’s sincerely held religious belief that he should not work on The Bronfenbrenner, the Sabbath. Of course, if allowing a swap or other accommodation would not provide the coverage the for Evil 1984 employer needs for its business operations or otherwise pose an Theory, undue hardship, the accommodation does not have to be granted.

3. Change of of Alcoholism examples, Job Tasks and Lateral Transfer. When an employee’s religious belief or practice conflicts with a particular task, appropriate accommodations may include relieving the employee of the task or transferring the employee to a different position or location that eliminates the conflict with the employee’s religion. Whether or not such accommodations pose an The Bronfenbrenner Theory, undue hardship will depend on Essay Technology for Evil in George 1984, factors such as the nature or importance of the duty at The Bronfenbrenner, issue, the availability of others to perform the function, the availability of other positions, and Clear Objectives Essay the applicability of a CBA or seniority system. Restaurant Server Excused from Singing Happy Birthday. Kim, a server at a restaurant, informed her manager that she would not be able to join other waitresses in singing “Happy Birthday” to The Bronfenbrenner Theory customers because she is Clear, a Jehovah’s Witness whose religious beliefs do not allow her to The Bronfenbrenner celebrate holidays, including birthdays. There were enough servers on The Concept examples, duty at any given time to perform this singing without affecting service.

The manager refused any accommodation. If Kim files a Title VII charge alleging denial of religious accommodation, she will prevail because the restaurant could have accommodated her with little or no expense or disruption. The Bronfenbrenner Theory! [174] Pharmacist Excused from Providing Contraceptives. Neil, a pharmacist, was hired by a large corporation that operates numerous large pharmacies at which more than one pharmacist is on on mango street quotes, duty during all hours of operation. Neil informed his employer that he refused on religious grounds to participate in The Bronfenbrenner distributing contraceptives or answering any customer inquiries about contraceptives. The employer reasonably accommodated Neil by offering to allow Neil to signal to a co-worker who would take over servicing any customer who telephoned, faxed, or came to the pharmacy regarding contraceptives. [175] Pharmacist Not Permitted to Turn Away Customers.

In the above example, assume that instead of facilitating the assistance of such customers by a co-worker, Neil leaves on hold indefinitely those who call on the phone about clothing a contraceptive rather than transferring their calls, and walks away from in-store customers who seek to fill a contraceptive prescription rather than signaling a co-worker. The Bronfenbrenner Theory! The employer is not required to accommodate Neil’s request to remain in such a position yet avoid all situations where he might even briefly interact with customers who have requested contraceptives, or to accommodate a disruption of business operations. The employer may discipline or terminate Neil for marketing not meeting legitimate expectations. [176] The employee should be accommodated in his or her current position if doing so does not pose an The Bronfenbrenner, undue hardship. [177] If no such accommodation is possible, the male punishment employer needs to consider whether lateral transfer is a possible accommodation. [178] For example, if a pharmacist who has a religious objection to dispensing contraceptives can be accommodated without undue hardship by The Bronfenbrenner Theory, allowing the pharmacist to street clothing signal a co-worker to assist customers with such prescriptions, the employer cannot choose instead to accommodate by The Bronfenbrenner, transferring the pharmacist to a different position. Essay On How For Evil In George! Moreover, if the pharmacist cannot be accommodated within his position, the employer cannot transfer the pharmacist to a position that entails less pay, responsibility, or opportunity for advancement unless a lateral transfer is unavailable or would otherwise pose an undue hardship.[179] Lateral Transfer Versus Transfer to a Lower-Paying Position. An electrical utility lineman requests accommodation of his Sabbath observance, but because the nature of his position requires being available to The Bronfenbrenner Essay handle emergency problems at any time, there is no accommodation that would permit the lineman to remain in his position without posing an undue hardship. The employer can accommodate the on How Technology is Used for Evil in George lineman by offering a lateral transfer to another assignment at the same pay, if available. If, however, no job at the same pay is readily available, then the employer could satisfy its obligation to Theory reasonably accommodate the Organizational lineman by offering to transfer him to a different job, even at lower pay, if one is available. [180]

4. Modifying Workplace Practices, Policies and The Bronfenbrenner Essay Procedures. When an employer has a dress or grooming policy that conflicts with an employee’s religious beliefs or practices, the employee may ask for an exception to the policy as a reasonable accommodation. [181] Religious grooming practices may relate, for example, to black street shaving or hair length. Religious dress may include clothes, head or face coverings, jewelry, or other items. Absent undue hardship, religious discrimination may be found where an employer fails to accommodate the employee’s religious dress or grooming practices. [182] Prakash, who works for CutX, a surgical instrument manufacturer, does not shave or trim his facial hair because of his Sikh religious observance. When he seeks a promotion to manage the division responsible for sterilizing the instruments, his employer tells him that, to work in that division, he must shave or trim his beard because otherwise his beard may contaminate the sterile field. When Prakash explains that he cannot trim his beard for The Bronfenbrenner Theory Essay religious reasons, the employer offers to allow Prakash to wear two face masks instead of Essay examples, trimming his beard. Prakash thinks that wearing two masks is unreasonable and files a Title VII charge. CutX will prevail because it offered a reasonable accommodation that would eliminate Prakash’s religious conflict with the hygiene rule. Some courts have concluded that it would pose an undue hardship if an employer was required to accommodate a religious dress or grooming practice that conflicts with the public image the employer wishes to Theory Essay convey to customers. [183] While there may be circumstances in which allowing a particular exception to an employer’s dress and grooming policy would pose an undue hardship, an The Concept of Alcoholism examples, employer’s reliance on the broad rubric of “image” to Theory deny a requested religious accommodation may in a given case be tantamount to reliance on customer religious bias (so-called “customer preference”) in violation of Title VII. [184]

Nasreen, a Muslim ticket agent for a commercial airline, wears a head scarf, or hijab, to work at the airport ticket counter. After September 11, 2001, her manager objected, telling Nasreen that the the house quotes customers might think she was sympathetic to terrorist hijackers. Nasreen explains to her manager that wearing the hijab is her religious practice and continues to The Bronfenbrenner wear it. She is terminated for wearing it over her manager’s objection. Customer fears or prejudices do not amount to Objectives undue hardship, and the refusal to Theory Essay accommodate her and the termination, therefore, violate Title VII.

In addition, denying Nasreen the position due to male punishment perceptions of customer preferences about religious attire would be disparate treatment based on religion in violation of Title VII, because it would be the same as refusing to hire Nasreen because she is a Muslim. See supra § II-B. Essay! [185] There may be limited situations in black wall which the The Bronfenbrenner Essay need for uniformity of appearance is so important that modifying the The Concept dress code would pose an Theory Essay, undue hardship. [186] However, even in these situations, a case-by-case determination is advisable. [187] If any employee needs to use a workplace facility as a reasonable accommodation, for Clear Essay example use of The Bronfenbrenner, a quiet area for prayer during break time, the employer should accommodate the request under Title VII unless it would pose an undue hardship. Male Punishment! If the employer allows employees to use the facilities at issue for non-religious activities not related to work, it may be difficult for the employer to Theory Essay demonstrate that allowing the facilities to be used in the same manner for religious activities is not a reasonable accommodation or poses an undue hardship. [188]

Use of Essay Technology in George Orwell’s 1984, Employer Facilities. An employee whose assigned work area is a factory floor rather than an Theory, enclosed office asks his supervisor if he may use one of the wall street company’s unoccupied conference rooms to pray during a scheduled break time. The supervisor must grant this request if it would not pose an undue hardship. An undue hardship would exist, for example, if the only conference room is The Bronfenbrenner Theory Essay, used for work meetings at that time. However, the supervisor is not required to provide the male punishment employee with his choice of the available locations, and can meet the accommodation obligation by making any appropriate location available that would accommodate the employee’s religious needs if this can be done absent undue hardship, for The Bronfenbrenner Essay example by current marketing, offering an unoccupied area of the work space rather than the conference room. c. Tests and The Bronfenbrenner Essay Other Selection Procedures. An employer has an obligation to clothing accommodate an employee or prospective employee when scheduling a test or administering other selection procedures, where the applicant has informed the employer of a sincerely held religious belief that conflicts with a pre-employment testing requirement, unless undue hardship would result. [189] An employer may not permit an applicant’s need for a religious accommodation to affect its decision whether or not to hire the applicant unless the employer can demonstrate that it cannot reasonably accommodate the applicant’s religious practice without undue hardship. [190] d. Theory! Providing Social Security Numbers. It will typically pose an undue hardship for an employer to accommodate an applicant or employee’s asserted religious belief against street, providing or using a social security number. [191] 5. Excusing Union Dues or Agency Fees. Absent undue hardship, Title VII requires employers and Theory unions to accommodate an employee who holds religious objections to joining or financially supporting a union. [192] Such an employee can be accommodated by allowing the equivalent of Essay is Used 1984, her union dues (payments by union members) or agency fees (payments often required from non-union members in a unionized workplace) to be paid to a charity agreeable to the employee, the union, and The Bronfenbrenner Theory Essay the employer. [193] Whether a charity-substitute accommodation for wall clothing payment of union dues would cause an undue hardship is an Theory, individualized determination based upon, among other things, the union’s size, operational costs, and Clear Objectives the number of individuals that need the accommodation. [194] If an The Bronfenbrenner Theory, employee’s religious objection is not to joining or financially supporting the union, but rather to the union’s support of certain political or social causes, the employee may be accommodated if it would not pose an undue hardship by, for example, reducing the amount owed and/or by male punishment, allowing the The Bronfenbrenner Theory employee to donate to current marketing a charitable organization the The Bronfenbrenner full amount the employee owes or that portion that is attributable to the union’s support of the cause to The Concept of Alcoholism which the Theory Essay employee has a religious objection, or by diverting the full amount to Essay Technology is Used in George Orwell’s the national, state, or local union in The Bronfenbrenner the event one of those entities does not engage in support of the cause to which the employee has a religious objection. [195]

6. Permitting Prayer, Proselytizing, and Other Forms of Religious Expression. Some employees may seek to display religious icons or messages at their work stations. Others may seek to proselytize by engaging in one-on-one discussions regarding religious beliefs, distributing literature, or using a particular religious phrase when greeting others. Still others may seek to engage in male punishment prayer at their work stations or to use other areas of the workplace for either individual or group prayer or study. In some of these situations, an employee might request accommodation in advance to permit such religious expression. In other situations, the employer will not learn of the situation or be called upon to consider any action unless it receives complaints about the Theory Essay religious expression from Essay on How Technology is Used for Evil in George Orwell’s 1984 either other employees or customers. As noted in §§ II-A-3 and The Bronfenbrenner Essay III-C of this document, prayer, proselytizing, and other forms of religious expression do not solely raise the issue of the house on mango street, religious accommodation, but may also raise disparate treatment or harassment issues. To determine whether allowing or continuing to permit an employee to pray, proselytize, or engage in Theory Essay other forms of religiously oriented expression in the workplace would pose an undue hardship, employers should consider the potential disruption, if any, that will be posed by permitting this expression of on How is Used for Evil in George Orwell’s 1984, religious belief. [196] As explained below, relevant considerations may include the effect such expression has had, or can reasonably be expected to have, if permitted to Theory Essay continue, on co-workers, customers, or business operations. a. Effect on Workplace Rights of Co-Workers. Expression can create undue hardship if it disrupts the work of other employees or constitutes or threatens to constitute unlawful harassment. Since an Organizational Objectives, employer has a duty under Title VII to protect employees from religious harassment, it would be an undue hardship to The Bronfenbrenner Essay accommodate such expression.

As explained in § III-A-2-b of wall street, this document, religious expression directed toward co-workers might constitute harassment in some situations, for The Bronfenbrenner example where it is facially abusive ( i.e. , demeans people of other religions), or where, even if not abusive, it persists even though the 1984 co-workers to whom it is directed have made clear that it is unwelcome. It is necessary to make a case-by-case determination regarding whether the effect on The Bronfenbrenner, co-workers actually is an undue hardship. The House Quotes! However, this does not require waiting until the alleged harassment has become severe or pervasive. [197] As with harassment on any basis, it is Essay, permitted and advisable for employers to take action to stop alleged harassment before it becomes severe or pervasive, because while isolated incidents of harassment generally do not violate federal law, a pattern of such incidents may be unlawful. [198] The determination of whether it is an the house on mango, undue hardship to allow employees to engage in religiously oriented expression toward customers is a fact-specific inquiry and will depend on the nature of the expression, the nature of the employer’s business, and The Bronfenbrenner Theory the extent of the impact on customer relations. For example, one court found that it did not impose an undue hardship for Essay on How for Evil Orwell’s a private sector employer to allow a cashier to use the The Bronfenbrenner Theory general religious greeting “Have a Blessed Day” in accepting payment where it was said in the context of brief anonymous interactions and had little demonstrable adverse impact on customers or the wall clothing business. The Bronfenbrenner Theory! [199] However, other courts have found undue hardship where religiously oriented expression was used in the context of a regular business interaction with a client. [200] Whether or not the client objects, this may be an Organizational, undue hardship for an employer where the The Bronfenbrenner expression could be mistaken as the on mango street quotes employer’s message. Where the religiously oriented expression is not limited to use of a phrase or greeting, but rather is in the manner of individualized, specific proselytizing, an employer is The Bronfenbrenner Theory, far more likely to be able to demonstrate that it would constitute an undue hardship to accommodate an black wall, employee’s religious expression, regardless of the length or nature of the business interaction. The Bronfenbrenner Theory! [201] Display of Religious Objects By an Essay examples, Employee. Susan and Roger are members of the same church and are both employed at XYZ Corporation. The Bronfenbrenner! Susan works as an architect in a private office on an upper floor, where she occasionally interacts with co-workers, but not with clients. Male Punishment! Roger is The Bronfenbrenner Theory, a security guard stationed at current marketing, a desk in The Bronfenbrenner Theory Essay the front lobby of the marketing XYZ building through which all employees, clients, and other visitors must enter.

At a recent service at Theory, Susan and Roger’s church, the the house minister distributed posters with the message “Jesus Saves!” and encouraged parishioners to Theory Essay display the posters at their workplaces in order to “spread the word.” Susan and Roger each display the poster on the wall above their respective work stations. XYZ orders both to remove the poster despite the fact that both explained that they felt a religious obligation to display it, and despite the fact that there have been no complaints from black street co-workers or clients. Susan and Roger file charges alleging denial of Theory, religious accommodation. The employer will probably be unable to show that allowing Susan to display a religious message in her personal workspace posed an undue hardship, because there was no evidence of any disruption to Essay in George the business or the workplace which resulted. By contrast, because Roger sits at the lobby desk and the poster is the first thing that visitors see upon Theory entering the building, it would appear to represent XYZ’s views and marketing would therefore likely be shown to pose an undue hardship. [202] Undue Hardship to Allow Employee to Discuss Religion with Clients. Helen, an employee in The Bronfenbrenner Essay a mental health facility that served a religiously and ethnically diverse clientele, frequently spoke with clients about religious issues and shared religious tracts with them as a way to the house quotes help solve their problems, despite being instructed not to do so. After clients complained, Helen’s employer issued her a letter of reprimand stating that she should not promote her religious beliefs to clients and that she would be terminated if she persisted. Helen’s belief in the need to evangelize to Theory clients cannot be accommodated without undue hardship. The employer has the right to control speech that threatens to impede provision of effective and efficient services.

Clients, especially in a mental health setting, may not understand that the marketing religious message represents Helen’s views rather than the clinic’s view of the most beneficial treatment for the patient. Theory! [203] Some employers have integrated their own religious beliefs or practices into the workplace, and they are entitled to do so. [204] However, if an employer holds religious services or programs or includes prayer in business meetings, Title VII requires that the employer accommodate an employee who asks to be excused for religious reasons, absent a showing of undue hardship. [205] Excusing an employee from Essay on How for Evil in George religious services normally does not create an undue hardship because it does not cost the employer anything and The Bronfenbrenner Theory does not disrupt business operations or other workers. [206] Prayer at Meetings. Michael’s employer requires that the mandatory weekly staff meeting begin with a religious prayer. Michael objects to participating because he believes it conflicts with his own sincerely held religious beliefs. On Mango Quotes! He asks his supervisor to allow him to arrive at the meeting after the prayer. The supervisor must accommodate Michael’s religious belief by either granting his request or offering an The Bronfenbrenner Theory, alternative accommodation that would remove the conflict between Michael’s religious belief and the staff meeting prayer, even if other employees of Michael’s religion do not object to male punishment being present for the prayer. [207] Employer Holiday Decorations.

Each December, the president of XYZ corporation directs that several wreaths be placed around the office building and a tree be displayed in the lobby. Several employees complain that to accommodate their non-Christian religious beliefs, the employer should take down the wreaths and tree, or alternatively should add holiday decorations associated with other religions. Title VII does not require that XYZ corporation remove the wreaths and Theory tree or add holiday decorations associated with other religions. The result under Title VII on Essay on How Technology in George Orwell’s, these facts would be the The Bronfenbrenner Theory same whether in a private or government workplace. [208] Similarly, an employer is required, absent undue hardship, to excuse an employee from compulsory personal or professional development training where it conflicts with the employee’s sincerely held religious beliefs or practices. [209] There may be cases, however, where an employer can show that it would pose an undue hardship to provide an alternative training or to excuse an employee from any part of wall street, a particular training, even if the employee asserts it is contrary to his religious beliefs to attend ( e.g. The Bronfenbrenner Theory! , where the training provides information on how to perform the job, on the house street quotes, how to Theory comply with equal employment opportunity obligations, or on other workplace policies, procedures, or applicable legal requirements). Religious Objection to Training Program Employee Must Be Excused. As part of its effort to promote employee health and productivity, the new president of a company institutes weekly mandatory on-site meditation classes led by a local spiritualist. Angelina explains to her supervisor that the meditation conflicts with her sincerely held religious beliefs, and current marketing asks to The Bronfenbrenner Essay be excused from participating.

Because it would not pose an undue hardship, the male punishment company must accommodate Angelina’s religious belief by excusing her from the weekly meditation classes, even if the Theory Essay company and the house street quotes other employees believe that this form of meditation does not conflict with any religious beliefs. Religious Objection to Training Program Employee Need Not Be Excused. Employer XYZ holds an annual training for The Bronfenbrenner Essay employees on black street clothing, a variety of personnel matters, including compliance with EEO laws and also XYZ’s own internal anti-discrimination policy, which includes a prohibition on sexual orientation discrimination. Lucille asks to be excused from the The Bronfenbrenner portion of the training on sexual orientation discrimination because she believes that it “promotes the acceptance of of Alcoholism, homosexuality,” which she sincerely believes is immoral and The Bronfenbrenner sinful based on The Concept of Alcoholism, her religion. The training does not tell employees to value different sexual orientations but simply discusses and reinforces the employer’s conduct rule requiring employees not to discriminate against or harass other employees and to treat one another professionally. Because an employer needs to make sure that its employees know about and The Bronfenbrenner Theory Essay comply with such employer workplace rules, it would be an undue hardship for of Alcoholism examples XYZ to excuse Lucille from the Essay training.[210] While not all of the following issues will be in dispute in every charge alleging denial of religious accommodation, if CP alleges that R failed to marketing accommodate CP’s religious beliefs or practices, the The Bronfenbrenner investigator should generally follow this line of inquiry, considering these steps: Ascertain the wall nature of the belief or practice that CP claims R has failed to accommodate ( e.g. Theory Essay! , dress, grooming, holy day observance, etc.) and what accommodation was sought (e.g., exception to Objectives dress code, schedule change, leave, etc.). If disputed by R, determine whether CP’s beliefs are “religious” in nature.

If disputed by Theory Essay, R, determine whether CP “sincerely holds” the particular religious belief or practice at issue. Ascertain whether CP actually notified R of the need for a religious accommodation, i.e. , whether it was made known to R that an accommodation was needed and that it was for religious reasons. The investigator should seek evidence of when, where, how, and to quotes whom such notice was given, and the names of any witnesses to the notification. If R claims that it was not notified of CP’s need for an accommodation, the investigator should attempt to resolve the discrepancies between R’s contention and CP’s allegation by The Bronfenbrenner, gathering additional available evidence corroborating or refuting CP’s and male punishment R’s contentions. Determine R’s response, if any, to The Bronfenbrenner Essay the accommodation request. The House Quotes! Was an accommodation offered, and if so, what? The investigator should obtain R’s statement of all attempts to accommodate CP, if any attempts were made. The investigator should seek a specific and complete explanation from The Bronfenbrenner Essay R as to the facts on which it relied ( e.g. , why R concluded CP did not have a sincerely-held religious belief or practice, or why R concluded that accommodation would have posed an undue hardship in terms of cost, disruption, effect on co-workers, or any other reason).

For example, in the event R is a union and the accommodation claim relates to payment of agency fees or union dues, the investigator should obtain any relevant information regarding how the Organizational Clear Essay particular union at issue may have handled payment by this religious objector in order to provide accommodation. If R asserts that it did not accommodate CP’s request because it would have posed an undue hardship, obtain all available evidence regarding whether or not a hardship would in fact have been posed, i.e. , whether the alleged burden is more than de minimis . If R’s undue hardship defense is based on cost, ascertain the cost of the accommodation in relation to R’s size, nature of business operations, operating costs, and the impact, if any, of similar accommodations already being provided to other employees. If R’s undue hardship defense is based on a factor other than cost ( i.e. , disruption, production or staffing levels, security, or other factor), similarly ascertain the impact of the accommodation with respect to R’s particular workplace and The Bronfenbrenner Theory Essay business. When there is more than one method of accommodation available that would not cause undue hardship, the investigator should evaluate whether the accommodation offered is reasonable by examining: (1) whether any alternative reasonable accommodation was available; (2) whether R considered any alternatives for accommodation; (3) the alternative(s) for accommodation, if any, that R actually offered to of Alcoholism Essay examples CP; and (4) whether the alternative(s) the employer offered eliminated the conflict. Theory! [211] If R asserts CP failed to cooperate with R in of Alcoholism reaching an accommodation, obtain any available evidence regarding the The Bronfenbrenner relevant communications, including whether CP refused any offer of reasonable accommodation. Reasonable Accommodation - Generally. Employers should inform employees that they will make reasonable efforts to accommodate the employees’ religious practices.

Employers should train managers and on mango street quotes supervisors on how to recognize religious accommodation requests from employees. The Bronfenbrenner Essay! Employers should consider developing internal procedures for processing religious accommodation requests. Employers should individually assess each request and Essay examples avoid assumptions or stereotypes about what constitutes a religious belief or practice or what type of accommodation is appropriate. Employers and The Bronfenbrenner Theory employees should confer fully and wall clothing promptly to the extent needed to share any necessary information about the Essay employee’s religious needs and the available accommodation options. An employer is not required to provide an Organizational Essay, employee’s preferred accommodation if there is more than one effective alternative to The Bronfenbrenner Essay choose from. Organizational Essay! An employer should, however, consider the employee’s proposed method of accommodation, and if it is denied, explain to the employee why his proposed accommodation is not being granted. Theory! Managers and supervisors should be trained to consider alternative available accommodations if the particular accommodation requested would pose an undue hardship. The House On Mango Street! When faced with a request for a religious accommodation which cannot be promptly implemented, an employer should consider offering alternative methods of accommodation on a temporary basis, while a permanent accommodation is being explored. In this situation, an employer should also keep the employee apprised of the status of the employer’s efforts to implement a permanent accommodation. The de minimis undue hardship standard refers to Theory Essay the legal requirement. As with all aspects of street clothing, employee relations, employers can go beyond the requirements of the law and should be flexible in evaluating whether or not an accommodation is The Bronfenbrenner Theory Essay, feasible.

An employer should not assume that an accommodation will conflict with the terms of a seniority system or CBA without first checking if there are any exceptions for The Concept Essay examples religious accommodation or other avenues to allow accommodation consistent with the The Bronfenbrenner Theory Essay seniority system or CBA. An employer should not automatically reject a request for religious accommodation just because the accommodation will interfere with the existing seniority system or terms of a CBA. Although an employer may not upset co-workers’ settled expectations, an employer is free to seek a voluntary modification to a CBA in Clear Essay order to accommodate an employee’s religious needs. Employers should train managers to be aware that, if the requested accommodation would violate the CBA or seniority system, they should confer with the employee to Theory determine if an wall street clothing, alternative accommodation is available. Employers should ensure that managers are aware that reasonable accommodation may require making exceptions to policies or procedures that are not part of a CBA or seniority system, where it would not infringe on other employees’ legitimate expectations. Employers should work with employees who need an adjustment to their work schedule to accommodate their religious practices. Notwithstanding that the legal standard for undue hardship is “more than de minimis ,” employers may of The Bronfenbrenner, course choose voluntarily to wall incur whatever additional operational or financial costs they deem appropriate to accommodate an employee’s religious need for scheduling flexibility. Employers should consider adopting flexible leave and scheduling policies and procedures that will often allow employees to meet their religious and other personal needs. Such policies can reduce individual requests for exceptions. For example, some employers have policies allowing alternative work schedules and/or a certain number of “floating” holidays for each employee. While such policies may not cover every eventuality and some individual accommodations may still be needed, the number of such individual accommodations may be substantially reduced.

Voluntary Substitutes or Swaps. An employer should facilitate and encourage voluntary substitutions and swaps with employees of substantially similar qualifications by publicizing its policy permitting such arrangements, promoting an Theory, atmosphere in which substitutes are favorably regarded, and The Concept Essay examples providing a central file, bulletin board, group e-mail, or other means to help an employee with a religious conflict find a volunteer to substitute or swap. Change of Job Assignments and Lateral Transfers. An employer should consider a lateral transfer when no accommodation which would keep the employee in his or her position is possible absent undue hardship. However, an Theory Essay, employer should only Organizational Clear Objectives Essay, resort to transfer, whether lateral or otherwise, after fully exploring accommodations that would permit the employee to Theory remain in his position. Marketing! Where a lateral transfer is unavailable, an employer should not assume that an employee would not be interested in Theory a lower-paying position if that position would enable the wall street employee to abide by The Bronfenbrenner, his or her religious beliefs.

If there is no accommodation available that would permit the the house on mango employee to Theory remain in his current position or an equivalent one, the employer should offer the available position as an accommodation and the house on mango permit the employee to Essay decide whether or not to take it. Modifying Workplace Practices, Policies, and Procedures. Employers should make efforts to accommodate an employee’s desire to wear a yarmulke, hijab, or other religious garb. If the employer is concerned about male punishment uniform appearance in a position which involves interaction with the public, it may be appropriate to The Bronfenbrenner consider whether the employee’s religious views would permit him to resolve the in George Orwell’s 1984 religious conflict by, for The Bronfenbrenner Theory Essay example, wearing the item of religious garb in the company uniform color(s). Managers and employees should be trained not to engage in stereotyping based on religious dress and grooming practices and should not assume that atypical dress will create an undue hardship. Employers should be flexible and current creative regarding work schedules, work duties, and selection procedures to the extent practicable. Employers should be sensitive to the risk of unintentionally pressuring or coercing employees to attend social gatherings after the employees have indicated a religious objection to attending. Permitting Prayer, Proselytizing, and Other Forms of The Bronfenbrenner Essay, Religious Expression. Employers should train managers to gauge the actual disruption posed by religious expression in the workplace, rather than merely speculating that disruption may result.

Employers should also train managers to identify alternative accommodations that might be offered to avoid actual disruption ( e.g. , designating an unused or private location in the workplace where a prayer session or Bible study meeting can occur if it is disrupting other workers). Employers should incorporate a discussion of religious expression, and the need for all employees to be sensitive to the beliefs or non-beliefs of others, into any anti-harassment training provided to managers and employees. Employees should advise their supervisors or managers of the nature of the conflict between their religious needs and the work rules. Employees should provide enough information to Clear Objectives Essay enable the employer to understand what accommodation is needed, and why it is necessitated by The Bronfenbrenner Theory, a religious practice or belief. Employees who seek to proselytize in male punishment the workplace should cease doing so with respect to any individual who indicates that the The Bronfenbrenner communications are unwelcome.

12-V RELATED FORMS OF DISCRIMINATION. A. National Origin, Race , and Color. Title VII’s prohibition against black wall street clothing, religious discrimination may overlap with Title VII’s prohibitions against The Bronfenbrenner Theory Essay, discrimination based on national origin, race, and Organizational Clear Essay color. Where a given religion is strongly associated or perceived to Theory be associated with a certain national origin, the same facts may state a claim of both religious and national origin discrimination. [212] All four bases might be implicated where, for example, co-workers target a dark-skinned Muslim employee from Saudi Arabia for on How is Used Orwell’s 1984 harassment because of his religion, national origin, race, and/or color. [213] Title VII prohibits retaliation by an employer, employment agency, or labor organization because an The Bronfenbrenner Theory Essay, individual has engaged in protected activity. The Concept Of Alcoholism Examples! [214] Protected activity consists of opposing a practice the employee reasonably believes is made unlawful by one of the employment discrimination statutes or of filing a charge, testifying, assisting, or participating in any manner in an investigation, proceeding, or hearing under the statute. EEOC has taken the position that requesting religious accommodation is protected activity. [215] Retaliation for Requesting Accommodation. Jenny requests that she be excused from The Bronfenbrenner Essay daily employer-sponsored Christian prayer meetings because she is an atheist.

Her supervisor insists that she attend, but she persists in her request that she should be excused, and explains that requiring her to attend is offensive to wall street her religious beliefs. She takes her request to human resources, and informs them that requiring her to attend these prayer meetings is offensive to her religious beliefs. The Bronfenbrenner Theory! Despite her supervisor’s objections, the human resources department instructs the supervisor that in the circumstances no undue hardship is posed and he must grant the request. Technology Is Used For Evil In George Orwell’s! Motivated by reprisal, her supervisor shortly thereafter gives her an unjustified poor performance rating, and denies her requests to attend training that is The Bronfenbrenner, approved for similarly situated employees. This violates Title VII. Employers can reduce the risk of retaliation claims by training managers and supervisors to be aware of their anti-retaliation obligations under Title VII, including specific actions that may constitute retaliation. The House Street! Employers can help reduce the risk of retaliation claims by carefully and timely recording the accurate business reasons for disciplinary or performance related actions and Essay sharing these reasons with the Essay is Used in George Orwell’s employee. HOW APPLICANTS OR EMPLOYEES CAN FILE A CHARGE. If you believe you have been discriminated against by a private sector or state or local government employer, labor union, or employment agency when applying for a job or while on the job because of your race, color, religion, sex, national origin, age (40 or over), or disability, or believe that you have been discriminated against because you opposed unlawful discrimination or participated in an equal employment opportunity (EEO) proceeding, you may file a charge of discrimination with the U.S.

Equal Employment Opportunity Commission (EEOC). Essay! Charges against Essay examples, private sector and local and The Bronfenbrenner Essay state government employers may be filed in current person, by mail, or by The Bronfenbrenner Essay, telephone by male punishment, contacting the nearest EEOC office. If there is no EEOC office in the immediate area, call toll free 1-800?669?4000 or 1?800?669?6820 (TTY) for more information. To avoid delay, call or write beforehand if you need special assistance, such as an interpreter, to file a charge. Federal sector employees and applicants should contact the Theory Essay EEO office of the agency responsible for on mango street the alleged discrimination to initiate EEO counseling. There are strict time frames in which charges of employment discrimination must be filed or your agency’s EEO office must be contacted. When charges or complaints are filed beyond these time frames, you may not be able to obtain any remedy. The Bronfenbrenner Theory! Charges against private sector or state or local governments must be filed with EEOC within 180 days of the the house on mango street alleged discriminatory act.

The time frame is extended to 300 days if the alleged discrimination arose in a state or locality that has a fair employment practices agency (FEPA) with the The Bronfenbrenner Theory Essay authority to grant or seek relief for the alleged discrimination. Federal sector employees and wall street clothing applicants must initiate EEO counseling at the agency responsible for the alleged discrimination within 45 days of the alleged discriminatory event. Allegations of harassment based on race, color, religion, sex, or national origin are timely if at least one incident of harassment that is part of the larger pattern of harassment occurred within the filing period. If you wish to remain anonymous during the period when an EEOC charge is being processed involving a private sector or state or local government employer, another individual or an organization may file a charge on your behalf. In some circumstances, an EEOC Commissioner may file a charge against a private sector or state or local government employer. The Bronfenbrenner Essay! Federal sector employees and applicants may remain anonymous during EEO counseling, but lose the right to anonymity after filing a formal complaint. WHEN A CHARGE IS FILED AGAINST A PRIVATE SECTOR OR STATE OR LOCAL GOVERNMENT EMPLOYER. This appendix provides general information regarding the processing of a charge alleging discrimination by a private sector or state or local government employer under the EEO statutes. The information presented in this appendix applies to private sector and state and local government employers only. For information on the processing of complaints against federal agencies, visit the EEOC’s “Federal Sector Information” page on the Internet at http://eeoc.gov/federal/fed_employees/index.cfm. Anyone who believes that a private sector or state or local government employer has violated his or her employment rights based on race, color, sex, religion, national origin, age (40 or over), disability, opposition to on mango quotes unlawful discrimination, or participation in The Bronfenbrenner Theory an EEO proceeding, may file a charge of Organizational Objectives, discrimination with the EEOC.

A charge does not constitute a finding that your company did, in fact, discriminate. The EEOC has a responsibility to investigate and The Bronfenbrenner Theory Essay determine whether there is reasonable cause to believe discrimination occurred. That process begins with the EEOC sending your company a copy of the male punishment charge, which will briefly identify the charging party, the basis ( e.g. , race, religion, etc.) and issues (hiring, promotion, etc.), and the date(s) of the The Bronfenbrenner Theory Essay alleged discrimination. The House Street Quotes! You also may be asked to provide a response to the charge and Essay supporting documentation. The EEOC also may ask to visit your work site or to interview some employees. It is important that your company retain records relating to the house on mango street issues under investigation as a result of the charge until the charge or any lawsuit based on the charge is resolved. In some cases, the EEOC notice may offer mediation as a method of resolving the charge before an investigation. EEOC’s mediation program is a free service, and participation is voluntary. The process is confidential, and there is a firewall ( i.e. , total separation) between the mediation program and Essay EEOC’s enforcement activities. Mediation provides employers and charging parties the opportunity to reach mutually agreeable solutions early in the process.

The EEOC will notify your company if a charge is eligible for mediation. In the street clothing event that mediation does not succeed, the charge is referred for investigation. If the EEOC finds reasonable cause to believe that your company discriminated against a charging party, it will invite you to conciliate the charge ( i.e. Theory! , the EEOC will offer you a chance to resolve the matter informally). In some cases, where conciliation fails, the EEOC will file a civil court action. If the EEOC does not find discrimination, or if conciliation fails and the EEOC chooses not to file suit, it will issue a notice of a right to sue, which gives the charging party 90 days to file a civil court action. The EEOC also must issue a notice of right to sue to the charging party on request if its handling of the charge is still pending after 180 days, or earlier if the EEOC knows it will take more than 180 days to complete action on the charge. In all cases, your company should remember that it is unlawful to retaliate against the charging party for filing the charge, even if you believe the charge is without merit. You should submit a response to the EEOC and provide the information requested, even if you believe the charge is frivolous.

If the charge was not dismissed by the EEOC when it was received, that means there was some basis for proceeding with further investigation. There are many cases where it is unclear whether discrimination may have occurred and an investigation is necessary. Essay On How Is Used For Evil! You are encouraged to present any facts that you believe show the allegations are incorrect or do not amount to a violation of the law. [1] This document uses examples that refer to the practices and beliefs of various religions. These examples are intended to clarify the legal principles for which they are used and do not purport to represent the Theory religious beliefs or practices to which they refer.

In some instances, links to non-EEOC Internet sites are also provided for the reader’s convenience in obtaining additional information. EEOC assumes no responsibility for their content and does not endorse their organizations or guarantee the accuracy of the house on mango quotes, these sites. [2] This Section of the Theory Compliance Manual replaces Section 628: Religious Accommodation , EEOC Compliance Manual, Volume II and its Appendices: Appendix A, Policy Statement on Ansonia Board of Education v. Is Used In George! Philbrook and Religious Accommodation ; Appendix B, Policy Guidance On ‘New Age’ Training Programs Which Conflict With Employees’ Religious Beliefs ; and Appendix C, Religious Objections to Unionism . It also replaces the The Bronfenbrenner following policy documents: Religious Organizations that Pay Women Less than Men in Accordance with Religious Beliefs ; Religious Organization Exemption Under Title VII of the street Civil Rights Act of Theory, 1964, as amended ; and The Concept examples Policy Statement on Goldman v. Weinberger (Accommodation of the Wearing of Religious Dress ). The Commission’s Guidelines on Discrimination Because of Religion (hereafter Commission Guidelines ) are not affected by this Section. See Commission Guidelines , 29 C.F.R. The Bronfenbrenner Essay! Part 1605. [3] Use of the term “employee” in this document should be presumed to Organizational Objectives include an Theory, applicant and, as appropriate, a former employee. [4] 42 U.S.C. § 2000e-2(a) provides that it is an unlawful employment practice for an employer: (1) 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 race, color, religion, sex, or national origin; or.

(2) to limit, segregate, or classify his employees or applicants for employment in any way which would deprive or tend to current deprive any individual of employment opportunities or otherwise adversely affect his status as an employee, because of such individual’s race, color, religion, sex, or national origin. 42 U.S.C. § 2000e(j) provides that: The term “religion” includes all aspects of religious observance and practice, as well as belief, unless an employer demonstrates that he is The Bronfenbrenner Theory Essay, 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. [5] Federal legislation known as the Workplace Religious Freedom Act (“WRFA”), that has been proposed since the 1990s, would amend Title VII to change the current “ de minimis ” standard for establishing undue hardship to require employers to show that the accommodation would cause significant difficulty or expense. Marketing! See H.R. 1431, 110th Cong. The Bronfenbrenner Essay! (2007). The House On Mango Street! This compliance manual chapter interprets and applies the current federal law, and takes no position on WRFA. Note: Various state and local laws extend beyond Title VII in terms of the protected bases covered, the discrimination prohibited or accommodation required, and the legal standards and defenses that apply. [6] See, e.g., Torcaso v. Watkins , 367 U.S. Theory Essay! 488, 495 n.11 (1961) (First Amendment does not permit government to Objectives Essay distinguish between theistic and non-theistic religions such as Buddhism, Taoism, Ethical Culture, and Secular Humanism); Young v. Southwestern Sav. Theory! Loan Ass’n, 509 F.2d 140 (5th Cir.

1975) (Title VII violated by Essay on How for Evil Orwell’s, requiring atheist employee to attend prayer portion of business meeting). [7] Society for Human Resource Management (SHRM) and Essay the Tanenbaum Center for Interreligious Understanding, Religion in the Workplace Survey, at 6 (Society for Human Resource Management, 2001) (executive summary and information on obtaining report available at black wall clothing, http://www.tanenbaum.org/research.html (last visited July 2, 2008); Pew Forum on Religion and Public Life, U.S. Essay! Religious Landscape Survey (2008), available at http://religions.pewforum.org/reports (last visited July 2, 2008). [8] In fiscal year 2007, EEOC received 2,880 religious discrimination charges, accounting for 3.5% of all charges filed with the Commission that year. In fiscal year 1992, EEOC received 1,388 religious discrimination charges, accounting for 1.9% of the house on mango street quotes, all charges filed with the Commission that year. The Bronfenbrenner Essay! Statistics regarding the number of religious discrimination charges filed with the Commission can be found at http://eeoc.gov/eeoc/statistics/enforcement/charges.cfm. [9] “Religion in the Workplace is a Diversity Issue for U.S. Companies,” U.S. Department of State’s Bureau of International Information Programs (Nov. 28, 2007), available at http://www.america.gov/st/ washfile-english/2007/November/20071128173019xlrennef0.1781427.html (last visited July 2, 2008). [10] The principles discussed in this Section apply to Title VII claims against private employers as well as to federal, state, and local public sector employers, unless otherwise noted.

See 42 U.S.C. Current Marketing! §§ 2000e(a) - (b), 2000e-16(a), et seq. , and 2000e-16a. The Bronfenbrenner Theory! See, e.g. , infra nn.11-15, 66 (directing attention to situations where the Religious Freedom Restoration Act (RFRA) may apply), and 201-203. As explained in the house on mango n.5, supra , claims under various state or local laws may be analyzed under different standards. [11] The First Amendment religion and speech clauses (“Congress shall make no law respecting an establishment of religion, or prohibiting the free exercise thereof; or abridging the freedom of speech”) protect individuals against restrictions imposed by Theory, the government, not by private entities, and therefore do not apply to rules imposed on private sector employees by their employers. The First Amendment, however, does protect private sector employers from government interference with their free exercise and the house quotes speech rights. Moreover, government employees’ religious expression is protected by both the First Amendment and Title VII. See infra nn.12-15, 66, and Essay accompanying text; Brown v. Polk County , 61 F.3d 650 (8th Cir. 1995); Guidelines on Religious Exercise and Religious Expression in the Federal Workplace (Aug. 14, 1997) (hereafter Federal Workplace Guidelines ), 158 Daily Labor Report (BNA) 1522-5968 (Aug. 15, 1997) (available at http://clinton2.nara.gov/WH/New/html/19970819-3275.html (last visited July 2, 2008)).

Although the Federal Workplace Guidelines are directed at federal employers, they provide useful guidance for private employers as well. In addition, the Organizational Clear Essay U.S. Department of Justice maintains a website, www.firstfreedom.gov, which provides information on Theory, a variety of constitutional and statutory religious discrimination issues, including a section on Title VII employment protections based on religion. [12] See Daniels v. City of Arlington , 246 F.3d 500 (5th Cir.) (as a government entity, police department may be able to demonstrate that providing the requested accommodation would have posed an undue hardship because allowing the officer to wear a cross on his uniform would give the appearance of public agency endorsement of the officer’s religious views, in wall street clothing violation of the department’s constitutional obligations), cert. The Bronfenbrenner Theory! denied , 534 U.S. 951 (2001); Helland v. South Bend Cmty. Essay! Sch. Corp. , 93 F.3d 327 (7th Cir. 1996) (public school did not violate either plaintiff’s Title VII religious accommodation right or his First Amendment free exercise right by removing plaintiff from substitute teacher list due to his proselytizing in class); Brown v. Polk County , 61 F.3d at 656-59 (where there was no evidence that subordinates objected on religious grounds , it would not have posed an undue hardship under Title VII, or violated the First Amendment Establishment Clause, to Theory Essay accommodate supervisor’s occasional affirmations of Christianity and spontaneous voluntary prayers during meetings). [13] See, e.g., EEOC v. Townley Eng’g Mfg.

Co. , 859 F.2d 610, 621 (9th Cir. Essay On How Technology Is Used In George! 1988) (court must balance the The Bronfenbrenner Theory application of Title VII to the employment policy against quotes, private employers’ right under First Amendment Free Exercise clause to practice their religion; private secular employer’s free exercise right to The Bronfenbrenner Theory hold mandatory religious services for employees did not outweigh its Title VII obligation to accommodate atheist employee’s request to be exempt from attending the services on religious grounds; excusing plaintiff’s attendance would not pose an undue hardship on current, operation of The Bronfenbrenner Essay, employer’s business). [14] See, e.g., Knight v. Connecticut Dep’t of Pub. Health , 275 F.3d 156, 164-65 (2d Cir. 2001) (state agency did not violate either Title VII or First Amendment Free Exercise Clause by refusing to Organizational Objectives allow employee to evangelize clients of state agency while performing job duties; in addition, employer would have risked First Amendment Establishment Clause violation by permitting the accommodation); Fraternal Order of Police v. City of Newark , 170 F.3d 359 (3d Cir. 1999) (police department violated Sunni Muslim officer’s First Amendment free exercise rights by refusing to make a religious exception to The Bronfenbrenner its “no beard” policy to accommodate his beliefs, while exempting other officers for medical reasons); Draper v. Male Punishment! Logan County Pub. Library , 403 F. Supp. 2d 608 (W.D.

Ky. 2005) (public library employee’s First Amendment free speech and free exercise rights were violated when she was prohibited from wearing a necklace with a cross ornament). [15] Guidance for government workplaces on the First Amendment religious free exercise issues, much of which is also useful for Theory Essay the private sector, is Technology for Evil in George, available in the Federal Workplace Guidelines , supra n.11 ; see also Brown , 61 F.3d at The Bronfenbrenner Essay, 658 (applying First Amendment test governing free speech of public employees to First Amendment free exercise claims, court balanced an employee’s right to free exercise with the employer’s interest in providing effective and efficient public services; public employee’s termination constituted both denial of of Alcoholism Essay, religious accommodation under Title VII and Theory violation of First Amendment Free Exercise Clause). [16] 42 U.S.C. § 2000e-2. To determine whether an entity is covered by Title VII, see EEOC Compliance Manual, “Threshold Issues,” https://www.eeoc.gov/policy/docs/threshold.html. Although this document concerns Title VII, employers and employees should note that there may be state and local laws in the house their jurisdiction prohibiting religious discrimination in employment, some of which may be parallel to Title VII and some of which may afford narrower or broader coverage.

[18] “Theistic” is defined as “believing in a god or gods.” The American Heritage Dictionary of the English Language , Fourth Ed , Houghton Mifflin Co. Theory Essay! (2004), available at http://dictionary.reference.com/browse/theistic (last visited July 2, 2008). [19] 42 U.S.C. § 2000e(j). Male Punishment! Redmond v. GAF Corp. , 574 F.2d 897, 900 (7th Cir. 1978) (the statutory language “all aspects of religious practice and belief” is interpreted broadly; “to restrict the act to those practices which are mandated or prohibited by a tenet of the religion, would involve the court in determining not only what are the Theory Essay tenets of a particular religion, which by male punishment, itself perhaps would not be beyond the province of the court, but would frequently require the courts to The Bronfenbrenner Theory decide whether a particular practice is or is not required by the tenets of the religion”); s ee also Employment Div., Dep’t of on How Technology is Used in George, Human Res. of Oregon v. Smith , 494 U.S. 872, 887 (1990) (in holding that the Free Exercise Clause did not prohibit application of Oregon drug laws to ceremonial ingestion of Essay, peyote, Court noted that “[r]epeatedly and in many different contexts, we have warned that courts must not presume to street clothing determine the place of a particular belief in a religion or the The Bronfenbrenner plausibility of a religious claim”). [20] Thomas v. Review Bd. of the wall Indiana Employment Sec. Div. , 450 U.S. 707, 714 (1981) (“religious beliefs need not be acceptable, logical, consistent, or comprehensible to others in order to merit First Amendment protection”); see also Church of Theory, Lukumi Babalu Aye, Inc. v. City of Hialeah , 508 U.S. Organizational Essay! 520, 531 (1993) (although animal sacrifice may seem “abhorrent” to some, Santerian belief is religious in Theory nature and is protected by the First Amendment); U.S. v. Meyers , 906 F. Supp. 1494, 1499 (D. Wyo.

1995) (“one man’s religion will always be another man’s heresy”). [21] Thomas , 450 U.S. at 716 (“[I]t is not within the judicial function and judicial competence to inquire whether the petitioner or [another practitioner] . . . more correctly perceived the wall street clothing commands of their common faith. Courts are not arbiters of scriptural interpretation.”). [22] Redmond , 574 F.2d at 901 n.12 (Title VII case citing United States v. Seeger , 380 U.S. 163 (1969), and Welsh v. United States , 398 U.S. 333 (1970), which defined protected “religion” for The Bronfenbrenner Essay purposes of the male punishment Universal Military Training and Service Act). Unless otherwise noted, cases are cited in this document for their Title VII holdings.

[23] Seeger , 380 U.S. at 176. “This standard was developed in The Bronfenbrenner Essay [ Seeger ] and [ Welsh ]. The Commission has consistently applied this standard in its decisions.” 29 C.F.R. § 1605.1. [24] Commission Guidelines , 29 C.F.R. § 1605.1 (“The fact that no religious group espouses such beliefs or the fact that the Essay on How Technology Orwell’s 1984 religious group to which the individual professes to belong may not accept such belief will not determine whether the belief is a religious belief of the employee or prospective employee.”); Welsh, 398 U.S. at 343 (petitioner’s beliefs were religious in nature although the church to which he belonged did not teach those beliefs); accord Africa v. Commonwealth of Pa ., 662 F.2d 1025, 1032-33 (3d Cir.1981); Bushouse v. Local Union 2209, United Auto., Aerospace Agric. Implement Workers of The Bronfenbrenner Theory Essay, Am. Black Wall Street Clothing! , 164 F. Supp. 2d 1066, 1076 n.15 (N.D. Ind. 2001) (“Title VII’s intention is to provide protection and accommodation for a broad spectrum of religious practices and belief not merely those beliefs based upon organized or recognized teachings of The Bronfenbrenner Theory, a particular sect”). [25] Commission Guidelines , 29 C.F.R. § 1605.1; Torcaso , 367 U.S. at 489-90 (government may not favor theism over pantheism or atheism); Welsh , 398 U.S.

333 (to be religion protected by the First Amendment, a belief system need not have a concept of black street, a god, supreme being, or afterlife; plaintiff’s belief was deemed to be religious because it was held with strength of traditional religious beliefs); Townley , 859 F.2d 610 (Title VII prohibits an employer from compelling its atheist employees to attend religious services); Young , 509 F.2d 140 (same). [26] United States v. Meyers, 906 F. Supp. 1494, 1499 (D. Wyo. 1995) (the threshold for establishing the religious nature of beliefs is low; under the First Amendment, “if there is any doubt about whether a particular set of beliefs constitutes a religion, the Court will err on the side of freedom and find that the beliefs are a religion. The Bronfenbrenner! . . . [because the The Concept of Alcoholism country’s] founders were animated in The Bronfenbrenner Theory large part by a desire for religious liberty”), aff’d , 95 F.3d 1475, 1482-83 (10th Cir. 1996); see also Smith , 494 U.S. at 887 (in holding that the current Free Exercise Clause did not prohibit application of Oregon drug laws to ceremonial ingestion of peyote, Court noted that “[r]epeatedly and in many different contexts, we have warned that courts must not presume to determine the The Bronfenbrenner Theory place of a particular belief in a religion or the plausibility of a religious claim”). [27] Meyers, 906 F. Supp. at 1502 (religions address “ultimate ideas,” i.e. , “fundamental questions about life, purpose, and death”; holding that single-faceted worship of marijuana was not a religion for First Amendment purposes), aff’d , 95 F.3d at 1483; accord Africa, 662 F.2d at 1032 (“a religion [protected by the First Amendment] addresses fundamental and ultimate questions having to do with deep and Essay imponderable matters [and] . . . is Theory, comprehensive in The Concept of Alcoholism examples nature; it consists of Essay, a belief-system as opposed to an isolated teaching”); Dettmer v. Landon , 617 F. Supp. The Concept Of Alcoholism Essay Examples! 592, 595-96 (E.D. Va.

1985) (under the First Amendment, Wiccans’ belief is religious in nature because, among other things, the belief structure relates to “ultimate” concerns and reflects a broad concern for improving the quality of life for others), aff’d in Theory relevant part and rev’d on Clear, other grounds , 799 F.2d 929 (4th Cir. 1986); Church of the Chosen People (No. Am. Panarchate) v. The Bronfenbrenner Theory! United States , 548 F. Supp. 1247 (D. Minn. 1982) (a church whose single-faceted doctrine concerned sexual preference and not ultimate questions was not a religion entitled to tax exemption); Brown v. Pena , 441 F. Supp. 1382, 1385 (S.D.

Fla. Wall Street Clothing! 1977) (“religious” belief under Title VII “is based on Essay, a theory of ‘man’s nature or his place in the Universe,’ [and is] not merely a personal preference”), aff’d, 589 F.2d 1113 (5th Cir. 1979). Although “religion” is often marked by external manifestations such as ceremonies, rituals or clergy, such manifestations are not required for a belief to be “religious.” E.g., Malnak v. Yogi, 592 F.2d 197, 209-10 (3d Cir. 1979). [28] For example, EEOC and courts have found that the the house on mango street quotes Ku Klux Klan is not a religion within the meaning of Title VII because its philosophy has a narrow, temporal, and political character. Theory Essay! Commission Decision No. 79-06, CCH EEOC Decisions ¶ 6737 (1983); Bellamy v. Mason’s Stores, Inc., 368 F. Technology Is Used For Evil In George Orwell’s! Supp. The Bronfenbrenner Theory Essay! 1025, 1026 (E.D.

Va. 1973), aff’d , 508 F.2d 504 (4th Cir. 1974); Slater v. King Soopers , 809 F. Supp. 809, 810 (D. Clear Essay! Colo. 1992) (dismissing religious discrimination claim by The Bronfenbrenner, a member of the Ku Klux Klan who allegedly was fired for Essay is Used in George 1984 participating in a Hitler rally because the Ku Klux Klan is The Bronfenbrenner Essay, “political and social in nature” and is not a religion for Title VII purposes); s ee also Brown v. Pena, 441 F. Supp.

1382 (plaintiff’s belief that eating cat food contributes to his well-being is a personal preference and not a religion). In an Organizational Essay, analogous case, Peterson v. Wilmur Communications, Inc ., 205 F. Supp. 2d 1014, 1022 (E.D. Wis. 2002), the court held that an employee’s membership in the World Church of the Creator was a “religious” belief, even though the organization’s central tenet is white supremacy, because “it functions as religion in The Bronfenbrenner Theory Essay [plaintiff’s] life” as evidenced by the fact that he has been a minister in it for more than three years, worked to current marketing put the church’s teachings into practice, and actively proselytizes. However, the Theory Peterson court might have reached a different conclusion had it considered whether the belief was merely one-dimensional and thus not religious, i.e. , not part of current, a moral or ethical belief system concerning “ultimate ideas” about “life, purpose, and death.” [29] Compare Tiano v. Dillard Dep’t Stores, Inc ., 139 F.3d 679 (9th Cir. 1998) (employer not liable for denying employee’s request to The Bronfenbrenner be absent from work on male punishment, particular dates to The Bronfenbrenner Essay attend a religious pilgrimage where the male punishment evidence showed that her religious needs could be met by going on the pilgrimage at another time and that the The Bronfenbrenner particular dates she requested were simply a personal preference), with Heller v. EBB Auto Co. , 8 F.3d 1433 (9th Cir. 1993) (employer liable for failing to accommodate Jewish employee’s attendance of spouse’s conversion ceremony); see also Wessling v. Kroger Co. , 554 F. Supp. Current! 548 (E.D.

Mich. 1982) (employer not liable for The Bronfenbrenner Theory denial of accommodation where employee requested leave to help children get into their costumes and practice before performance of church play; employee’s own testimony revealed her participation in this instance was more in male punishment the nature of The Bronfenbrenner Essay, a parental and the house on mango street quotes social obligation); Redmond , 574 F.2d at 901 (employer liable for failing to accommodate employee’s participation in Essay Saturday Bible classes; the Clear court found his attendance to The Bronfenbrenner be pursuant to a sincerely held religious belief given that he was appointed to Essay on How is Used for Evil Orwell’s 1984 be lifetime leader of The Bronfenbrenner Theory Essay, his church Bible study class many years earlier, time of meeting was scheduled by Organizational Clear, church elders, and Theory employee felt that his participation was at dictate of his elders and constituted a “religious obligation”); Weitkenaut v. Goodyear Tire Rubber Co. , 381 F. Supp. The Concept Of Alcoholism Essay Examples! 1284, 1288?89 (D. Vt. 1974) (employer liable for failing to protect minister’s attendance at monthly church organizational meetings where it was considered necessary to preparing for his pastoral duties and thus essential to his ability to The Bronfenbrenner Essay lead his congregation). [30] Cf. LaFevers v. Black Wall Street Clothing! Saffle , 936 F.2d 1117 (10th Cir. 1991) (although not all Seventh-day Adventists are vegetarian, an individual adherent’s genuine religious belief in such a dietary practice warrants constitutional protection under the First Amendment). [31] See, e.g., Wessling v. Essay! Kroger Co. , 554 F. Supp. 548 (E.D.

Mich. 1982) (court held that plaintiff, who had volunteered to arrive at Organizational Clear Essay, Church early to set up, decorate, and Theory receive children prior to their performance of a play during Christmas Mass, was engaging in current a social and family obligation rather than a religious belief, practice, or observance). [32] See Dettmer v. Landon, 799 F.2d 929, 932 (4th Cir. Theory Essay! 1986) (in First Amendment case, rejecting argument that witchcraft was a “conglomeration” of street, “various aspects of the occult” rather than a religion; religious beliefs need not be “acceptable, logical, consistent or comprehensible to others” to be protected); Washington Ethical Soc’y v. Theory! District of Clear Objectives Essay, Columbia , 249 F.2d 127, 128 (D.C. Cir. 1957) (Ethical Society qualifies as a “religious corporation or society” and its building is The Bronfenbrenner, entitled to The Concept of Alcoholism tax exemption; belief in a Supreme Being or supernatural power is not essential to qualify for tax exemption accorded to “religious corporations,” “churches” or “religious societies”); Fellowship of Humanity v. County of Alameda , 315 P.2d 394 (Cal. App. 1957) (same holding with respect to Secular Humanists). [33] EEOC v. Red Robin Gourmet Burgers, Inc. Theory! , 2005 WL 2090677 (W.D. Wash.

Aug. Of Alcoholism Essay Examples! 29, 2005) (denying employer’s motion for summary judgment on accommodation claim arising from Theory Essay employee’s refusal to cover his Kemetic religious tattoos in order to comply with employer’s dress code). [34] These facts are similar to those in Cloutier v. Costco Wholesale Corp. , 390 F.3d 126 (1st Cir. 2004). Black Wall Street! However, the court in Cloutier did not resolve the issue of whether or not the plaintiff’s facial piercing, which she alleged was displayed pursuant to her adherence to Theory Essay the beliefs of the Church of the house quotes, Body Modification, was part of a “religious” belief, practice, or observance, instead finding that the proposed accommodation of The Bronfenbrenner Essay, allowing display of the Organizational Clear piercing would have posed an Theory, undue hardship. [35] Seeger , 380 U.S. at 185 (“[w]hile the Technology is Used in George Orwell’s 1984 ‘truth’ of a belief is not open to question, there remains the significant question of whether it is ‘truly held’”). [36] EEOC v. Union Independiente De La Autoridad De Acueductos, 279 F.3d 49, 56 (1st Cir. Theory! 2002) (evidence that Seventh-day Adventist employee had acted in ways inconsistent with the tenets of his religion, for example that he worked five days a week rather than the required six, had lied on on How Technology is Used in George Orwell’s 1984, an employment application, and took an oath before a notary upon becoming a public employee, can be relevant to The Bronfenbrenner Essay the evaluation of Essay is Used in George Orwell’s, sincerity but is not dispositive); Hansard v. Johns-Manville Prods. Corp ., 1973 WL 129 (E.D.

Tex. Feb. 16, 1973) (employee’s contention that he objected to The Bronfenbrenner Theory Essay Sunday work for religious reasons was undermined by his very recent history of Sunday work); see also Hussein v. Waldorf-Astoria , 134 F. Supp. 2d 591 (S.D.N.Y. Black! 2001) (employer had a good faith basis to doubt sincerity of employee’s professed religious need to wear a beard because he had not worn a beard at The Bronfenbrenner Theory, any time in male punishment his fourteen years of employment, had never mentioned his religious beliefs to anyone at the hotel, and simply showed up for work one night and asked for an on-the-spot exception to the no?beard policy), aff’d , 2002 WL 390437 (2d Cir. The Bronfenbrenner Theory! Mar. 13, 2002) (unpublished). [37] EEOC v. Ilona of Hungary, Inc ., 108 F.3d 1569 (7th Cir. 1997) (en banc) (Jewish employee proved her request for leave to observe Yom Kippur was based on a sincerely held religious belief even though she had never in her prior eight-year tenure sought leave from Organizational Objectives work for a religious observance, and The Bronfenbrenner Theory Essay conceded that she generally was not a very religious person; the evidence showed that certain events in her life, including the birth of her son and the death of her father, had strengthened her religious beliefs over the years); Cooper v. Oak Rubber Co ., 15 F.3d 1375 (6th Cir.

1994) (that employee had worked the Friday night shift at plant for approximately seven months after her baptism did not establish that she did not hold sincere religious belief against working on Saturdays, considering that 17 months intervened before employee was next required to work on Saturday, and employee’s undisputed testimony was that her faith and commitment to her religion grew during this time); EEOC v. IBP, Inc., 824 F. Supp. 147 (C.D. Ill. 1993) (Seventh-day Adventist employee’s previous absence of faith and subsequent loss of current marketing, faith did not prove that his religious beliefs were insincere at The Bronfenbrenner Theory, the time that he refused to The Concept of Alcoholism work on the Sabbath); s ee also Union Independiente, 279 F.3d at 57 n.8 (the fact that the alleged conflict between plaintiff’s beliefs and union membership kept changing might call into question the sincerity of the beliefs or “might simply reflect an evolution in The Bronfenbrenner Essay plaintiff’s religious views toward a more steadfast opposition to current union membership”). [38] Commission Guidelines , 29 C.F.R. § 1605.1; Anderson v. U.S.F. The Bronfenbrenner Theory Essay! Logistics (IMC), Inc. Organizational Objectives! , 274 F.3d 470, 475 (7th Cir.

2001) (employee’s belief that she needed to use the phrase “Have a Blessed Day” was a religious practice covered by Title VII even though using the phrase was not a requirement of Theory Essay, her religion); Rivera v. Clear Essay! Choice Courier , 2004 WL 1444852 (S.D.N.Y. June 25, 2004) (the statutory language providing that Title VII encompasses “all aspects of religious observance and practice, as well as belief,” means that Title VII “protects more than . The Bronfenbrenner Essay! . . practices specifically mandated by an employee’s religion”). [39] For the text of 42 U.S.C. § 2000e-2(a), which applies to employers, see supra n.4. Under 42 U.S.C. § 2000e-2(b), it is unlawful for the house on mango street quotes employment agencies to “fail or refuse to refer for employment, or otherwise to discriminate against, any individual because of his . . . religion . . . or to classify or refer for employment any individual on the basis of his . . Theory! . Male Punishment! religion . Essay! . . Essay On How Is Used For Evil Orwell’s! .” Under 42 U.S.C. § 2000e-2(c), it is unlawful for Essay unions to “(1) to exclude or expel from membership, or otherwise to discriminate against, any individual because of his . . . religion . Of Alcoholism Examples! . Essay! . ; (2) to limit, segregate or classify its membership or applicants . . . or to refuse to refer for employment any individual . . Marketing! . because of such individual’s . . . religion . . . ; or (3) to Theory cause or attempt to cause an on How Technology, employer to The Bronfenbrenner Theory Essay discriminate . . Essay On How Is Used For Evil 1984! . in violation of The Bronfenbrenner Theory, this section.” [40] See, e.g., Union Independiente, 279 F.3d 49; Bushouse , 164 F. Supp. 2d 1066. See infra §§ II, III, and IV; see also § IV-C-5. [41] Goodman v. Lukens Steel Co . 482 U.S.

656, 668-69 (1987) (unions violated “§ 703(c)(1) [of Title VII, which] makes it an unlawful practice for current marketing a Union to ‘exclude or to expel from its membership, or otherwise to Theory discriminate against, any individual’” when they “ignored [racial] discrimination claims . . . , knowing that the employer was discriminating in violation of the contract”). See, e.g., Perugini v. The Concept Essay Examples! Safeway Stores, 935 F. 2d 1083 (9th Cir. Theory! 1991) (remand to determine whether union discriminatorily failed to of Alcoholism Essay examples challenge employer’s refusal to give pregnant worker light duty); Rainey v. The Bronfenbrenner! Town of Warren , 80 F. Supp. 2d 5, 17 (D.R.I. Essay Technology 1984! 2000) (“[i]t is axiomatic that a union’s failure to adequately represent union members in the face of The Bronfenbrenner, employer discrimination may subject the of Alcoholism examples union to liability under either Title VII or its duty of The Bronfenbrenner, fair representation”). To the Organizational Clear Objectives extent it has been held that a union cannot be held liable where it knowingly acquiesces in discrimination, the EEOC disagrees.

See EEOC v. Pipefitters Ass’n Local Union 597 , 334 F.3d 656 (7th Cir. The Bronfenbrenner Essay! 2003). [42] Section 702(a) of Title VII, 42 U.S.C. Clear Objectives Essay! § 2000e-1(a), provides: This subchapter shall not apply to . . . a religious corporation, association, educational institution, or society with respect to The Bronfenbrenner Theory the employment of individuals of black street clothing, a particular religion to perform work connected with the carrying on by such corporation, association, educational institution, or society of its activities. Section 703(e)(2) of Title VII, 42 U.S.C. The Bronfenbrenner Essay! § 2000e-2(e)(2) provides: it shall not be an current marketing, unlawful employment practice for Theory a school, college, university, or educational institution or institution of learning to Essay hire and employ employees of The Bronfenbrenner Theory Essay, a particular religion if such school, college, university, or other educational institution or institution of learning is, in whole or in substantial part, owned, supported, controlled, or managed by a particular religion or by examples, a particular religious corporation, association, or society, or if the curriculum of such school, college, university, or other educational institution or institution of learning is directed toward the propagation of a particular religion.

While Congress did not include a definition of the § 702(a) term “religious corporation” in Title VII, at least one judge has argued that the legislative history indicates that Congress intended “the § 703(e)(2) exemption to require a lesser degree of association between an entity and a religious sect than what would be required under § 702(a).” See LeBoon v. Lancaster Jewish Cmty. Ctr. , 503 F.3d 217, 237 (3d Cir. 2007) (Rendell, J., dissenting). Executive Order 13279, Equal Protection of the Laws for Faith-Based and Community Organizations , issued on The Bronfenbrenner Theory, December 12, 2002, provides that certain faith-based organizations that provide social programs can deliver those services and on mango street make hiring decisions on the basis of their religious beliefs even if they receive federal funding. See 67 Fed. The Bronfenbrenner! Reg.

77,141 (12/16/02). Male Punishment! The Guidance to Faith-Based and Community Organizations on Partnering with the Federal Government , http://www.whitehouse.gov/government/fbci/guidance_document_01-06.pdf (last visited July 2, 2008), issued by the White House Office of Theory, Faith Based and Community Initiatives, explains that while religious organizations that receive federal funds to provide social services may choose to hire persons of the same religion, they are also subject to federal, state, and local employment and anti-discrimination laws, such as Title VII. [43] Townley , 859 F.2d at 618; accord Hall v. Baptist Mem. Health Care Corp. , 215 F.3d 618, 624-25 (6th Cir. 2000) (college of health sciences qualified as a religious institution under Title VII because it was an examples, affiliated institution of a church-affiliated hospital, had direct relationship with the Baptist church, and Theory Essay the college atmosphere was permeated with religious overtones). [44] Townley, 859 F.2d at examples, 618; see also Killinger v. Samford Univ. , 113 F.3d 196 (11th Cir. 1997) (Baptist university was “religious educational institution” where largest single source of funding was state Baptist Convention, all university trustees were Baptists, university reported financially to The Bronfenbrenner Essay Convention and to Baptist State Board of Missions, university was member of Association of Baptist Colleges and Organizational Clear Essay Schools, university charter designated its chief purpose as “the promotion of the Christian Religion throughout the world by maintaining and operating institutions dedicated to the development of Christian character in high scholastic standing,” and both Internal Revenue Service (IRS) and Department of Education recognized university as religious educational institution).

[45] Townley , 859 F.2d at 619 (manufacturer of mining equipment, whose owners asserted that they made a covenant with God that their business “would be a Christian, faith?operated business,” is not a religious organization because it is for The Bronfenbrenner Essay profit; it produces mining equipment, a secular product; it is black wall street clothing, not affiliated with or supported by a church; and The Bronfenbrenner Theory its articles of incorporation do not mention any religious purpose) . The House On Mango Street! Cf. EEOC v. Kamehameha Sch./Bishop Estate , 990 F.2d 458, 461 (9th Cir. The Bronfenbrenner Theory Essay! 1993) (non-profit school not “religious” for Title VII purposes where ownership and Organizational Objectives affiliation, purpose, faculty, student body, student activities, and curriculum of the schools are either essentially secular, or neutral as far as religion is concerned). [46] See Corp. of the Theory Essay Presiding Bishop of the Church of Jesus Christ of Latter-Day Saints v. Amos , 483 U.S. 327 (1987) (a nonprofit church-run business does not violate Title VII if it refuses to hire anyone other than members of its own religion, even for enterprises or jobs that are not religious in nature). [47] Killinger , 113 F.3d at 200 (School of Divinity need not employ professor who did not adhere to the theology advanced by its leadership); Tirpanlis v. Unification Theological Seminary , 2001 WL 64739 (S.D.N.Y.

Jan. 24, 2001) (seminary operated by wall street, Unification Church cannot be sued for religious discrimination by Greek Orthodox employee who was allegedly terminated for Theory refusing to accept the Clear Objectives Essay teachings of the Unification Church). [48] Ziv v. The Bronfenbrenner Theory! Valley Beth Shalom , 156 F.3d 1242 (Table), 1998 WL 482832 (9th Cir. Aug. The House Street! 11, 1998) (unpublished) (religious organization can be held liable for retaliation and national origin discrimination); DeMarco v. Holy Cross High Sch. , 4 F.3d 166 (2d Cir. The Bronfenbrenner Theory! 1993) (religious institutions may not engage in age discrimination). [49] EEOC v. Fremont Christian Sch. Current Marketing! , 781 F.2d 1362 (9th Cir. 1986) (religious school violated Title VII and the Equal Pay Act when it provided “head of household” health insurance benefits only to single persons and married men). [50] McClure v. Salvation Army , 460 F.2d 553, 558-60 (5th Cir. 1972); s ee also Hollins v. Methodist Healthcare, Inc. , 474 F.3d 223 (6th Cir.

2007) (applying ministerial exception to The Bronfenbrenner Theory bar claim by resident in hospital’s pastoral care program who alleged disability discrimination); Tomic v. Catholic Diocese of Peoria , 442 F.3d 1036 (7th Cir. 2006) (applying ministerial exception to bar age discrimination claim brought by Catholic Diocese music director who was terminated following a dispute with the bishop’s assistant regarding what to play during the male punishment Easter Mass); Hankins v. Lyght , 441 F.3d 96 (2d Cir. 2006) (applying ministerial exception to bar age discrimination claim); Combs v. Central Texas Annual Conf. of United Methodist Church, 173 F.3d 343 (5th Cir. 1999) (barring claim because court could not determine whether an employment decision concerning a minister was based on Essay, legitimate or illegitimate grounds without entering the constitutionally impermissible realm of internal church management); EEOC v. Catholic Univ. of America , 83 F.3d 455 (D.C. Current! Cir. 1996) (ministerial exception barred Title VII sex discrimination claim brought by tenured member of Catholic University’s department of religious canon law); DeMarco v. Holy Cross High School , 4 F.3d 166 (2d Cir. 1993) (ministerial exception inapplicable to The Bronfenbrenner Theory parochial school teacher’s age discrimination claim because employer’s contention that teacher was terminated specifically for failing to attend Mass and to lead his students in prayers could be evaluated without risk of excessive entanglement between government and religious institution); Guianan v. Roman Catholic Archdiocese of Indianapolis, 42 F. Essay! Supp. 2d 849 (S.D.

Ind. 1998) (ministerial exception inapplicable to parochial school teacher’s age discrimination claim, even though teacher taught at least one class in religion per term, and organized one worship service per month, since vast majority of teacher’s duties involved teaching math, science, and other secular courses). [51] Rayburn v. Gen. The Bronfenbrenner Essay! Conference of Seventh?Day Adventists , 772 F.2d 1164, 1169 (4th Cir. 1985). [52] Rweyemamu v. Cote , 520 F.3d 198 (2d Cir. Examples! 2008) (Title VII race discrimination claim by African-American Catholic priest challenging denial of promotion and subsequent termination was barred by the ministerial exception); Petruska v. Gannon Univ. , 462 F.3d 294 (3d Cir. 2006) (ministerial exception bars Title VII sex discrimination claim by female Catholic chaplain against The Bronfenbrenner Theory Essay, school, alleging that she was forced out as chaplain after she advocated on the house on mango street quotes, behalf of alleged victims of sexual harassment and spoke out against the school’s president regarding alleged sexual harassment and discrimination against female employees); Werft v. Desert Southwest Annual Conf. of the United Methodist Church , 377 F.3d 1099 (9th Cir. Theory! 2004) (ministerial exception barred minister’s claim against church for failure to accommodate his disabilities). Marketing! However, some courts have ruled that the ministerial exception does not bar harassment claims by Theory Essay, ministers, but rather only applies to claims involving matters such as hiring, promotion, and termination. See Elvig v. Calvin Presbyterian Church , 375 F.3d 951 (9th Cir.

2004) (ministerial exception does not bar sexual harassment claim by minister), reh’g denied , 397 F.3d 790 (9th Cir. 2005) (two concurring and three dissenting opinions); Bollard v. Essay On How Technology In George 1984! California Province of the Soc’y of Jesus , 196 F.3d 940 (9th Cir. 1999) (novice’s sexual harassment claim could be maintained without excessive entanglement between church and state because religious order did not offer a religious justification for the alleged harassment, and plaintiff did not seek reinstatement or other equitable relief); Dolquist v. Theory Essay! Heartland Presbytery, 342 F. Supp. 2d 996 (D. Kan. 2004) (First Amendment Establishment and Free Exercise Clauses did not preclude minister from pursuing Title VII sexual harassment claim against her church, because claims did not involve choice of clergy); see also Bryce v. Episcopal Church in the Diocese of Colorado, 289 F.3d 648, 657-59 (10th Cir. 2002) (although “employment decisions may be subject to Title VII scrutiny, where the decision does not involve the church’s spiritual functions,” minister’s Title VII harassment claim was subject to dismissal because it was based on communications protected by the First Amendment under the “church autonomy” doctrine; the doctrine is broader than the ministerial exception and bars civil court review of internal church disputes involving matters of doctrine and church governance). [53] Geary v. Visitation of wall street, Blessed Virgin Mary Parish Sch. , 7 F.3d 324 (3d Cir.

1993) (lay teacher at church?operated elementary school not a minister); Dole v. Theory Essay! Shenandoah Baptist Church , 899 F.2d 1389 (4th Cir. 1990) (lay teachers of street clothing, private religious schools who “perform no sacerdotal functions [nor] serve as church governors [and] belong to no clearly delineated religious order” are not ministers despite their sincere belief that theirs is a ministry); but see EEOC v. Catholic Univ. of America , 83 F.3d 455 (D.C. Cir. 1996) (ministerial exception barred Title VII sex discrimination claim brought by tenured member of Theory Essay, Catholic university’s department of religious canon law). [54] Alicea?Hernandez v. Catholic Bishop of Chicago, 320 F.3d 698 (7th Cir.

2003) (ministerial exception applied to Communications Director who was responsible for crafting the Church’s message to the Hispanic community); EEOC v. Roman Catholic Diocese of Raleigh, 213 F.3d 795 (4th Cir. 2000) (ministerial exception applies to cathedral’s director of marketing, music ministry and part-time music teacher); Rayburn , 772 F.2d at 1168 (ministerial exception applies to associate pastor who had completed seminary training but was not ordained); Starkman v. The Bronfenbrenner Essay! Evans , 198 F.3d 173 (5th Cir. 1999) (ministerial exception barred Americans with Disabilities Act claim by wall street clothing, church choir director). [55] EEOC v. Southwestern Baptist Theological Seminary , 651 F.2d 277, 283 (5th Cir. 1981) (“[w]hile religious organizations may designate persons as ministers for their religious purposes free from any governmental interference, bestowal of such a designation does not control their extra?religious legal status”). [56] Abramson v. The Bronfenbrenner Theory Essay! William Paterson Coll. of N.J. , 260 F.3d 265, 281 (3d Cir. 2001) (prima facie case and evidentiary burdens of an employee alleging religious discrimination mirror those of an employee alleging race or sex discrimination).

A disparate impact analysis could also apply in examples the religion context, particularly in the area of recruitment and hiring. See, e.g., Barrow v. Greenville Indep. Sch. Dist. , 480 F.3d 377 (5th Cir. 2007) (affirming summary judgment, citing lack of statistical evidence, for employer on Title VII claim brought by teacher who asserted policy favoring teachers whose children attended the public schools had a disparate impact on Theory Essay, those whose children attended private school for religious rather than secular reasons). However, because the reasonable accommodation/undue hardship analysis usually applies when a neutral work rule adversely affects religious practices, s ee infra § IV, disparate impact analysis is seldom if ever used in religion cases. [57] 42 U.S.C. Organizational Objectives Essay! § 2000e-2(e)(1); see also §§ I-C and II-D of this document. [58] See, e.g., EEOC v. The Bronfenbrenner! Preferred Mgmt .Corp., 216 F. Supp. 2d 763, 813 (S.D. Ind. 2002) (telling applicant that “[y]ou damned humanists are ruining the The Concept of Alcoholism examples world” and The Bronfenbrenner Essay will “burn in hell forever” raises reasonable inference that the failure to hire her was unlawfully based on religion).

[60] In Noyes v. The House On Mango Street Quotes! Kelly Servs. Inc ., 488 F.3d 1163 (9th Cir. Theory Essay! 2007), the plaintiff alleged “reverse religious discrimination” when she was not promoted because she did not follow the religious beliefs of the house street quotes, her supervisor and management, who were members of a small religious group and favored and Essay promoted other members of the the house street religious group. The court ruled that while the employee did not adhere to a particular religion, the fact that she did not share the employer’s religious beliefs was the basis for the alleged discrimination against her, and The Bronfenbrenner Essay the evidence was sufficient to create an issue for trial on whether the Essay on How is Used for Evil in George 1984 employer’s decision to promote another employee was a pretext for religious discrimination. [61] Tincher v. Wal-Mart Stores , 118 F.3d 1125, 1131 (7th Cir. 1997) (reasonable jury could conclude that employer’s articulated reason for the discharge of a Seventh-day Adventist was pretextual and that the real reason was religious discrimination because of the The Bronfenbrenner Theory Essay inconvenience caused by employee’s inability to work on Saturdays); s ee also Campos v. City of Blue Springs, 289 F.3d 546 (8th Cir. 2002) (evidence supported religiously motivated constructive discharge based on The Concept, plaintiff’s Native American spiritual beliefs); EEOC v. University of Chicago Hospitals , 276 F.3d 326 (7th Cir. The Bronfenbrenner! 2002) (evidence sufficient to proceed to the house on mango street trial in case brought on behalf of Theory Essay, recruiter alleging constructive discharge based on her evangelical religious beliefs); Dachman v. Shalala , 2001 WL 533760 (4th Cir.

May 18, 2001) (unpublished) (Orthodox Jewish employee who was treated in the same manner as non-Jewish employees with similar performance and disciplinary records failed to show that she was terminated because of her religion); Altman v. Minn. Dep’t of Corr. , 251 F.3d 1199, 1203 (8th Cir. 2001) (in case raising both Title VII and First Amendment claims, holding that employer may not discipline employees for religiously based conduct because it is religious in nature if it permits such conduct by other employees when not motivated by religious beliefs). However, not all employer decisions affect a term, condition, or privilege of Technology Orwell’s, employment as required to be actionable as disparate treatment. See, e.g. , Goldmeier v. The Bronfenbrenner Essay! Allstate Ins. Co. , 337 F.3d 629 (6th Cir.

2003) (resignation 53 days prior to effective date of the house on mango quotes, employer’s policy that would have posed conflict with employees’ religious beliefs did not constitute constructive discharge); Shabat v. The Bronfenbrenner Theory! Blue Cross Blue Shield , 925 F. Supp. 977 (W.D.N.Y. 1996) (plaintiff’s contention that he received a promotion only by on How Technology in George, pressuring management did not allege an “adverse” employment action). [62] See infra § IV, Reasonable Accommodation. [63] 42 U.S.C. § 2000e-2(a)(1) (discriminating in hiring, discharge, or otherwise with respect to compensation, terms, conditions, or privileges of employment); see also 42 U.S.C. § 2000e-2(a)(2) (discriminating by limiting, segregating, or classifying employees or applicants in a way which would deprive or tend to deprive employment opportunities or otherwise adversely affect employment status); cf. Ansonia Bd. of Educ. v. Philbrook , 479 U.S. 60, 71 (1986) (a benefit “that is part and parcel of the employment relationship may not be doled out in Theory Essay a discriminatory fashion, even if the employer would be free . . . Current Marketing! not to provide the benefit at all”) (quoting Hishon v. King Spalding , 467 U.S. 69, 75 (1984)). The Bronfenbrenner Essay! However, at least one court has held that a private employer providing company resources to recognized employee “affinity groups” does not violate Title VII by street, denying this privilege to any group promoting or advocating any religious or political position, where the company excluded not only groups advocating a particular religious position but also those espousing religious indifference or opposition.

See Moranski v. General Motors Corp. , 433 F.3d 537 (7th Cir. 2005). [64] Delelegne v. Kinney Sys., Inc., 2004 WL 1281071 (D. Mass. June 10, 2004) (Ethiopian Christian parking garage cashier could proceed to trial on claims of religious harassment and discriminatory termination where he was not allowed to bring a Bible to work, pray, or display religious pictures in Essay his booth, while Somali Muslim employees were permitted to take prayer breaks and to display religious materials in their booths). [65] This fact pattern may also give rise to a denial of accommodation claim. See infra § IV-C-6.

[66] Determining whether religious expression disrupts co-workers or customers is discussed in §§ III-C and IV-C-6, infra . Additionally, in a government workplace, the Clear First Amendment Free Exercise Clause and Establishment Clause may affect the employer’s or employee’s ability to Theory Essay restrict or engage in religious expression. See supra nn.11-15 infra nn.201-203 ; see also Federal Workplace Guidelines , supra n.11, at sections 2-B and 2-E, noting implications of the male punishment Religious Freedom Restoration Act (RFRA) for neutral rules that burden religion in the federal workplace. [67] 42 U.S.C. § 2000e-2(g) (permitting covered entities to discharge or refuse to Essay “hire and employ” or refer an Essay on How is Used for Evil in George Orwell’s, individual who does not meet federal security requirements). Theory Essay! However, the Commission is aware of no statute or order that requires or permits distinctions based on religion. On How For Evil Orwell’s! See infra § IV-B-5 (discussion of security requirements and Title VII’s accommodation obligation). [69] Compare Abrams v. Baylor Coll. of The Bronfenbrenner, Med. Quotes! , 805 F.2d 528 (5th Cir. 1986) (being non-Jewish was not a BFOQ for The Bronfenbrenner Theory a university which had a contract to The Concept examples supply physicians on rotation at a Saudi Arabian hospital when the hospital presented no evidence to support its contention that Saudi Arabia would actually have refused an entry visa to a Jewish faculty member), and Rasul v. District of Columbia , 680 F. The Bronfenbrenner Essay! Supp.

436 (D.D.C. 1988) (Department of Corrections failed to current demonstrate that Protestant religious affiliation was a BFOQ for position as prison chaplain because chaplains were recruited and hired on The Bronfenbrenner, a facility-wide basis and were entrusted with the job of planning, directing, and maintaining a total religious program for all inmates, whatever their respective denominations), with Kern v. Dynalectron Corp ., 577 F. Supp. 1196 (N.D. Tex. 1983) (requirement that pilot convert to Islam was a BFOQ which warranted employer’s refusal to hire him, inasmuch as requirement was not based on street clothing, a preference of contractor performing work in Saudi Arabia, but on the fact that non?Muslim employees caught flying into Mecca would, under Saudi Arabian law, be beheaded), aff’d , 746 F.2d 810 (5th Cir. 1984), and Pime v. Loyola Univ. of Chicago , 803 F.2d 351 (7th Cir. 1986) (although university was not a religious organization under Title VII, the court held that having some Jesuit presence in The Bronfenbrenner Essay philosophy department was a BFOQ since university was founded by male punishment, Jesuits, continues to have Jesuit tradition, and requires all of its undergraduates to The Bronfenbrenner Theory Essay take philosophy).

[70] Faragher v. Boca Raton , 524 U.S. 775, 788 (1998) (harassment claims are actionable on any of the house street, Title VII’s protected bases); Meritor Sav. Bank, FSB v. Essay! Vinson , 477 U.S. 57, 66 (1986) (the same Title VII harassment principle applies whether the harassment is based on race, national origin, religion, or sex); see also Abramson, 260 F.3d at 276; Hafford v. Seidner , 183 F.3d 506, 512 (6th Cir. 1999); Tillery v. ATSI, Inc. , 242 F. Supp. On How Is Used For Evil Orwell’s! 2d 1051, 1063 (N.D. Ala. 2003), aff’d , 97 Fed.

Appx. 906 (11th Cir. 2004) (Table). [71] See Venters v. City of Delphi , 123 F.3d 956 (7th Cir. Theory! 1997) (employee who was terminated after she disagreed with supervisor’s religious beliefs raised a triable Title VII harassment claim based on two separate theories of harassment liability: that a “tangible employment benefit” was conditioned upon of Alcoholism examples acquiescing to her supervisor’s religious beliefs, and also that a hostile work environment was created). [72] Meritor Sav. The Bronfenbrenner Theory! Bank, 477 U.S. at The Concept Essay examples, 66 (1986) (prohibition on discrimination “in the terms, conditions, or privileges of employment” requires employers to maintain a workplace free from harassment based upon protected status).

[73] See, e.g., Venters , 123 F.3d at The Bronfenbrenner Essay, 964 (employee established that she was discharged on on How is Used for Evil Orwell’s 1984, the basis of her religion after supervisor, among other things, repeatedly called her “evil” and stated that she had to share his Christian beliefs in order to The Bronfenbrenner Theory be a good employee). [74] Many of the example’s facts are taken from Sattar v. Motorola, Inc ., 138 F.3d 1164 (7th Cir. 1998). However, in Sattar the plaintiff did not prevail because the current marketing plaintiff failed to prove that his discharge was linked to the harassment by his former supervisor. [75] Pederson v. Casey’s Gen. Stores, Inc. , 978 F. Theory Essay! Supp.

926 (D. Current Marketing! Neb. 1997) (employer’s refusal to accommodate employee’s need to have Easter day off, while knowing that she could not compromise her religious needs and where it would not have posed an undue hardship, amounted to Essay constructive discharge in violation of Title VII). [76] Venters , 123 F.3d at 972 (“the accommodation framework . Clear Objectives! . . has no application when the employee alleges that he was fired because he did not share or follow his employer’s religious beliefs”). [77] Faragher , 524 U.S. at 788 (environmental harassment claims are actionable on any of Title VII’s protected bases); Meritor Sav. Bank, 477 U.S. at 67 (same); see also EEOC Enforcement Guidance: Vicarious Employer Liability for Unlawful Harassment by The Bronfenbrenner Essay, Supervisors (1999), available at https://www.eeoc.gov/policy/docs/harassment.html. [78] Harris v. The House Street! Forklift Sys., Inc. , 510 U.S. Essay! 17, 21 (1993). [79] Meritor Sav. Bank, 477 U.S. at 67. [80] Marcus v. West , 2002 WL 1263999, *11 (N.D.

Ill. June 3, 2002) (mistreatment of Sanctified Pentecostal Christian employee was not because of religion; supervisor mistreated all of her employees and had poor management and interpersonal skills). [81] Turner v. Wall Clothing! Barr , 811 F. Supp. 1, 2 (D.D.C. 1993) (hostile environment created where Jewish employee was subjected to Essay a “joke” about the Holocaust, denied opportunity to work overtime, and ridiculed as a “turnkey”; although the latter two incidents did not refer to religion, the facts showed that he was singled out for such treatment because of male punishment, his religion). [82] See EEOC v. Sunbelt Rentals, Inc. , 521 F.3d 306 (4th Cir. 2008) (reversing summary judgment for Theory the employer and remanding the case for trial, the court ruled that a reasonable fact finder could conclude that a Muslim employee who wore a kufi as part of his religious observance was subjected to hostile work environment religious harassment when fellow employees repeatedly called him “Taliban” and “towel head,” made fun of his appearance, questioned his allegiance to the United States, suggested he was a terrorist, and made comments associating all Muslims with senseless violence); EEOC v. WCM Enter., Inc. , 496 F.3d 393 (5th Cir. Male Punishment! 2007) (reversing summary judgment for the employer and The Bronfenbrenner Theory remanding the case for trial, the black wall street court ruled that a reasonable fact finder could conclude that harassment initiated after September 11, 2001, against a car salesman who was born in Theory Essay India and is a practicing Muslim was severe or pervasive and motivated by his national origin and religion). In Sunbelt , the male punishment Fourth Circuit Court of Appeals held: “we cannot regard as ‘merely offensive,’ and thus ‘beyond Title VII's purview,’ Harris , 510 U.S. at 21, constant and repetitive abuse founded upon The Bronfenbrenner Theory Essay misperceptions that all Muslims possess hostile designs against the United States, that all Muslims support jihad, that all Muslims were sympathetic to the 9/11 attack, and that all Muslims are proponents of radical Islam.” 521 F.3d at 318. [83] See Abramson, 260 F.3d at 279 (supervisor’s criticism of professor’s refusal to work on her Sabbath, scheduling meetings on Jewish holidays, and charging her for leave on those holidays could be found to have “infected [professor’s] work experience” because of her religion). [84] Henson v. City of Dundee , 682 F.2d 897, 903 (11th Cir.

1982). [86] See WCM Enter. , 496 F.3d at 400-01 (plaintiff’s religious and national origin harassment claim was based on marketing, having been referred to as a “Muslim extremist,” and The Bronfenbrenner Theory constantly called “Taliban” among other terms); Khan v. United Recovery Sys., Inc., 2005 WL 469603 (S.D. Tex. The House On Mango Street! 2005) (plaintiff’s religious harassment claim was based on alleged comments by The Bronfenbrenner, co-worker that court characterized as “malicious and vitriolic,” including that all Muslims are terrorists who should be killed, that he wished “all these Muslims were wiped off the face of the earth,” that plaintiff might get shot for wearing an “Allah” pendant, and questioning plaintiff about what was being taught at her mosque and whether it was “connected with terrorists”; in addition, plaintiff alleged that her supervisor placed newspaper articles on her desk about mosques in Afghanistan that taught terrorism, along with a note telling her to come into his office and justify such activity). [87] Human resources professionals who responded to a survey by the Society for Human Resource Management (SHRM) and the Tanenbaum Center for Interreligious Understanding reported that 19% of the employees in their organizations engaged in proselytizing to co-workers. While 32% of the employees perceived increased cooperation and communication within their organizations due to acceptance of religious diversity, 9% of the employees felt harassed by street, co-workers who expressed their religious beliefs.

Religion in the Workplace Survey, at 24 (Society for Human Resource Management, 2001) (executive summary and The Bronfenbrenner information on the house street, obtaining report available at http://www.tanenbaum.org/research.html (last visited July 2, 2008)). [88] Venters , 123 F.3d at 976 (because the employee made clear her objection to the comments by telling her supervisor he had “crossed the line,” she established that the Theory comments were unwelcome). [89] Id. (“whatever questions there might have been as to whether Venters welcomed these discussions were answered as of th[e] date [that she told him he had crossed the line]”). [90] Harris , 510 U.S. at marketing, 21-22; Faragher , 524 U.S. at 788 (“We have made it clear that conduct must be extreme to amount to The Bronfenbrenner Theory a change in the terms and conditions of employment.”). [91] Faragher , 524 U.S. at Objectives Essay, 787-88; Oncale v. Sundowner Offshore Servs. , 523 U.S. Essay! 75, 82-83 (1998) (“[t]he real social impact of workplace behavior often depends on a constellation of surrounding circumstances, expectations, and relationships which are not fully captured by a simple recitation of the words used or the current marketing physical acts performed”); Harris , 510 U.S. at The Bronfenbrenner Theory Essay, 23.

[92] Bains LLC v. Black Street! Arco Prods. Co ., 405 F.3d 74 (9th Cir. 2005) (upholding finding of liability for harassment in violation of 42 U.S.C. § 1981 where Sikh employees were regularly called “rag-heads” and Essay “towel-heads,” and were asked to clean up fuel spills with their turbans). [93] Williams v. Gen. Motors Corp ., 187 F.3d 553, 564 (6th Cir. 1999) (“a work environment viewed as a whole may satisfy the legal definition of an abusive work environment, for purposes of male punishment, a hostile environment claim, even though no single episode crosses the Title VII threshold”). [94] Jones v. The Bronfenbrenner Essay! United Space Alliance , 2006 WL 250761 (11th Cir. Feb. 3, 2006) (unpublished) (plaintiff, a member of the Technology 1984 Apostolic/Pentecostal faith, alleged that he was subjected to a hostile work environment based on religion when his manager made derogatory remarks to him based on his religion, a co-worker removed from the community bulletin board a flyer describing events at the plaintiff’s church, the plaintiff’s manager told him to remove the Theory lanyard for clothing his identification badge because it had “Jesus” on it, his manager told him not to leave his Bible on The Bronfenbrenner Theory, his desk, he was asked to turn down the religious music that he played at marketing, work, and he was accused of having a conflict of interest with the space program because he was a pastor; in finding there was insufficient evidence of a hostile work environment, court ruled that the alleged incidents were not objectively severe or pervasive because none occurred on a repeated basis, none were physically threatening or humiliating, and none interfered with the Essay plaintiff’s job performance).

[95] EEOC v. AKZ Mgmt., Inc. , Civil Action No. 07-8356 (S.D.N.Y. consent decree filed Sept. Current Marketing! 26, 2007) (settlement of religious harassment and disparate treatment claims on behalf of The Bronfenbrenner Essay, employees who were pressured by management to practice or conform to Scientology). The Concept Of Alcoholism Essay! See Johnson v. Spencer Press of Maine, Inc ., 364 F.3d 368 (1st Cir. 2004) (jury properly found harassment was severe and The Bronfenbrenner Theory pervasive where supervisor repeatedly insulted plaintiff and mocked his religious beliefs, and threatened him with violence); Sattar , 138 F.3d at 1167 (employee harassed with a barrage of e-mails with dire warnings of the divine punishments that awaited those who refuse to follow Islam) ; Preferred Mgmt. Corp ., 216 F. Supp. Wall! 2d 763 (Christian employer violated Title VII by requiring employees to conform to her views). [96] Harris , 510 U.S. at 21; Meritor , 477 U.S. at 64.

[97] Harris , 510 U.S. at 22 (“even without regard to these tangible effects, the The Bronfenbrenner Theory Essay very fact that the discriminatory conduct was so severe or pervasive that it created a work environment abusive to employees because of their race, gender, religion, or national origin offends Title VII’s broad rule of workplace equality . . . . Certainly Title VII bars conduct that would seriously affect a reasonable person’s psychological well?being, but the statute is not limited to such conduct”); s ee Dey v. Colt Const. Dev. Male Punishment! Co ., 28 F.3d 1446, 1454-55 (7th Cir. 1994) (“The mention in Harris of an unreasonable interference with work performance was not intended to penalize the The Bronfenbrenner Theory Essay employee who possesses the dedication and Organizational Objectives fortitude to complete her assigned tasks even in The Bronfenbrenner Essay the face of offensive and the house on mango street quotes abusive [conduct] . . . . As Justice Scalia separately explained in Essay Harris , the test under Title VII ‘is not whether work has been impaired, but whether working conditions have been discriminatorily altered.’”) (citation omitted). [98] See Harris , 510 U.S. at 23 (“whether an environment is ‘hostile’ or ‘abusive’ can be determined only by looking at The Concept Essay, all the circumstances . . . The Bronfenbrenner Theory! ; no single factor is male punishment, required”). [99] Faragher , 524 U.S. at 788 (citing Oncale , 523 U.S. at Theory, 80); Sheikh v. The House Street! Indep.

Sch. Dist. 535 , 2001 WL 1636504 (D. Minn. Essay! Oct. 18, 2001) (a Muslim employee who was ostracized by colleagues because he refused to examples shake hands with female colleagues did not suffer a materially adverse change in the terms and Essay conditions of employment). [100] See Marcus , 2002 WL 1263999 at *11 (asking very religious employee to swear on a Bible to resolve differences with a colleague and telling her that people did not like her “church lady act” are isolated incidents that were not severe or pervasive enough to create a hostile work environment); Sublett v. Male Punishment! Edgewood Universal Cabling Sys., Inc. , 194 F. Supp. 2d 692, 703 (S.D. Ohio 2002) (supervisor’s single comment to Rastafarian employee that “those dread things” made him look too “radical” was not sufficiently severe to The Bronfenbrenner Theory Essay create a hostile environment). [101] Cf.

Tessler v. KHOW Radio, Inc. , 1997 WL 458489 at *8 (D. Colo. Apr. 21, 1997). [102] Cf. Brown v. Polk County , 61 F.3d at 656-57 (it did not pose an undue hardship for employer to accommodate supervisor’s sporadic and voluntary prayers during workplace meetings). [103] Williams , 187 F.3d at 563 (in determining whether the current alleged conduct rises to The Bronfenbrenner Essay the level of severe or pervasive, a court should consider the factual “totality of the circumstances”; using a “holistic perspective is necessary, keeping in mind that each successive episode has its predecessors, that the impact of the separate incidents may accumulate, and that the work environment created thereby may exceed the sum of the on How is Used Orwell’s individual episodes”). [104] Cf . Johnson v. Spencer Press of Maine, Inc. , 364 F.3d 368 (1st Cir.

2004) (affirming jury verdict for The Bronfenbrenner Theory Essay plaintiff on religious harassment claim, court noted that plaintiff testified supervisor who made ongoing derogatory remarks about plaintiff’s religion also once put the point of a knife under plaintiff’s chin, in addition to threatening to kill him with a hand grenade, run him over with a car, and shoot him with a bow and street clothing arrow). [105] As with any harassment claim, employer liability will depend on whether the employee can show, in a case of co-worker harassment, that the employer knew or should have known of the misconduct and failed to The Bronfenbrenner Theory take prompt and appropriate corrective action. Additionally, in the case of harassment by non-employees, employer liability will depend on whether the employer had control over such individuals’ misconduct. For standards regarding liability for current harassment by supervisors, see EEOC Enforcement Guidance: Vicarious Employer Liability for Essay Unlawful Harassment by Supervisors (1999), available at current marketing, https://www.eeoc.gov/policy/docs/harassment.html. [106] See Peters v. Renaissance Hotel Operating Co. , 307 F.3d 535 (7th Cir. Theory Essay! 2002) (the impact of on mango, actions not directed at a complaining employee is not as great as the The Bronfenbrenner Theory Essay impact of harassment directed at him and the combined impact of all the current marketing comments was not severe or pervasive enough to create an The Bronfenbrenner Essay, unlawful hostile environment). [107] Burlington Indus., Inc. v. Ellerth , 524 U.S. The Concept Examples! 742, 762 (1998); Faragher , 524 U.S. at 788; Preferred Mgmt. Corp. The Bronfenbrenner Theory! , 216 F. Supp. 2d at Organizational, 839 n.25 (employer’s anti-harassment policy was inadequate because it did not include a prohibition on religious harassment, employer did not provide training on The Bronfenbrenner Essay, religious harassment, and managers responded to complaints of religious harassment by requiring employees to participate in The Concept of Alcoholism Essay a training program based on religious principles). However, under agency principles an employer is automatically liable for hostile work environment harassment even if it does not result in a tangible employment action if “the agent’s high rank in the company makes him or her the employer’s alter ego.” Ellerth , 524 U.S. at 758.

If the harasser is of a sufficiently high rank to fall “within that class of an employer organization’s officials who may be treated as the The Bronfenbrenner Theory organization’s proxy,” which would include officials such as a company president, owner, partner, or corporate officer, the current marketing harassment is The Bronfenbrenner Essay, automatically imputed to the employer and no affirmative defense can be raised. Faragher , 524 U.S. at Organizational Clear Objectives Essay, 789 see also EEOC Enforcement Guidance: Vicarious Employer Liability for Unlawful Harassment by Theory, Supervisors (1999), https://www.eeoc.gov/policy/docs/harassment.html. [108] Sheikh , 2001 WL 1636504 at current marketing, *5 (employer not liable because it took steps to The Bronfenbrenner Theory Essay stop alleged harassment of Muslim employee by his co-workers); see Guidelines on Discrimination Because of National Origin , 29 C.F.R. § 1606.8(d) (employer liable for quotes co-worker harassment about which it knew or should have known and failed to act). [109] Cf. Essay! Powell v. Street! Yellow Book USA, Inc. , 445 F.3d 1074 (8th Cir. 2006) (employer not liable for religious harassment of plaintiff because upon learning of The Bronfenbrenner, her complaints about a co-worker’s proselytizing, the employer promptly held a meeting and Organizational Objectives told the co-worker to stop discussing religion matters with plaintiff, and there was evidence that the company continued to monitor the situation to ensure that the co-worker did not resume her proselytizing). [110] 29 C.F.R. § 1606.8(e). Berry v. Delta Airlines, Inc. , 260 F.3d 803 (7th Cir.

2001) (employer not liable for alleged sexual harassment of its female employee by Theory Essay, a male contractor because it promptly investigated the allegations, requested a change in the contractor’s shift so that he would not have contact with the employee, and asked that all contractors be required to view sexual harassment training video). [111] When asked whether they had discussed religion in The Concept Essay examples the workplace in The Bronfenbrenner Theory the past twenty-four hours, 48% of black wall, Americans answered yes. See George Gallup, Jr. Timothy Jones, The Next American Spirituality: Finding God in the Twenty-First Century , at 72 (Cook Communication Ministries 2000). [112] Employers are permitted to exercise their religion to the extent that such exercise does not infringe on their employees’ religious beliefs. Townley , 859 F.2d at 621 (“Where the religious practices of The Bronfenbrenner Theory Essay, employers . . . and employees conflict, Title VII does not, and could not, require individual employers to abandon their religion. Rather, Title VII attempts to reach a mutual accommodation of the conflicting religious practices.”). [113] In a survey conducted by the Tanenbaum Center for Interreligious Understanding, 66% of Organizational Objectives Essay, employees surveyed reported that they had witnessed religious discrimination in the workplace. The Bronfenbrenner! Religious Bias in the Workplace: The Employee’s View (Tanenbaum Center for wall street clothing Interreligious Understanding, 1999) (executive summary available at http://www.tanenbaum.org/research_1999.html ) (last visited July 2, 2008).

[114] See Examples 15, 18-19, 27-28, 49-50. For a further discussion of the circumstances under which reasonable accommodation of The Bronfenbrenner Theory Essay, religious expression in the workplace, including proselytizing, may be denied because it poses an undue hardship on of Alcoholism Essay, the conduct of the The Bronfenbrenner employer’s business, see infra § IV-C-6. [115] Cf. Bodett v. CoxCom, Inc. , 366 F.3d 736 (9th Cir. 2004) (employer prevailed on claim brought by terminated employee for disparate treatment based on the house on mango quotes, religion; employee’s violation of employer’s anti-harassment policy was a legitimate nondiscriminatory reason for termination, even if the violations were motivated by the employee’s religious beliefs). [116] 42 U.S.C. § 2000e(j); Commission Guidelines , 29 C.F.R. § 1605.2(b). [117] Compare Trans World Airlines, Inc. v. Hardison, 432 U.S. 63, 84 (1977) (interpreting Title VII “undue hardship” standard, with 42 U.S.C. The Bronfenbrenner Essay! § 12111(10)(A) (defining ADA “undue hardship” standard); see infra n.139. [118] Protos v. Volkswagen of Am., Inc., 797 F.2d 129, 136 (3d Cir.

1986) (“[t]his is . Male Punishment! . . part of The Bronfenbrenner, our ‘happy tradition’ of male punishment, avoiding unnecessary clashes with the Theory dictates of conscience”) (citation omitted). [119] See Seshadri v. Kasraian , 130 F.3d 798, 800 (7th Cir. 1997) (employee who seeks accommodation need not belong to an established church but cannot preclude inquiry into whether he has a religion); Chrysler Corp. v. Objectives! Mann , 561 F.2d 1282, 1285 (8th Cir. 1977) (observing that the plaintiff “did little to acquaint Chrysler with his religion and its potential impact upon his ability to perform his job”); s ee also Redmond , 574 F.2d at 902 (relying on Mann , concluding that “an employee who is The Bronfenbrenner, disinterested in informing his employer of male punishment, his religious needs ‘may forego the right to have his beliefs accommodated by The Bronfenbrenner Theory Essay, his employer’”). [120] See Heller , 8 F.3d at 1439 (employee’s request for leave to participate in religious conversion ceremony of his wife and Essay on How for Evil in George 1984 children was sufficient to place employer on notice that this was pursuant to a religious practice or belief; an The Bronfenbrenner Theory Essay, employer need have “only enough information about an employee's religious needs to permit the employer to male punishment understand the existence of a conflict between the employee's religious practices and the employer's job requirements”); Brown v. Polk County , 61 F.3d at 654 (even though employee did not explicitly ask for a religious accommodation, court held employer was on Theory Essay, notice of the need for accommodation given that it reprimanded employee for engaging in known religious activities); Hellinger v. Eckerd Corp., 67 F. Supp. Black Wall Street! 2d 1359 (S.D. Fla. 1999) (although applicant did not himself inform employer about his religious conflict on his job application, employer had learned when he contacted applicant’s former supervisor for a reference that the applicant had refused to sell condoms at prior job due to Theory a religious objection, and was therefore on current, notice); cf. Wessling , 554 F. The Bronfenbrenner! Supp. at 552 (employee’s request to leave work early in order to arrive early for a Christmas play at her church in order to decorate and Essay Technology Orwell’s receive children was insufficient to place her employer on notice of a religious practice; it was more in the nature of a social activity or family obligation that happened to be associated with the church). [121] Cary v. Carmichael, 908 F. Supp.

1334 (E.D. The Bronfenbrenner! Va. Black Street! 1995), aff’d , 116 F.3d 472 (4th Cir. The Bronfenbrenner Theory! 1997); see also Elmenayer v. The Concept Essay! ABF Freight Sys. , 2001 WL 1152815 (E.D.N.Y. Sept. 20, 2001) (employer not liable for disciplining employee for tardiness where employee failed until after his discharge to explain that tardiness was because he attended a prayer service), aff’d on other grounds , 318 F.3d 130 (2d Cir. 2003). [122] Notwithstanding the different legal standards for determining when a failure to accommodate poses an undue hardship under Title VII and the ADA, see supra n.117, courts have endorsed a cooperative information-sharing process between employer and employee, similar to the “interactive process” used for disability accommodation requests under the ADA. See, e.g., Thomas v. Nat’l Ass’n of Letter Carriers , 225 F.3d 1149, 1155 n.5 (10th Cir. The Bronfenbrenner Theory Essay! 2000) (“the [ADA] ‘interactive process’ rationale is equally applicable to Essay on How Orwell’s the obligation to offer a reasonable accommodation to an individual whose religious beliefs conflict with an employment requirement”); Elmenayer , 2001 WL 1152815, at Theory, *5 (same), aff’d on other grounds , 318 F.3d 130 ; Kenner v. Domtar Indus., Inc ., 2006 WL 662466 (W.D.

Ark. Mar. Male Punishment! 13, 2006) (“Title VII’s reasonable accommodation provisions contemplate an interactive process, with cooperation between the employer and the employee, but which must be initiated by the employer”); Cosme v. The Bronfenbrenner Theory! Henderson , 2000 WL 1682755, *6 (S.D.N.Y. Nov. 9, 2000) (“[t]he process of finding a reasonable [religious] accommodation is intended to Essay Technology is Used in George 1984 be an Theory Essay, interactive process in The Concept Essay which both the employer and employee participate”), aff’d , 287 F.3d 152 (3d Cir. The Bronfenbrenner Theory! 2002); cf. Essay On How Technology Is Used For Evil In George Orwell’s 1984! Ansonia Bd. of The Bronfenbrenner Theory Essay, Educ. , 479 U.S. at wall, 69 (“courts have noted that ‘bilateral cooperation is appropriate in the search for an acceptable reconciliation of the needs of the employee’s religion and the exigencies of the employer’s business’”) (quoting Brener v. Diagnostic Ctr. Hosp. , 671 F.2d 141, 145-46 (5th Cir. 1982)). [123] EEOC v. Arlington Transit Mix, Inc ., 957 F.2d 219, 222 (6th Cir.

1991) (“[a]fter failing to pursue [a voluntary waiver of seniority rights] or any other reasonable accommodation, the company is in The Bronfenbrenner no position to argue that it was unable to The Concept examples accommodate reasonably [plaintiff’s] religious needs without undue hardship on the conduct of its business”); EEOC v. Ithaca Indus., Inc. , 849 F.2d 116 (4th Cir. 1988) (employer’s failure to attempt to accommodate violated Title VII). [124] Shelton v. Univ. of Med. Dentistry of N.J. , 223 F.3d 220, 227 (3d Cir. 2000) (by refusing to Essay meet with employer’s human resources department, employee failed to satisfy her duty to cooperate in finding a reasonable accommodation). [125] Ansonia Bd. of Educ. , 479 U.S. at 69 (employer could satisfy its obligation by offering an alternative reasonable accommodation to the particular one proposed by the employee); Brener , 671 F.2d at 146 (“employee has a correlative duty to make a good faith attempt to marketing satisfy his needs through means offered by the employer”); EEOC v. AutoNation USA Corp ., 2002 WL 31650749 (9th Cir.

Nov. 22, 2002) (unpublished) (employer satisfied its initial burden by showing that it suggested possible accommodations but that the employee short-circuited the process by resigning without first giving the proposed accommodations the opportunity to The Bronfenbrenner Theory be implemented or tested); Chrysler Corp. v. Mann , 561 F.2d 1282, 1286 (8th Cir. 1977) (where employee “will not attempt to accommodate his own beliefs through the means already available to him or cooperate with his employer in its conciliatory efforts, he may forego the right to have his beliefs accommodated”), cert. denied , 434 U.S. 1039 (1978). [126] See also Bushouse , 164 F. Supp. 2d 1066. [127] Id. at 1078 n.18 (court held that union’s refusal to provide accommodation unless employee produced independent corroboration that his accommodation request was motivated by a sincerely held religious belief did not violate Title VII’s religious accommodation provision, but cautioned that the Organizational Clear Essay holding was limited to “the facts and circumstances of the present case” and that “the inquiry [into sincerity] and scope of that inquiry will necessarily vary based upon the individual requesting corroboration and the facts and The Bronfenbrenner Theory circumstances of the request”).

[128] EEOC v. Tyson Foods, Inc ., Civil Action No. 99-5126 (W.D. Ark. consent decree entered Aug. 14, 2000) (settlement of Title VII challenge to employer’s policy of requiring a letter from a church in support of all accommodation requests). [129] See EEOC v. Ilona of Clear, Hungary, Inc. , 108 F.3d 1569 (7th Cir. Theory Essay! 1997) (employer did not satisfy reasonable accommodation requirement by offering to let Jewish employees take off a day other than Yom Kippur, because that would not eliminate the marketing conflict between religion and Essay work); Shelton , 223 F.3d at current marketing, 225 (citing Ansonia Bd. of The Bronfenbrenner Theory Essay, Educ ., 479 U.S. at 68-69) (employer’s accommodation of granting unpaid leave for religious observance instead of allowing use of paid personal days provided for in collective bargaining agreement (CBA), was a reasonable accommodation as long as use of the wall street clothing paid days was not allowed for all purposes other than religious ones); cf. Bruff v. N. Mississippi Health Serv., Inc., 244 F.3d 495 (5th Cir.

2001) (hospital offered reasonable accommodation as a matter of law where it offered plaintiff who could not be accommodated in her current position thirty days and the assistance of its in-house employment counselor to find another position where the conflict between the duties and religious beliefs could be eliminated or reduced); EEOC v. Universal Mfg. Corp ., 914 F.2d 71 (5th Cir. 1990) (employer’s offer of five working days off or alternatively seven days off if employee worked one shift within that seven days, did not satisfy obligation to offer reasonable accommodation of her religious practice of refraining from work during seven-day religious festival, where employer did not show undue hardship). [130] See infra nn.131-133. Essay! Under the Commission’s approach, a reasonable accommodation must eliminate the conflict between work and religion unless such accommodation would impose an undue hardship, i.e. , more than de minimis cost or disruption on the employer’s business. Some courts have approached the issue of what is a reasonable accommodation in a manner that conflicts with longstanding Commission and judicial precedent. See, e.g., EEOC v. Firestone Fibers Textiles Co. , 515 F.3d 307 (4th Cir. 2008) (analyzing reasonableness of Essay is Used, proposed accommodation based on facts typically considered as part of undue hardship analysis); Sturgill v. United Parcel Service, Inc. , 512 F.3d 1024 (8th Cir. 2008) (noting that terminology which describes a reasonable accommodation as one that eliminates any work-religion conflict is imprecise, because it may incorrectly imply that reasonableness is Theory Essay, determined as a matter of marketing, law without regard to The Bronfenbrenner Theory Essay the facts of an individual case, or that an employer is current, not permitted to Theory choose among alternative accommodations, or that even accommodations which conflict with a CBA or otherwise pose an wall street, undue hardship must be granted). The Commission’s approach is more straightforward and The Bronfenbrenner more in keeping with the purpose of the house quotes, Title VII’s accommodation requirement. Concerns about Essay issues such as conflicts with a union contract or burdens on male punishment, other employees’ settled expectations can and should be addressed in Essay the context of whether or not it would impose an undue hardship.

Moreover, the employer need not grant an employee’s requested reasonable accommodation if the employer wishes instead to offer an alternative accommodation of its own choosing that also would eliminate the work-religion conflict and does not adversely affect the employee’s terms, conditions, or privileges of employment. [131] In Ansonia Bd. of Educ., 479 U.S. at 68-69, the Court held that an employer has met its obligation under § 701(j) of Title VII when it demonstrates that it has offered a reasonable accommodation to the employee; “where the employer has already reasonably accommodated the employee’s religious needs, the statutory inquiry is at an end. Essay! The employer need not further show that each of the employee’s alternative accommodations would result in undue hardship.” Cf. Opuku?Boateng v. California, 95 F.3d 1461 (9th Cir. Theory! 1996) (where employer offered no accommodation and employee offered several possibilities, such as scheduling him instead for other equally undesirable shifts and adopting a system of voluntary or mandatory shift trades, the employer had to accept one of the employee’s proposals unless doing so would create an undue hardship). This section addresses only whether the accommodation was reasonable. An employer that does not provide a reasonable accommodation may nevertheless avoid liability if it shows that providing the accommodation would pose an undue hardship. Undue hardship is addressed below in § IV.B. [132] Ansonia Bd. of Educ. The Concept Of Alcoholism! , 479 U.S. at 70-71 (“requiring [an employee] to Theory Essay take unpaid leave for holy day observance rather than use personal paid leave days provided for male punishment under CBA would generally be a reasonable accommodation” because it has “no direct effect upon either employment opportunities or job status,” but “unpaid leave is not a reasonable accommodation when paid leave is The Bronfenbrenner Essay, provided for all purposes except religious ones . . . [s]uch an arrangement would display a discrimination against religious practices that is the antithesis of reasonableness”).

In cases involving requests for schedule changes or leave as an accommodation, an current, employer does not have to provide paid leave as an accommodation beyond that otherwise available to the employee, but may have to provide unpaid leave as an accommodation if it would not pose an undue hardship. [133] Commission Guidelines , 29 C.F.R. § 1605.2(c)(2)(ii) (“when there is more than one means of accommodation that would not cause undue hardship, the employer or labor organization must offer the Theory alternative which least disadvantages the current individual’s employment opportunities”). The Commission’s guidelines do not require an employer to accept any alternative favored by the employee, and, thus, are not inconsistent with Ansonia . In fact, the Court in Ansonia recognized that the limitation in the Commission’s guidelines that alternatives must be considered if they will not “disadvantage an individual’s employment opportunities” distinguished the Commission’s position from the position of the Second Circuit that was rejected in Ansonia . 470 U.S. at 69 n.6. Appellate courts in the wake of Ansonia have, as the Commission’s guidelines instruct, evaluated whether employer accommodations had a negative impact on The Bronfenbrenner Essay, the individual’s employment opportunities. See Cosme v. Henderson , 287 F.3d 152, 160 (2d Cir. 2002) (an accommodation might be unreasonable if it imposes a “significant work-related burden on the employee without justification”); Wright v. Clear Objectives! Runyon , 2 F.3d 214, 217 (7th Cir. 1993) (whether an The Bronfenbrenner Essay, accommodation is clothing, reasonable requires a more searching inquiry if an employee, “in order to accommodate his religious practices, had to accept a reduction in pay or some other loss of benefits”). [134] Smith v. Pyro Mining Co. , 827 F.2d 1081, 1085 (6th Cir. 1987) (quoting Redmond , 574 F.2d at 902-03). [135] Baker v. Home Depot , 445 F.3d 541 (2d Cir.

2006) (employer’s offer to The Bronfenbrenner Theory schedule employee to work in the afternoon or evenings on Sundays, rather than the mornings, was not a “reasonable” accommodation under Title VII where employee’s religious views required not only male punishment, attending Sunday church services but also refraining from The Bronfenbrenner work on Sundays). [136] Wilshin v. Allstate Ins. Marketing! Co., 212 F. The Bronfenbrenner Theory Essay! Supp. 2d 1360 (M.D. Ga. 2002) (employer satisfied obligation to accommodate employee’s Saturday Sabbath observance by offering Sunday work hours instead, notwithstanding that employee would have preferred weekday hours). [137] Shelton , 223 F.3d at the house on mango street, 226 (state hospital’s offer to transfer nurse to newborn intensive care unit was reasonable accommodation for her religious beliefs which prevented her from assisting in emergency procedures to terminate pregnancies, where nurse presented no evidence that transfer would affect her salary or benefits); see also Rodriguez v. City of Theory Essay, Chicago, 156 F.3d 771 (7th Cir.

1998) (city’s offer to allow police officer to exercise his right under CBA to transfer to a district with no abortion clinics resolved his religious objection to being assigned to black street guard such facilities; Title VII did not compel employer to instead grant his preferred accommodation of remaining in his district but being relieved of such assignments); Wright , 2 F.3d at Theory Essay, 217 (7th Cir. On How Technology! 1993) (employer reasonably accommodated employee by suggesting he exercise his rights under CBA to bid on jobs that would have eliminated the conflict between work and religion). [138] Townley , 859 F.2d at 614 n.5 (citing Am. The Bronfenbrenner Theory! Postal Workers Union v. Postmaster , 781 F.2d 772, 774?75 (9th Cir. 1986)); see also Rodriguez v. City of Chicago, 1996 WL 22964, at *3 (N.D. Organizational Clear Objectives Essay! Ill. Jan. 12, 1996) (rejecting employer’s argument that a threat of adverse action is not enough to state a claim; “it is nonsensical to suggest that an employee who, when forced by his employer to choose between his job and his faith, elects to avoid potential financial and/or professional damage by The Bronfenbrenner Theory, acceding to his employer’s religiously objectionable demands has not been the victim of Essay on How, religious discrimination”).

Moreover, a denial of accommodation claim can be brought if the employer could have provided an accommodation absent undue hardship that did not disadvantage a term, condition, or privilege of The Bronfenbrenner, employment, but did not do so. For example, if a Muslim employee is black wall street clothing, transferred to non-customer service position because she refuses to stop wearing a religiously mandated headscarf, she states a claim for denial of accommodation under Title VII. Draper v. U.S. Pipe Foundry Co. , 527 F.2d 515 (6th Cir. 1975) (resorting to transfer where accommodation was possible in employee’s current position is actionable as denial of reasonable accommodation). However, an employer need not accommodate an employee who chooses to resign before notifying the employer of the The Bronfenbrenner Essay need for accommodation or fails to cooperate with the male punishment employer in The Bronfenbrenner Essay the accommodation process. See, e.g., Goldmeier v. Allstate Ins. Co. , 337 F.3d 629 (6th Cir. 2003) (resignation 53 days prior to effective date of employer’s policy that would have posed conflict with employees’ religious beliefs did not constitute constructive discharge); Lawson v. Washington , 296 F.3d 799 (9th Cir. 2002) (Jehovah’s Witness who quit state patrol rather than salute the current flag or take an oath in Theory Essay violation of his religious beliefs was not constructively discharged and thus was not subject to an adverse employment action where, rather than request accommodation, he informed employer that he was resigning due to Essay on How Technology is Used for Evil his religious conflict); Shelton v. Univ. of Med.

Dentistry of N.J. , 223 F.3d 220, 227 (3d Cir. 2000) (employee who refused to meet with employer’s human resources department to pursue alternative accommodations could not argue that accommodation employer offered was not reasonable). [139] Townley , 859 F.2d at 614 n.5 ; Rodriguez, 1996 WL 22964. [140] Cooper , 15 F.3d at 1379 (Seventh-day Adventist employee’s need for accommodation to observe Sabbath had changed in the 17 months since employer had last scheduled her to work on a Friday night or Saturday; her “undisputed testimony was that her faith and commitment to Essay her religion grew during this time”). [141] See, e.g., Hardison, 432 U.S. at 84. This “more than de minimis ” Title VII undue hardship standard is Organizational, substantially lower than the ADA undue hardship standard, which requires employers to The Bronfenbrenner show that the current marketing accommodation would cause “significant difficulty or expense.” [142] Both the Essay statute, at 42 U.S.C. Wall Street! § 2000e(j), and the Commission Guidelines , at 29 C.F.R. Theory Essay! § 1605.2(b), require an employer to reasonably accommodate an of Alcoholism, employee’s or applicant’s religious beliefs and practices “unless the employer demonstrates” that doing so would pose an undue hardship. Even under the Fourth Circuit’s decision in EEOC v. Firestone , and the Eighth Circuit’s decision in Sturgill v. United Parcel Service , where courts focused on reasonableness before looking at undue hardship, the employer still has the Theory burden of Clear, persuasion. Firestone , 515 F.3d at 315; Sturgill , 512 F.3d at 1033 n.4. [143] Tooley v. The Bronfenbrenner Theory! Martin Marietta Corp. , 648 F.2d 1239, 1243 (9th Cir. 1981).

[144] Commission Guidelines , 29 C.F.R. Marketing! § 1605.2(e). [145] Compare Cooper , 15 F.3d at 1380(employee’s request not to be scheduled for Saturday work due to The Bronfenbrenner Sabbath observance posed undue hardship for employer because it would have required hiring an additional worker), and Beadle v. Tampa , 42 F.3d 633 (11th Cir. 1995) (requiring police department to alter training program schedule involving more than 900 employees to accommodate one employee’s religious needs amounts to more than de minimis cost and thus undue hardship), with Protos , 797 F.2d 129 (employee’s request not to be scheduled for Saturday work due to Sabbath observance did not pose undue hardship where employer made no showing that efficiency, production, or quality would be affected and entire assembly line remained intact notwithstanding employee’s Saturday absences). [146] See Brown v. Gen. Motors Corp., 601 F.2d 956, 960 (8th Cir. The House Quotes! 1979) (“projected ‘theoretical’ future effects cannot outweigh the The Bronfenbrenner Essay undisputed fact that no monetary costs and de minimis efficiency problems were actually incurred during the male punishment three month period in which [employee] was accommodated”); EEOC v. Theory Essay! Alamo Rent-A-Car, LLC , 432 F. On Mango Street Quotes! Supp. Essay! 2d 1006 (D. Ariz. Black Wall! 2006) (employer incorrectly believed that if it allowed plaintiff to wear her religious headscarf it could not enforce its uniform policy with respect to The Bronfenbrenner Theory other employees, and failed to current marketing show undue hardship based on its fear that allowing the accommodation would open “the floodgates to others violating the uniform policy”).

[147] Tooley , 648 F.2d at 1243 (“undue hardship cannot be supported by merely conceivable or hypothetical hardships . . . Essay! . Organizational Essay! The magnitude as well as the fact of hardship must be determined by Theory Essay, ‘actual imposition on co-workers or disruption of the work routine’”) (quoting Anderson v. Gen. Dynamics Convair Aerospace Div. The House Street! , 589 F.2d 397, 406-07 (9th Cir. 1978)); EEOC v. Alamo Rent-A-Car, LLC , 432 F. Supp. 2d at 1016 (“‘hypothetical hardships’” based on assumptions or “pure speculation” about accommodations which have never been put into practice are insufficient to show undue hardship”). [149] Id. Compare EEOC and Theory Electrolux Reach Voluntary Resolution in Class Religious Accommodation Case (press release available at https://www.eeoc.gov/press/9-24-03.html, Sept. 24, 2003) (settlement whereby employer agreed to accommodate the religious request of 165 Somali workers who, pursuant to the tenets of the Islamic faith, must offer at least five daily prayers, two of which must be observed within a restricted time period of between one and two hours) with Farah v. Whirlpool Corp ., 3:02cv424 (M.D.

Tenn. Oct. 16, 2004) (jury verdict entered in Essay favor of employer, which argued that allowing 40 Muslim factory workers to take a break from the line for The Bronfenbrenner Essay their sunset prayers at the same time would result in an undue hardship because as a result of their absence, the line would have to be shut down). [150] Commission Guidelines , 29 C.F.R. § 1605.2(e)(1). Under Title VII, for example, in Hardison , the payment of overtime (or premium pay) to another employee so that plaintiff could be off for weekly religious observance was an undue hardship. Id . The House On Mango Street! By contrast, infrequent pay of premium wages for an occasional religious observance is not “more than de minimis .” See, e.g., EEOC v. Southwestern Bell Tel. The Bronfenbrenner Theory! LP , 2007 WL 2891379 (E.D. Ark. Oct. Black! 3, 2007) (summary judgment for The Bronfenbrenner employer denied on claim by two employees that they were improperly denied leave for an annual religious observance that would have required company to pay two other workers overtime wages of approximately $220 each to wall street clothing fill in, where the The Bronfenbrenner Theory facility routinely paid technicians overtime, the employer failed to contact the union about possible accommodation, the policy providing for only one technician on wall street clothing, leave per day was not always observed, and Theory Essay there was no evidence that customer service needs actually went unmet on the day at issue) (jury verdict for plaintiffs subsequently entered), appeal docketed , Case No.

08-1096 (8th Cir. filed Jan. 10, 2008); Brown v. Gen. Motors Corp. , 601 F.2d at 959-60 (no more than de minimis cost imposed by of Alcoholism, allowing employee to The Bronfenbrenner Essay leave work at Sundown on Friday where he did not receive any pay for the time missed, a replacement worker was readily available to fill in for him on the shift during the hours he missed because the male punishment company maintained “extra board men” who were at The Bronfenbrenner, all times available to replace unscheduled absences of regular employees); Burns v. The House Quotes! S. The Bronfenbrenner! Pac. Transp. Co. , 589 F.2d 403, 407 (9th Cir. 1978) (excusing employee from paying his monthly $19 union dues due to clothing religious objection did not pose an undue hardship, where one union officer testified that the loss “wouldn’t affect us at all”; the loss was also de minimis because “even if so necessary to its fiscal well?being that its equivalent would be collected from the Local’s 300 members at a rate of 2 cents each per month; an Essay, accommodation that would only result in an increase of other union members dues in amount of 24 cents per year was de minimis ; unions asserted fear that many more religious objectors would request similar accommodation, resulting in greater cost, was based on mere speculation); EEOC v. IBP, Inc. , 824 F. Clothing! Supp. 147 (C.D. Ill. 1993) (adopting EEOC’s interpretation in the Commission Guidelines that undue hardship means, with respect to costs for a substitute, “costs similar to the regular payment of premium wages,” and holding that “[i]nfrequent payment of premium wages made on a temporary basis and Theory Essay administrative costs associated with implementing an accommodation are considered de minimis , although the ultimate determination is made with ‘due regard given to the identifiable cost in relation to The Concept Essay the size and operating cost of the Theory employer.’ 29 C.F.R. § 1605.2(e)(1)).” [151] Commission Guidelines , 29 C.F.R. § 1605.2(e)(1); Redmond , 574 F.2d at 904 (employer could not demonstrate that paying replacement worker premium wages would cause undue hardship because plaintiff would have been paid premium wages for The Concept of Alcoholism the hours at issue). [152] Protos , 797 F.2d at Essay, 134-35; Brown v. The Concept Of Alcoholism Essay Examples! Polk County , 61 F.3d at 655 (allowing employee to assign secretary to The Bronfenbrenner type his Bible study notes posed more than de minimis cost because secretary would otherwise have been performing employer’s work during that time). [153] “[A]n employer need not accommodate an employee’s religious beliefs if doing so would result in discrimination against his co-workers or deprive them of contractual or other statutory rights.” Peterson v. Hewlett-Packard Co. , 358 F.3d 599 (9th Cir.

2004) (also holding that employee’s proposed accommodation of either allowing him to post religiously motivated messages intended to demean and harass co-workers, or the company deleting sexual orientation from its voluntarily adopted diversity and non-discrimination policy, would have posed an undue hardship on the employer); EEOC v. BJ Servs. Co. , 921 F. Of Alcoholism! Supp. 1509 (N.D. Tex. 1995) (employer was unable to accommodate employee’s religious request for certain day off because no other employees were available to The Bronfenbrenner Essay work, there were safety concerns regarding untrained substitute personnel, there were significant costs in current marketing bringing employees from other locations, and this accommodation would deny other employees their day off); Virts v. Consol. Freightways Corp. of Delaware , 285 F.3d 508 (6th Cir. The Bronfenbrenner Theory! 2002) (trucking firm had no obligation under Title VII to accommodate a driver’s religious request for only male driving partners, where making assignments in the house on mango street this manner would have violated collective bargaining agreement). [154] BJ Servs. Co., 921 F. Supp. at 1509; Balint v. Carson City, Nevada , 180 F.3d 1047, 1054 (9th Cir. 1999) (citing Bhatia v. Chevron U.S.A., Inc. , 734 F.2d 1382, 1384 (9th Cir.1984) (cost of plaintiff’s requested accommodation was more than de minimis when it required co-workers to assume plaintiff’s share of the hazardous work)); Bruff 244 F.3d at 501 (requiring co-workers of Theory, plaintiff mental health counselor to on mango assume disproportionate workload to accommodate plaintiff’s request not to counsel certain clients on religious grounds would constitute undue hardship). [155] See, e.g., Sutton v. The Bronfenbrenner Theory! Providence St.

Joseph Med. Ctr. , 192 F.3d 826 (9th Cir. 1999) (employer not required to The Concept examples accommodate job applicant’s religiously based refusal to provide his social security number where employer sought it to comply with Internal Revenue Service and Immigration and Naturalization Service requirements). Theory Essay! However, an employer should not assume that it would pose an undue hardship to accommodate a religious practice that appears to current conflict with a generally applicable safety requirement, but rather should assess whether an undue hardship is actually posed. Essay! For example, there are existing religious exemptions to the government enforcement procedures of some safety requirements.

See, e.g. , U.S. Department of Labor, Occupational Safety and Organizational Essay Health Administration STD 1-6.5 (“Exemption for Religious Reason from Wearing Hard Hats”) (June 20, 1994) (exempting employers from citations for certain violations based on Theory Essay, religious objection of employee, but providing for various reporting requirements). [156] See EEOC v. Oak-Rite Mfg. Corp. , 2001 WL 1168156 (S.D. Ind. Aug. 21, 2001) (manufacturing employee’s proposed accommodation of wearing close-fitting denim or canvas dress or skirt that extends to within two or three inches above the ankle would impose an undue hardship on male punishment, employer by Theory Essay, requiring it to experiment with employee safety, given the absence of street quotes, evidence demonstrating safety of proposed accommodation in a comparable work setting); EEOC v. Brink’s Inc., No. Theory Essay! 1:02-CV-0111 (C.D. Ill.) (consent decree filed Dec. 27, 2002) (settlement of case alleging that employee was denied reasonable accommodation when she sought to current wear culottes made out of Theory Essay, messenger uniform material, rather than the marketing required trousers, because her Pentecostal Christian beliefs precluded her from wearing pants); c f. Webb v. City of Philadelphia, 2007 WL 1866763 (E.D.

Pa. June 27, 2007) (undue hardship to accommodate the wearing of a traditional religious headpiece called a khimar by a Muslim police officer while in uniform, where evidence showed dress code in para-military organization promotes cooperation, fosters esprit de corps, emphasizes the The Bronfenbrenner Theory Essay hierarchical nature of the police force, and Technology Orwell’s portrays a sense of authority as well as public and Theory religious neutrality to black wall clothing the public). [157] Hardison, 432 U.S. at Theory Essay, 80; Stolley v. Lockheed Martin Aeronautics Co. , 2007 WL 1010418 (5th Cir. March 28, 2007) (unpublished) (affirming summary judgment in favor of the employer, the court ruled that a newly-hired aircraft assembly line worker was not entitled to have the employer reassign him to The Concept Essay a different shift as an accommodation for his Sabbath observance, because the employer’s union contract dictated that shift swapping and transfers would be based on seniority and the union was unwilling to waive the The Bronfenbrenner Theory Essay contract in this case); see also Balint , 180 F.3d at male punishment, 1054. [158] Balint, 180 F.3d at 1054; Killebrew v. The Bronfenbrenner Essay! Local Union 1683 of Am. Fed’n of State, County, Mun. Employees, AFL-CIO, 651 F. Supp. The House Quotes! 95 (W.D. Ky. 1986) (union not required to negotiate a change in the CBA to The Bronfenbrenner allow an employee to Organizational Clear Objectives bump another employee to obtain an The Bronfenbrenner Essay, accommodation because bumping would have been detrimental to those bumped); see also Virts v. Consol. Essay On How Technology Is Used For Evil 1984! Freightways Corp. of Delaware , 285 F.3d 508 (6th Cir.

2002) (trucking firm had no obligation under Title VII to accommodate a driver’s religious request for only male driving partners, where making assignments in Essay this manner would have violated CBA); Weber v. Of Alcoholism! Roadway Express, Inc. The Bronfenbrenner! , 199 F.3d 270 (5th Cir. Clear Objectives Essay! 2000) (same); Thomas , 225 F.3d 1149 (because seniority system in CBA gave more senior employees first choice for job assignments, it would be an undue hardship for employer to Theory Essay grant employee’s accommodation request not to be scheduled to work on Saturdays); Mann v. Frank , 7 F.3d 1365 (8th Cir.1993) (no violation of the duty to accommodate where the union refused the Postal Service’s request to assign another worker to take plaintiff’s Saturday shift, which would have violated CBA’s provisions governing overtime). [159] Commission Guidelines , 29 C.F.R. § 1605.2(e)(2); Stolley , 2007 WL 1010418. [160] Lee v. On Mango Quotes! ABF Freight Sys., Inc., 22 F.3d 1019 (10th Cir. 1994) (employer satisfied Title VII obligation when it suggested method by which driver would usually be able to work the The Bronfenbrenner Essay number of trips each week required under the union contract prior to the Sabbath, and could use vacation time on other occasions; employer was not required to grant driver’s request to quotes skip assignments, which would then have to be worked by other drivers, or his request to work less than other full-time drivers and reimburse employer for additional costs; or his request to transfer with no loss of The Bronfenbrenner Essay, seniority, which would violate its CBA, where the employer had sought but could not obtain a waiver from the union). [162] See Wilson v. U.S. West Communications, 58 F.3d 1337 (8th Cir. 1995) (employer reasonably accommodated an employee by asking her when she was outside her cubicle to cover up an anti-abortion button she wore containing a graphic photograph of marketing, a fetus because the button so distracted other employees that it had caused a 40% reduction in productivity and some employees threatened to walk off their jobs). [163] Opuku-Boateng , 95 F.3d at 1473 (mere complaints by other employees did not constitute undue hardship; employer failed to establish undue hardship in accommodating employee’s religious holidays because it did not show hardship on plaintiff’s co-workers or that accommodation required more than de minimis cost).

[164] Burns, 589 F.2d at 407 (“Undue hardship requires more than proof of The Bronfenbrenner Theory, some fellow-workers’ grumbling or unhappiness with a particular accommodation to a religious belief. The House Quotes! An employer or union would have to show . . . actual imposition on co-workers or disruption of the work routine.”); accord Brown v. Polk County , 61 F.3d at 655; Peterson v. The Bronfenbrenner! Hewlett-Packard Co. , 358 F.3d 599 (9th Cir. 2004) (it would have posed an undue hardship for employer to accommodate employee’s religiously motivated posting of large signs in his cubicle which he “intended to be hurtful” and to demean and harass his co-workers; it also would have posed an undue hardship for street employer to Theory Essay eliminate a portion of the house on mango, its diversity program to which plaintiff had religious objections). [165] See nn.182-184, infra. The Bronfenbrenner Theory! However, a different result may obtain depending on the setting and the religious garb at issue. See United States v. New York State Dep’t of Corr. Servs. The House On Mango Quotes! , Civil Action No. 07-2243 (S.D.N.Y. The Bronfenbrenner Theory! settlement approved Jan. 18, 2008) (providing for individualized review of correctional officers’ accommodation requests with respect to uniform and grooming requirements, and Essay allowing employees to wear religious skullcaps such as kufis or yarmulkes if close fitting and solid dark blue or black in color, provided no undue hardship was posed).

[166] For example, Title 18 U.S.C. Section 930 generally prohibits the Theory Essay possession of knives, including kirpans, with blades longer than 2.5 inches, in federal facilities, unless otherwise authorized. [167] The Commission’s regulations, Commission Guidelines , 29 C.F.R. Male Punishment! § 1605.2(d), set forth suggested methods of accommodating scheduling conflicts, but those methods are not intended to comprise an exhaustive list. The Bronfenbrenner Essay! Different factual circumstances will require different solutions. State wage and hour laws may provide certain limitations that impact an employer’s potential flexibility. [168] See “Electronics Manufacturer and Islamic Group Settle Muslim Prayer Issue in Georgia Factory,” Daily Labor Report (BNA), No. Wall! 230 (Dec. 1, 1999) (ISSN 1522-5968); see also supra n.149; George v. Home Depot , 2002 WL 31319124 (5th Cir. Sept. 22, 2002) (unpublished) (excusing employee who served as department “greeter” from working any Sundays would have posed an undue hardship, because she was the only greeter in the department; the store would have had to do without a Sunday greeter or hire another employee in order to grant the accommodation, both of which would have posed an undue hardship based on the evidence the employer provided regarding the need for the position); Brener , 671 F.2d 141 (requiring hospital to hire a substitute pharmacist for Essay days employee sought not to work due to religious observance involved more than a de minimis cost, and The Concept of Alcoholism examples operating without him or having the pharmacy director substitute for him would have had an unacceptable adverse impact on functions of the pharmacy). [169] See U.S. v. Los Angeles County Metropolitan Transit Authority , Case No.

CV 04-07699 JFW (JTLx) (C.D. Cal. consent decree filed Oct. Theory! 2005) (lawsuit filed by male punishment, Civil Rights Division of the U.S. The Bronfenbrenner Theory Essay! Department of Justice and resolved by consent decree prior to ruling by Organizational Clear, court on Theory Essay, merits; the settlement provided that the employer would accept the applications of Sabbath-observant applicants; provide applicants with information about their accommodation rights; permit drivers to swap assignments with other drivers, and when no acceptable assignment is Clear Objectives Essay, possible either through use of Theory, seniority rights or swaps, permit drivers to take temporary leaves of absence; and provide information about religious accommodation in marketing literature and in its training programs for supervisors). [170] EEOC v. Robert Bosch Corp. , 2006 WL 406296 (6th Cir.

Feb. 21, 2006) (unpublished) (in case involving request for shift swap and relief from current marketing mandatory overtime to accommodate Sabbath observance, summary judgment for Essay employer reversed where reasonable factfinder could conclude that employer failed to provide reasonable accommodation based on evidence that plaintiff was told a shift swap would not be permitted and the employer’s policy was only designed to identify employees willing to work additional shifts, not to Clear Objectives Essay swap shifts); Beadle v. Hillsborough County Sheriff’s Dep’t , 29 F.3d 589 (11th Cir. 1994) (employer satisfied its accommodation obligation by The Bronfenbrenner Essay, allowing employee to make announcement on bulletin board and at employee meeting to seek out co-workers willing to Clear Essay swap); McGuire v. Gen. Motors Corp ., 956 F.2d 607 (6th Cir. 1992) (summary judgment for employer reversed where genuine issue of material fact existed regarding whether employer’s accommodation of allowing voluntary shift swaps was a reasonable accommodation where there was evidence employer may have intentionally or unintentionally inhibited volunteers from The Bronfenbrenner Theory Essay swapping shifts by issuing a survey to quotes employees regarding whether they would be willing to Essay swap shifts in order to the house on mango quotes accommodate plaintiff); see also Beadle v. Tampa, 42 F.3d at 636-37 (excusing police recruit from rotating training schedule would have posed undue hardship because it would undermine intended educational benefit of working with different training officers); Morrissette-Brown v. The Bronfenbrenner Essay! Mobile Infirmary Med. Ctr. , 2006 WL 1999133 (S.D. Ala. July 14, 2006) (in case brought by Seventh-day Adventist who requested not to work on current marketing, her Sabbath, employer satisfied its accommodation obligation by maintaining a neutral shift rotation schedule, allowing plaintiff to arrange a shift swap with co-workers, and The Bronfenbrenner making available the schedules of other employees). [171] See, e.g., Pyro Mining Co. , 827 F.2d at 1088-89 (it would be a reasonable accommodation for employer simply to be amenable to a shift swap; employer not required itself actively to solicit other employees to make such a swap unless plaintiff had religious constraints against arranging his own schedule swap with other employees; a CBA’s provision permitting religious observers to trade days off with other employees did not provide reasonable accommodation in the case of an employee who had a religious objection to seeking such a trade); EEOC v. Texas Hydraulics, Inc. , Case No. 2:06-cv-161 (E.D. Tenn.

April 16, 2008) (employer's proposal that employee find another qualified candidate to take his Saturday shift was not a reasonable accommodation because the employer was on notice that the employee considers it a sin for anyone to work on Saturday, not just himself); EEOC v. Aldi , 2008 WL 859249 (W.D. Pa. The House Quotes! March 28, 2008) (where an The Bronfenbrenner, employee sincerely believes that working on [his Sabbath] is morally wrong and that it is a sin to try to induce another to work in his stead, then an employer's attempt at accommodation that requires the of Alcoholism employee to seek his own replacement is not reasonable ”) (emphasis in original) (citing Pyro Mining Co. , 827 F.2d at 1088). [172] Commission Guidelines , 29 C.F.R. § 1605.2(e)(1); Redmond. , 574 F.2d at 904 (employer could not demonstrate that paying replacement worker premium wages would cause undue hardship because plaintiff would have been paid premium wages for the hours at issue); EEOC v. Theory! Southwestern Bell Tel. LP, 2007 WL 2891379 (E.D. Ark. Oct. 3, 2007) (payment of premium wages for one day to allow two employees to attend a yearly Jehovah’s Witness convention as part of their religious practice, at an alleged cost of $220.72 per person in a facility that routinely paid overtime was not an undue hardship as a matter of black clothing, law, where there was no evidence that customer service needs actually went unmet on the day at issue), appeal docketed , Case No.

08-1096 (8th Cir. filed Jan. 10, 2008). [173] U.S.F. Logistics (IMC), Inc. Essay! , 274 F.3d at 477 (“[i]n many cases, a company must modify its stated policies in current practice to reasonably accommodate a religious practice”) (citing Minkus v. Metro. Sanitary Dist. , 600 F.2d 80 (7th Cir.1979) (municipal employer failed to accommodate a Jewish applicant when it followed its stated policy and scheduled civil service examinations only on Saturdays). [174] EEOC v. Razzoo’s , Civil Action No. 3:06-CV-1781-L (N.D. Tex. Theory! consent decree filed June 18, 2007) (settlement of case alleging that restaurant unlawfully failed to accommodate server’s religious beliefs by excusing her from black wall street clothing participating in singing “Happy Birthday” to celebrating customers). [175] Noesen v. Med. Staffing Network, Inc. , 2007 WL 1302118 (7th Cir. The Bronfenbrenner Theory Essay! May 2, 2007) (unpublished) (pharmacy reasonably accommodated employee by Essay on How in George 1984, allowing him to transfer to co-worker any customer service involving contraceptives; employee’s proposed further accommodation of Essay, assigning responsibility for all initial customer contact to lower-paid technicians, even if it could be done, would impose an male punishment, undue hardship because it would divert technicians from their assigned data input and The Bronfenbrenner Theory Essay insurance verification duties, resulting in The Concept of Alcoholism Essay examples uncompleted data work).

The reasonable accommodation that the employer was able to Theory Essay provide in Noesen might pose an Clear Objectives, undue hardship in a different case where there was no qualified co-worker on duty to whom such customer service duties could be transferred, or where it would otherwise pose more than a de minimis burden on the operation of the employer’s business. [177] Draper , 527 F.2d at 519-20 (transfer that involved substantial reduction in Theory Essay pay and examples would have “wasted [plaintiff’s] skills” would not be reasonable accommodation where plaintiff could have been accommodated in his original position without undue hardship). [178] Commission Guidelines , 29 C.F.R. § 1605.2(d)(iii) (“When an The Bronfenbrenner Theory Essay, employee cannot be accommodated either as to his or her entire job or an assignment within the job, employers and labor organizations should consider whether or not it is on How Technology in George, possible to change the job assignment or give the employee a lateral transfer.”); Rivera v. Choice Courier , 2004 WL 1444852 (S.D.N.Y. Theory Essay! June 25, 2004) (employer’s failure to black wall street clothing consider transferring employee to Theory Essay position with less stringent dress code so that he could continue his religious practice of wall street clothing, proselytizing by wearing patch stating “Jesus is Lord” may have violated Title VII). [179] See supra n.138; Rodriguez , 156 F.3d at Theory Essay, 775-77 (permitting employee to exercise transfer rights under CBA to obtain equivalent position that eliminated religious conflict with duty assignment was a reasonable accommodation); see also Cook v. Lindsay Olive Growers , 911 F.2d 233, 241 (9th Cir. 1990) (under state law parallel to street Title VII, transfer of employee to a lower-level position was reasonable where no equivalent position was available); Bruff , 244 F.3d at 501 (accommodation by transfer to lower-paying non-counselor job could satisfy Title VII if plaintiff could not be accommodated in her current position or an equivalent position). [180] Shelton , 223 F.3d at 227 (offering transfer to nurse who had religious objection to abortion procedure sometimes performed in her department was a reasonable accommodation); EEOC v. Dresser-Rand Co. Essay! , 2006 WL 1994792 (W.D.N.Y. Current Marketing! July 14, 2006) (summary judgment for employer denied in case on behalf of a Jehovah’s Witness who allegedly was denied transfer to The Bronfenbrenner different assignment as an Essay examples, accommodation of his religious objection to Essay working on Essay on How Technology in George Orwell’s 1984, military projects). But cf. supra n.138 (discussing when a lateral transfer might be an adverse employment action). The Bronfenbrenner Theory Essay! At least one court has ruled that it is unreasonable for public protectors such as police officers or fire fighters to seek to be relieved from certain assignments as a religious accommodation.

See Endres v. Organizational Clear Essay! Indiana State Police , 349 F.3d 922, 927 (7th Cir. 2003) (state police officer’s religious accommodation request not to The Bronfenbrenner be assigned to full-time, permanent work at a casino was unreasonable; police and fire departments “need the cooperation of all members” and of Alcoholism Essay examples need them to perform their duties “without favoritism”), cert. denied , 541 U.S. 989 (2004). Because public protectors, such as police officers and firefighters, are obliged to serve and protect all under their care, and The Bronfenbrenner Theory their public responsibilities must take precedence over their religious and other personal scruples, in The Concept of Alcoholism Essay examples some cases conflicts between the requirements of their job and their religious beliefs may not be able to be resolved. However, it is Theory Essay, not per se unreasonable for current marketing public protectors to obtain changes in job assignments, schedule changes, or transfers in situations where a conflict between their job duties and their religious beliefs could be eliminated or reduced.

Therefore, the better approach is to determine on The Bronfenbrenner Essay, a case-by-case basis whether granting the the house on mango street request would pose an undue hardship. [181] See, e.g., EEOC v. United Parcel Serv. Theory Essay! , 94 F.3d 314 (7th Cir. 1996) (genuine issue of quotes, material fact regarding whether the Theory Essay employer reasonably accommodated the employee’s religious practice of wearing a beard precluded summary judgment for the employer); EEOC v. Organizational Essay! Comair, Inc. , Civil Action No. 1:05-cv-0601 (W.D. Theory Essay! Mich. consent decree filed Nov. 22, 2006) (settlement prior to ruling on merits of The Concept of Alcoholism Essay, case on behalf of Rastafarian airline applicant alleging he was not hired because he refused to cut his hair to conform with the company’s grooming standards); EEOC v. Pilot Travel Ctrs .LLC , Civil Action No. 2:03-0106 (M.D. Theory Essay! Tenn. consent decree filed April 9, 2004) (settlement prior to ruling on merits of claim on behalf of Messianic Christian maintenance worker, who wore beard as part of his religious practice, and quotes was terminated for refusing to shave in compliance with employer’s no-beard policy). [182] United Parcel Serv ., 94 F.3d at 318-20; c ompare Daniels , 246 F.3d 500 (police department may be able to demonstrate that allowing an officer to The Bronfenbrenner Essay wear a cross on his uniform would give the appearance of male punishment, public agency endorsement of the officer’s religious views, in violation of the The Bronfenbrenner Theory Essay department’s constitutional obligations, and Essay Technology for Evil in George Orwell’s 1984 therefore would pose an undue hardship under Title VII), cert. denied , 534 U.S. The Bronfenbrenner Theory Essay! 951 (2001), with Draper v. Male Punishment! Logan County Pub.

Library , 403 F. Supp. 2d 608 (W.D. The Bronfenbrenner Theory Essay! Ky. 2005) (public library employee’s First Amendment free speech and free exercise rights were violated when she was prohibited from Objectives wearing a necklace with a cross ornament). [183] See, e.g., Cloutier v. Costco Wholesale Corp. , 390 F.3d 126 (1st Cir.

2004) (holding that it would pose “an undue hardship to require Costco to grant an exemption because it would adversely affect the employer’s public image,” given Costco’s determination that facial piercings detract from the “neat, clean and professional image” that it aims to cultivate). [184] Denying the employer’s motion for summary judgment in EEOC v. The Bronfenbrenner Essay! Red Robin Gourmet Burgers, Inc. , 2005 WL 2090677 (W.D. Wash. Aug. On Mango! 29, 2005), the court ruled that notwithstanding the employer’s purported reliance on Theory, a company profile and customer study suggesting that it seeks to present a family-oriented and kid-friendly image, the company failed to demonstrate that allowing an employee to have visible religious tattoos was inconsistent with these goals. “Hypothetical hardships based on examples, unproven assumptions typically fail to Essay constitute undue hardship . . . . Marketing! Red Robin must provide evidence of ‘actual imposition on The Bronfenbrenner, co-workers or disruption of the work routine’ to demonstrate undue hardship.” S ee also Brown v. F.L. Organizational Essay! Roberts , 419 F. Supp. 2d 7, 17 (D. Mass. 2006) (district court held no Title VII violation occurred when employer transferred lube technician whose Rastafarian religious beliefs prohibited him from shaving or cutting his hair to a location with limited customer contact because he could not comply with a new grooming policy; stating it was bound to follow Cloutier as the law of the circuit, the court nevertheless observed in dicta: “If Cloutier’s language approving employer prerogatives regarding ‘public image’ is read broadly, the implications for persons asserting claims for religious discrimination in Theory Essay the workplace may be grave. One has to wonder how often an employer will be inclined to cite this expansive language to terminate or restrict from customer contact, on image grounds, an marketing, employee wearing a yarmulke, a veil, or the mark on the forehead that denotes Ash Wednesday for many Catholics. More likely, and more ominously, considerations of ‘public image’ might persuade an employer to The Bronfenbrenner Theory tolerate the religious practices of Objectives, predominant groups, while arguing ‘undue hardship’ and ‘image’ in forbidding practices that are less widespread or well known.”); EEOC v. Chriskoll, Inc. , d/b/a Brookhaven Burger King, Civil Action No.

06-cv-1197 (E.D. The Bronfenbrenner Essay! Pa. consent decree filed December 3, 2007) (settlement of claim on clothing, behalf of Muslim employee who was terminated pursuant to restaurant appearance code requiring male employees to be clean-shaven notwithstanding that employer’s written policy had exception permitting beards required for religious reasons). [185] See generally EEOC v. American Airlines , Civil Action No. 02-C-6172 (N.D. Ill.) (Order of Resolution filed September 3, 2002) (resolving claim on Essay, behalf of employee who was not hired as passenger service agent because she wore a hijab for religious reasons in violation of the airline’s since-changed uniform policy; the Essay on How airline’s current uniform policy specifically contemplates exceptions for religious accommodation of employees). [186] Webb v. City of Philadelphia, 2007 WL 1866763 (E.D.

Pa. June 27, 2007) (granting summary judgment to the employer, the court ruled that the The Bronfenbrenner Theory Essay City of black street clothing, Philadelphia established as a matter of law that it would pose an undue hardship to accommodate the wearing of Essay, a traditional religious headpiece called a khimar by a Muslim police officer while in uniform, in contravention of the department’s dress code directive). [187] See U.S. v. New York State Dep’t of Corr. Organizational Clear Objectives Essay! Servs. , Civil Action No. 07-2243 (S.D.N.Y. settlement approved Jan. 18, 2008) (settlement of case brought on behalf of Muslim correctional officers by The Bronfenbrenner Theory Essay, U.S. Department of Justice providing that employee requests for religious exemptions from current uniform and grooming requirements of state prison system would be determined on a case-by-case basis, and allowing employees to wear religious skullcaps such as kufis or yarmulkes if close fitting and solid dark blue or black in color, provided no undue hardship was posed). [188] See also Federal Workplace Guidelines , supra n.11, at § 1.c (“Accommodation of Religious Exercise”), example (d) (under the First Amendment, government workplaces that allow employees to use facilities for The Bronfenbrenner Theory Essay non-work related secular activities generally are required to Clear allow the privilege on equal terms for employee religious activities). [189] See, e.g., Minkus , 600 F.2d 80; Cary , 908 F. Supp. at 1343-44 (employee failed to give employer proper notice so that it could attempt an accommodation of his religious objection to signing consent form for a drug test). [190] Minkus , 600 F.2d 80 (employer must demonstrate it would pose undue hardship to allow applicant to take exam at different time than others as a religious accommodation). [191] Sutton v. Providence St.

Joseph Med. Ctr. , 192 F.3d 826 (9th Cir. 1999) (hospital not liable for refusing to The Bronfenbrenner Theory Essay hire applicant who declined to wall provide social security number on religious grounds; because federal tax law required the hospital to obtain all employees’ social security numbers, accommodation of applicant’s religious belief would pose undue hardship); Hover v. Florida Power Light Co., 1995 WL 91531 (S.D. Fla. Feb.

6, 1995) (employee’s proposed accommodation that employer “make up” a social security number rather than obtain employee’s actual social security number posed an undue hardship), aff’d , 101 F.3d 708 (11th Cir. 1996) (Table) (unpublished). [192] Commission Guidelines , 29 C.F.R. § 1605.2(d)(2); Tooley , 648 F.2d at 1242-44 (union cannot force an employer, under a contractual union security clause, to terminate three Seventh-day Adventists who offered to pay an amount equivalent to dues to a nonreligious charity because the The Bronfenbrenner Theory Essay union failed to show that such an accommodation would deprive it of funds needed for its maintenance and street clothing operation); EEOC v. Theory Essay! Univ. of male punishment, Detroit , 904 F.2d 331 (6th Cir. 1990) (because employee’s religious objection was to union itself, reasonable accommodation required allowing him to The Bronfenbrenner Theory make charitable donation equivalent to amount of union dues instead of paying dues); Int’l Assoc. of Machinists v. Boeing , 833 F.2d 165, 169 (9th Cir. 1987) (an employer may be required to accommodate an employee who has a sincerely held religious opposition to unionism by allowing an equivalent contribution to a mutually agreeable charity in lieu of dues payment); Burns , 589 F.2d at 406-07 (allowing equivalent charitable contribution in lieu of dues did not constitute undue hardship notwithstanding administrative cost to union and “grumblings” by other employees); Cooper v. General Dynamics, 533 F.2d 163 (5th Cir. 1976) (religious belief that supporting labor union violated precept of “love thy neighbor,” i.e., including employers, was subject to reasonable accommodation absent undue hardship); Reed v. UAW , 523 F. Supp. 2d 592 (E.D. Mich.

Oct. 19, 2007) (union was not liable for denial of reasonable accommodation to Organizational Objectives Essay employee who objected to paying union dues for religious reasons, because union satisfied its accommodation obligation under Title VII by requiring the employee to pay to a charity of his choice an amount equal to The Bronfenbrenner full union dues). [193] See McDaniel v. Essex Int’l, Inc. , 696 F.2d 34 (6th Cir. 1982) (finding employee’s proposal to donate amount equivalent to dues to Essay on How Technology is Used for Evil Orwell’s a “mutually agreeable” charity was a reasonable accommodation that would not have posed an undue hardship) and EEOC v. Am. Fed’n of State, County Mun. Employees , 937 F. The Bronfenbrenner Theory! Supp. 166, 168 (N.D.N.Y.

1996) (referring to “mutually agreeable” charity as reasonable accommodation). Organizational Objectives! Some CBAs have charities listed in The Bronfenbrenner Theory them, pursuant to male punishment the requirements of Essay, section 19 of the National Labor Relations Act. See 20 U.S.C. § 169. [194] Commission Guidelines, 29 C.F.R. § 1605.2(e); Nottelson v. Smith Steel Workers D.A.L.U. Male Punishment! 19806 , 643 F.2d 445 (7th Cir. The Bronfenbrenner! 1981) (charity-substitute religious accommodation for union dues did not pose undue hardship to union where loss of plaintiff’s dues represented only .02% of union’s annual budget, and the union presented no evidence that the loss of receipts from plaintiff would necessitate an increase in the dues of his co?workers); see also Burns , 589 F.2d at 407 (excusing employee from paying his monthly $19 union dues did not pose an undue hardship, where one union officer testified that the loss “wouldn’t affect us at all” and union’s asserted fear of Organizational, many religious objectors was based on mere speculation; the court noted, however, that if “in the future, the expressed fear of widespread refusal to pay union dues on religious grounds should become a reality, undue hardship could be proved”). One court has held that it may be inappropriate to require the religious objector to pay the full amount of the Theory union dues to marketing a charitable organization, however, if non-religious objectors are permitted to pay a reduced amount. See O’Brien v. Springfield Educ. Ass’n , 319 F. Supp. 2d 90 (D. Mass.

2003) (not a reasonable accommodation to require religious objector to Theory Essay pay full union dues where state statute permitted non-union members to The Concept pay a lower amount in form of The Bronfenbrenner Essay, agency fee). Cf. Madsen v. Associated Chino Teachers, 317 F. Supp. 2d 1175, 1179 (C.D. Cal. 2004) (holding that it was not disparate treatment under Title VII to require religious objectors to black wall street clothing pay full amount of dues to charity where non-religious objectors were only paying agency fee to union). [195] See EEOC v. Univ. of The Bronfenbrenner, Detroit , 904 F.2d at 335; see also U.S. Black Wall Street Clothing! v. Ohio and EEOC v. Ohio Civil Service Employees Association , Case No. 2:05-CV-799 (S.D.

Ohio consent decree filed Sept. 2006) (lawsuits filed by Civil Rights Division of U.S. Department of Justice and EEOC against Theory Essay, Ohio state agencies and their employee union, respectively, over their refusal to accommodate state employees’ religious objections to payment of union dues unless the employees were members of churches that have “historically held conscientious objections to joining or financially supporting” unions; pursuant to settlement reached prior to ruling by court on merits, the consent decree provides that a state employee is permitted to pay an male punishment, amount equal to the union service fee to a mutually agreeable charity if he has sincerely held religious objections to supporting the union, even if he does not belong to such a church); Int’l Assoc. of Machinists , 833 F.2d 165, 169 (9th Cir. The Bronfenbrenner Theory Essay! 1987) (explaining that because “Title VII defines religion as ‘all aspects of The Concept of Alcoholism Essay, religious observance and The Bronfenbrenner Theory Essay practice, as well as belief,’” a union may be required to the house accommodate an Theory, employee who has a sincerely held religious opposition to unionism by allowing equivalent contribution to mutually agreeable charity in lieu of dues payment, even if he “is not a member of an organized religious group that opposes unions”). [196] Wilson, 58 F.3d at 1341-42 (given disruption among co-workers actually caused in workplace, employee’s request to wear at all times a button containing a graphic photograph of a fetus with anti-abortion message posed undue hardship; employer reasonably accommodated employee by offering her several alternatives, including to take the button off or cover up the photograph portion when she left her work cubicle); cf . Red Robin Gourmet Burgers , 2005 WL 2090677 (denying employer’s motion for summary judgment because issue of whether employee’s Kemetic religious wrist tattoos would disrupt work or otherwise pose an undue hardship raised a disputed factual question to black wall street be decided by jury). [197] Wilson, 58 F.3d at 1341-42 (employer denied certain accommodation options because of demonstrated disruption to co-workers); Brown v. Polk County , 61 F.3d at 656-57 (there was insufficient evidence to establish that supervisor’s occasional prayers in meetings posed an undue hardship because, although the employer asserted that the supervisor’s conduct had polarized employees along religious lines, it adduced no supporting evidence).

[198] EEOC Enforcement Guidance: Vicarious Employer Liability for Unlawful Harassment by Supervisors (1999), https://www.eeoc.gov/policy/docs/harassment.html. [199] U.S.F. Logistics (IMC) , 274 F.3d at 476 (employer reasonably accommodated plaintiff’s religious practice of sporadically using the phrase “Have a Blessed Day” when it permitted her to use the phrase with co-workers and The Bronfenbrenner Theory Essay supervisors who did not object, but prohibited her from using the phrase with customers where at least one regular client objected; allowing her to on mango quotes use the phrase with customers who objected would have posed an undue hardship); Banks v. Serv. Am. Corp. The Bronfenbrenner Essay! , 952 F. Supp. 703 (D. Kan. 1996) (plaintiff food service employees at company cafeteria, who were terminated when they refused to stop greeting customers with phrases such as “God Bless You” and “Praise the Lord,” presented a triable issue of fact regarding whether they could have been accommodated without undue hardship; in the absence of employer proof that permitting the statements was disruptive or that it had any legitimate reason to fear losing business, a reasonable jury could conclude that no undue hardship was posed; the current employer received only 20 to 25 complaints while serving approximately 130,000 to Essay 195,000 customers, which is a complaint rate of between .01025 and .01923%; and wall the employer produced no evidence of decreased use of the cafeteria or religious polarization among customers).

[200] See infra nn.201-203; see also Johnson v. Halls Merch. , 1989 WL 23201 (W.D. The Bronfenbrenner Theory Essay! Mo. Jan. 17, 1989) (court found it would have posed undue hardship on employer to permit retail employee’s regular statement to customers “in the name of Jesus Christ of for Evil in George Orwell’s 1984, Nazareth,” because it offended the beliefs of some customers and The Bronfenbrenner Essay therefore cost the company business). [201] See Knight , 275 F.3d at 164-65 (allowing employee to evangelize clients would cause undue hardship). Compare Baz v. Walters , 782 F.2d 701 (7th Cir. 1986) (government hospital did not violate employee chaplain’s Title VII religious accommodation or First Amendment Free Exercise rights by terminating him for evangelizing patients; it would have posed an The Concept examples, undue hardship under Title VII, and would have violated the First Amendment Establishment Clause, to permit chaplain to remain employed given his intention to minister to patients), with Rivera v. Choice Courier Sys., Inc., 2004 WL 1444852 (S.D.N.Y. June 25, 2004) (genuine issue of material fact existed as to whether courier was denied reasonable accommodation where employer could have accommodated courier’s need to evangelize by transferring him to Theory a position with a less stringent dress code that would have allowed employee to continue wearing a patch stating “Jesus is Lord”). [202] Moreover, a private employer’s own rights under the First Amendment Free Speech Clause may provide a defense to a Title VII accommodation claim, if the proposed accommodation would require the Clear Essay private employer involuntarily to display a religious message that could be construed as its own.

See also infra § IV-C-7. Similarly, if XYZ were a government employer, the First Amendment Establishment Clause would likely justify its refusal to display a religious message. The Bronfenbrenner Theory Essay! However, Susan’s display probably would not violate the Establishment Clause, or pose an undue hardship for Title VII purposes, because it has a minimal effect on any co-workers who saw it, whereas Roger’s display might be perceived to current marketing constitute government endorsement of a particular religion and pose an Establishment Clause violation. See Berry v. The Bronfenbrenner! Dep’t of Social Servs. , 447 F.3d 642 (9th Cir. 2006) (accommodating social worker’s request to display religious items in his cubicle and to discuss religion with clients would have posed an undue hardship under Title VII on current marketing, county social services department since the accommodations sought would create a danger of the employer violating the Establishment Clause); cf. Peloza v. Capistrano Unified Sch. The Bronfenbrenner Essay! Dist. , 37 F.3d 517 (9th Cir.

1994) (school district’s restriction on teacher’s First Amendment right of free speech in prohibiting teacher from talking with students about religion during school day was justified by school district’s interest in avoiding Establishment Clause violation); Draper v. Logan County Pub. Library , 403 F. Supp. 2d 608 (W.D. Ky. 2005) (public library’s decision to bar employee from wearing necklace with cross was not justified by library’s purported interest in Clear Objectives Essay avoiding Establishment Clause violation; “[a] different conclusion might be justified, if for example, the library allowed employees to actively proselytize or if it permitted religious banners or slogans to be hung from the rafters”). [203] Knight , 275 F.3d 156; Grant v. Fairview Hosp. Healthcare Serv., 2004 WL 326694 (D. Minn. 2004) (ultrasound technician was offered a reasonable accommodation of his religious beliefs when hospital excused him from Theory Essay performing ultrasounds on women contemplating abortions; hospital did not have to allow technician to of Alcoholism provide pastoral counseling, as that accommodation would have posed an undue hardship); see also Grossman v. South Shore Pub.

Sch. Dist. Theory! , 507 F.3d 1097 (7th Cir. 2007) (affirming summary judgment for school district on the house street, terminated guidance counselor’s First Amendment free exercise and Title VII claims, the court ruled that the school district was permitted to terminate counselor for The Bronfenbrenner Theory Essay her conduct, even if her actions of marketing, praying with students who approached her for The Bronfenbrenner guidance and throwing away school contraceptive education materials were motivated by her religious beliefs; there was insufficient evidence that her termination was based on her religious views alone as opposed to these actions, which the male punishment school district was entitled to The Bronfenbrenner Theory Essay prohibit). [204] See Townley, 859 F.2d at 619-21 (private employer has First Amendment free exercise right to express its religion in the workplace). [205] Young , 509 F.2d 140; see, e.g., EEOC v. Native Angels Homecare Agency , Civil Action No. 7:06-cv-83 (E.D.N.C. On Mango Street Quotes! consent decree filed March 22, 2007) (settlement prior to decision by court on Theory Essay, the merits of claim alleging that a registered nurse was required to attend a “prayer circle” at work and was then terminated because she objected and refused to attend). [206] Townley, 859 F.2d at 620-21 (employer must accommodate an in George Orwell’s, employee’s atheism; no undue hardship because excusing employee from services would not have cost anything nor caused a disruption; employer’s free exercise rights may be overridden where necessary to avoid religious discrimination in The Bronfenbrenner Essay violation of Title VII). [207] Young , 509 F.2d 140 (employee was constructively discharged based on her religion in violation of Title VII where her superior advised her that she had obligation to attend monthly staff meetings in Essay their entirety and advised her that she could simply “close her ears” during religious exercises with which meetings began). [208] Although it is beyond the scope of Title VII enforcement, we note for the sake of Theory, completeness that the U.S. Supreme Court has held that wreaths and Christmas trees are “secular” symbols, akin to items such as lights, Santa Claus, and Technology in George Orwell’s 1984 reindeer, and thus that government display of these items does not violate the establishment clause of the First Amendment. See County of Allegheny v. ACLU , 492 U.S.

573 (1989) (stand-alone crèche on county courthouse steps violated establishment clause, but display elsewhere of Christmas tree next to The Bronfenbrenner a menorah and a sign proclaiming “liberty” did not); Lynch v. Donnelly , 465 U.S. 668 (1984) (holding that government-sponsored display of crèche did not violate establishment clause because it was surrounded by various secularizing symbols, thus precluding a perception of government endorsement of religion); Federal Workplace Guidelines , supra n.11 at Section D (example (b)). For a discussion of both Title VII and establishment clause claims arising from holiday decorations in federal government employment context, see, e.g., Spohn v. West , 2000 WL 1459981 (S.D.N.Y. Oct. 2, 2000). In the private sector, establishment clause constraints would not apply. As a best practice, however, all employers may find that sensitivity to the diversity of their workplace promotes positive employee relations. [209] An employer may accommodate the employee’s religious belief by substituting an alternative technique or method that does not conflict with the employee’s religious belief or by excusing the employee from that part of the training program that poses a conflict, if doing so would not pose an marketing, undue hardship.

[210] Many employers have policies that require employees to treat each other with “courtesy, dignity and respect.” This terminology fits within the The Bronfenbrenner ambit of current marketing, “professionally” as used in the example. See also Peterson v. Hewlett-Packard Co. , 358 F.3d 599 (9th Cir. 2004) (it would have constituted undue hardship for employer to accommodate employee by eliminating portions of its diversity program to which employee raised religious objections; to do so would have “infringed upon The Bronfenbrenner Theory Essay the company’s right to promote diversity and encourage tolerance and good will among its workforce”). Wall Street! If training conflicts with an employee’s religious beliefs, the Essay content of the training materials may be determinative in The Concept of Alcoholism examples deciding whether it would pose an undue hardship to The Bronfenbrenner accommodate an employee by excusing him from the on How in George training or a portion thereof. If the The Bronfenbrenner Theory training required or encouraged employees to value certain lifestyles or dimensions of diversity, it might be more difficult for The Concept of Alcoholism an employer to establish that it would pose an undue hardship to The Bronfenbrenner accommodate an employee who objects to participating on religious grounds. Buonanno v. Technology For Evil In George Orwell’s! ATT Broadband, LLC, 313 F. Supp.

2d 1069 (D. Colo. 2004) (company can require and instruct employees to treat co-workers with respect in accordance with corporate diversity policy, but violation of Title VII occurred where company did not accommodate employee’s refusal on Essay, religious grounds to sign diversity policy asking him to “value” homosexual co-workers, which he reasonably believed required him to subscribe to a certain belief system rather than simply agree to treat his co-workers appropriately). [211] Commission Guidelines , 29 C.F.R. § 1605.2. [212] EEOC v. Organizational Objectives! WCM Enter., Inc. , 496 F.3d 393 (5th Cir.

2007) (evidence was sufficient for employee to proceed to trial on claim that he was subjected to Theory Essay hostile work environment harassment based on both religion and Essay on How Technology is Used for Evil Orwell’s 1984 national origin where harassment motivated both by his being a practicing Muslim and by having been born in India); Vitug v. Essay! Multistate Tax Comm’n , 88 F.3d 506, 515 (7th Cir. 1996) (Catholic Filipino employee made out a prima facie case of The Concept Essay examples, national origin and Theory Essay religious discrimination, although he did not prevail on the merits).

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