In a recent case, Donald Yeager v. FirstEnergy Generation Corporation, the Sixth Circuit Court of Appeals held that an employer is not required to accommodate an employee’s religious beliefs if doing so would violate a federal statute. Specifically, the Court held that the employer did not violate the rights of an employee when it terminated him for refusing to provide a social security number. The employee in this case sued the employer claiming that having a social security number was against his religious beliefs.
To make a claim of religious discrimination under the Civil Rights Act of 1964, the plaintiff must show three things. First, that he holds a sincere religious belief that is in conflict with a requirement of his employment; second, that he has informed his employer of the conflict; and third, that he was discharged or disciplined because he did not comply with that employment requirement. If a plaintiff successfully makes his case, then the employer must show that it could not reasonably accommodate the employee’s religious beliefs without undue hardship. If the employer cannot make this showing the plaintiff will prevail.
The Court said its decision to dismiss the employee’s claims could be supported in either of two ways. First, by finding that a statutory obligation is not truly an employment requirement, or second, by finding that complying with an employee’s religious belief is an undue hardship when it requires an employer to violate a federal law.
This article was written by Laura Barrera, law clerk. Please contact the attorneys at Demorest Law Firm if you have any questions.
