Title VII requires employers to provide reasonable accommodations based on employees' religious beliefs and practices. A new case from the Seventh Circuit Court of Appeals demonstrates that the employer meets its legal obligation under Title VII when it offers an effective accommodation, even if it is not the employee's preferred one.
In Porter v. City of Chicago, the plaintiff was a clerical worker for the police department whose shift changed to include working Sundays. She requested that she remain on her prior work schedule in order to allow her to attend church on Sunday. In response, the City offered to allow the plaintiff to work a later shift on Sundays, leaving her available to attend religious services in the morning. The employee rejected this proposal, quit, and sued alleging constructive discharge based on the employer's failure to accommodate her religious beliefs.
The Seventh Circuit affirmed summary judgment for the City. The Seventh Circuit concluded that the employer had provided an effective accommodation, even if it was not the one preferred by the employee. The court noted that the employer had previously agreed to a series of schedule accommodations to allow the plaintiff to attend Bible study and choir practice. The City also informed the plaintiff that she would be eligible to return to her prior schedule as soon as a position opened.
Employers faced with an employee request for a religious accommodation should not hesitate to engage that employee in a discussion and review of various alternatives, and whether they would meet the employee's needs. In some cases, the parties may reach an acceptable compromise. In others, the employer may identify effective accommodations that can be offered as an alternative to the employee's request, while fulfilling legal obligations under Title VII.