The Eleventh Circuit Court of Appeals has upheld the dismissal of a religious failure-to-accommodate lawsuit brought under Title VII by a former Seventh-day Adventist who refused to work on Saturdays because it conflicted with his Sabbath observance.
The ruling by the Eleventh Circuit in Patterson v. Walgreen Co., No. 16-16923 (11th Cir. Mar. 9, 2018), contrasts sharply with the recent ruling by the Tenth Circuit in Tabura v. Kellogg, which held that the employer had failed to meet its Title VII religious accommodation duty. The two cases together underscore the fact-specific nature of religious accommodation disputes, and how the perception of the employer’s response can make the difference between a win and a loss.
In Patterson, the company was able to show that it offered multiple accommodations to resolve the employee’s scheduling conflicts, and the court concluded that the company met its duty under Title VII even though the proffered accommodations did not completely resolve the problem.
A copy of the Eleventh Circuit’s opinion in Patterson v. Walgreen Co. is available here.
Members of the Center for Workplace Compliance (CWC) can read more here.