Title VII requires employers to provide reasonable accommodation of employee's religious beliefs and practices. In a recent case, the Seventh Circuit Court of Appeals concluded that this accommodation requirement extends to granting unpaid leave to attend a relative's funeral.

In Adeyeye v. Heartland Sweeteners, LLC, the plaintiff requested several weeks leave to return to Nigeria to attend his father's funeral. He claimed that he informed his employer that his attendance was compulsory, and would lead to "spiritual death" for him and his family members if not accomplished. After the leave request was denied, he sued under Title VII.

The district court dismissed the claim, stating that the plaintiff never gave his employer sufficient notice that his need to be away from work was linked to his religious beliefs. The Seventh Circuit reversed this dismissal, noting that the plaintiff's written leave requests disclosed his need to attend certain funeral rites and services that were arguably based on religious beliefs. The court then repeated long-standing precedent in refusing to inquire into the sincerity of the plaintiff's beliefs. In doing so, it rejected the employer's contention that the actual reason for the leave request was family obligation and not religious beliefs.

The Seventh Circuit did not address whether the requested leave would have presented an undue hardship to the employer's business. Unlike the ADA, Title VII's religious accommodation obligations end when they impose more than minor costs or disruptions on the employer. In the end, the jury will be charged with making this determination. Employees do not have to specifically request religious accommodations. If the employer reasonably should have known that the request is linked to spiritual beliefs, it has the obligation to perform the reasonable accommodation analysis.