Honor Thy Father and Thy Mother: Religious Accommodation Under Title VII in Adeyeye v. Heartland Sweeteners, LLC

Seventh Circuit Review, Dec 2013

Title VII of the Civil Rights Act provides that an employer must reasonably accommodate an employee's request for a leave of absence due to a religious observance or practice, as long as that accommodation does not present an undue hardship for the employer. The amendments to Title VII, and the Guidelines issued by the Equal Opportunity Employment Commission in response to Title VII, reveal a trend towards a broad interpretation of religious accommodation in the workplace. The Seventh Circuit Court of Appeals continued and exemplified this trend in Adeyeye v. Heartland Sweeteners, LLC. In Adeyeye, where an employee requested a leave of absence to attend his father's funeral ceremony in Africa, the Seventh Circuit presented a liberal understanding of religious accommodation and acknowledged a variety of non-traditional and less common religions. The court analyzed whether the employer, Heartland Sweeteners, LLC, provided sufficient accommodation for Adeyeye's religious request, or in the alternative, whether the employer showed that this request would present Heartland with an undue hardship. The court found that Adeyeye's request arose from a sincere religious belief and would not have presented Heartland with an undue hardship. This Article explains the Seventh Circuit's interpretation of religious accommodation in the workplace by looking to the amendments of Title VII, the relevant EEOC Guidelines, and the recognition of sincere religious beliefs by the Supreme Court in cases regarding conscientious objectors. This Article asserts that the Seventh Circuit's decision in Adeyeye reflects the appropriate tolerant statutory interpretation of Title VII regarding reasonable accommodations for religious requests. This decision came from the movement towards greater religious acceptance and understanding as reflected in the statutory language of Title VII and the evolution of the EEOC Guidelines.

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Honor Thy Father and Thy Mother: Religious Accommodation Under Title VII in Adeyeye v. Heartland Sweeteners, LLC

Honor Thy Father and Thy Mother: Religious Accommodation Under Title VII in Adeyeye v. Heartland Sweeteners, LLC Zeke Katz 0 IIT Chicago-Kent College of Law 0 0 This Employment Law is brought to you for free and open access by Scholarly Commons @ IIT Chicago-Kent College of Law. It has been accepted for inclusion in Seventh Circuit Review by an authorized editor of Scholarly Commons @ IIT Chicago-Kent College of Law. For more information , please contact Follow this and additional works at: http://scholarship.kentlaw.iit.edu/seventhcircuitreview Part of the Law Commons Recommended Citation Zeke Katz, Honor Thy Father and Thy Mother: Religious Accommodation Under Title VII in Adeyeye v. Heartland Sweeteners, LLC, 9 Seventh Circuit Rev. 110 (2013). Available at: http://scholarship.kentlaw.iit.edu/seventhcircuitreview/vol9/iss1/6 - Fall 2013 Cite as: Zeke Katz, Honor Thy Father and Thy Mother: Religious Accommodation Under Title VII in Adeyeye v. Heartland Sweeteners, LLC, 9 SEVENTH CIRCUIT REV. 110 (2013), at http://www.kentlaw.iit.edu/Documents/Academic Programs/7CR /v9-1/katz.pdf. ZEKE KATZ I. INTRODUCTION In Adeyeye v. Heartland Sweeteners, LLC (“Adeyeye”), an employer denied an employee’s request for a five-week leave of absence for the employee to participate in his father’s funeral ceremonies in Nigeria.1 This case exemplified the potential conflicts surrounding religious accommodation in the workplace. Under Title VII of the Civil Rights Act (“Title VII”), an employer must reasonably accommodate an employee’s request regarding a religious practice or observance, as long as that request does not impose an undue hardship on the employer.2 Courts look to previous Title VII jurisprudence and commentary to evaluate an employer’s obligation to accommodate an employee’s request for a leave of absence rooted in that employee’s religious practices or observances. In Adeyeye, the Seventh Circuit  J.D. candidate, May 2014, Chicago-Kent College of Law, Illinois Institute of Technology; B.A., Philosophy & Religion, Colgate University. I would like to thank Professor Hal Morris, our Executive Editor Kathleen Mallon, and my family for all their support. 1 Adeyeye v. Heartland Sweeteners, LLC, 721 F.3d 444 (7th Cir. 2013). 2 42 U.S.C. §§ 2000e-e-17 (2000). 110 Volume 9, Issue 1 Court of Appeals found that Heartland Sweeteners, LLC (“Heartland”) improperly rejected Sikiru Adyeye’s request for religious accommodation. The court’s decision epitomizes federal courts’ broader interpretation of both the qualifications of a religious tradition and an employer’s accommodation of religious traditions in the work place. As federal courts implement a more tolerant approach to employees’ religious observances those courts simultaneously promulgate the general expansion and promotion of religious freedom in the workplace. This trend towards more religious accommodation is exemplified in the amendments to Title VII, the Guidelines of the Equal Employment Opportunity Commission (“EEOC”), federal case law, and the Seventh Circuit Court of Appeals’ opinion in Adeyeye. Federal courts’ purposeful development towards employers’ broader accommodation of employees’ religious traditions has appropriately influenced a greater acceptance and understanding of a diverse variety of religions in the work place. Importantly, courts’ tolerant and progressive approach towards religious accommodation is consonant with the freedom of religion principles established in the First Amendment to the United States Constitution. The “reluctance to require more than a de minimis accommodation by employers seems to be inapposite to the societal goal of allowing members of all religions to practice their faith freely.”3 For employees to experience the religious freedom guaranteed by the Constitution, employers must reasonably accommodate those employees’ religious practices and observances. Title VII’s requirement that employers provide reasonable religious accommodations is closely intertwined with the freedom of religion under the First Amendment. The First Amendment to the United States Constitution states “Congress shall make no law respecting an establishment of religion, or prohibiting the free exercise Volume 9, Issue 1 thereof.”4 Freedom of religion is applied to the states via the Fourteenth Amendment to the United States Constitution, Section 1, which states “[n]o State shall make or enforce any law which shall abridge the privileges or immunities of citizens of the United States; nor shall any State deprive any person of life, liberty, or property, without due process of law; nor deny to any person within its jurisdiction the equal protection of the laws.”5 Enforcing employers to comply with employees’ reasonable religious requests encourages religious freedom in the workplace. Title VII compels employers to reasonably accommodate employees’ religious requests while the First Amendment simultaneously supports individuals’ rights to p (...truncated)


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Zeke Katz. Honor Thy Father and Thy Mother: Religious Accommodation Under Title VII in Adeyeye v. Heartland Sweeteners, LLC, Seventh Circuit Review, 2013, Volume 9, Issue 1,