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SAT / ACT Prep Online Guides and Tips. Whether you've never written an SAT Essay or didn't get the score you wanted on your last test, you can benefit from knowing more: both about the Essay itself, and what really matters when the graders are reading your essay. Here are 15 tips to master the SAT essay . If you can reliably follow all these points, you'll be able to get at least a 6/6/6 on the SAT essay - guaranteed. The SAT Essay is a very short assignment. You only get 50 minutes to paper, read a 650-750 word passage, analyze the devices the author uses to structure her/his argument, and write a full-fledged essay - and it can pass in a flash if you don't have a method for Custom writing reviews, attacking it. Writing an SAT essay requires a very specific approach that's unlike the Research paper, essays you've been writing for Essay writing pdf, English class in school. The goal of Research paper payment, this strategy is to cram in as many as possible of the desired components in the 50 minutes you've got. In this article, we give you 15 key tips for the SAT essay. The first five tips in this article relate to what the College Board tells us about anlaysis use, what's a good essay.

The next five are truths that the Research, College Board doesn't want you to Dissertation consulting service editing, know (or doesn’t make explicit). And the last five tips for SAT essay writing show you how to build an SAT essay, step by step. What the College Board Does Tell You: 5 Tips. Research. The College Board explains the main components of the successful SAT Essay in its scoring criteria. Here they are condensed: The SAT essay rubric states: The response includes a precise central claim.” What this means is that your essay needs to make a clear argument that the reader can easily identify. All you have to do to create your precise central claim is to identify the main idea of the writing, passage and list the methods the author uses to support it. Fortunately, the SAT provides you with the paper payment, passage’s main idea, so you don’t have to go hunting for it yourself. I've bolded the claim in this (fake) sample prompt so you can see this for yourself: Write an essay in which you explain how Sam Lindsay builds an argument to persuade her audience that more works of art should feature monsters . Custom Essay Writing. In your essay, analyze how Lindsay uses one or more of the features listed in the box above (or features of Research paper, your own choice) to strengthen the logic and persuasiveness of her argument. Be sure that your analysis focuses on the most relevant features of the passage. Your essay should not explain whether you agree with Lindsay’s claims, but rather explain how Lindsay builds an argument to persuade her audience.

Now, here's an example of a thesis statement for Writing for ap english, an essay responding to this prompt: In the article “Monsters Monsters Everywhere,” Sam Lindsay uses personal anecdotes, vivid language, and appeals to emotion to persuade her audience that more works of art should feature monsters. It's fine to copy the exact words describing the author’s central claim from the Research payment, prompt into your thesis statement—in fact, this guarantees that the graders will see that your thesis is there and on-topic. #2: Include Both an Introduction and a Conclusion. The SAT essay rubric states: The response includes a skillful introduction and conclusion.” Including an introduction paragraph in your essay is absolutely essential to getting a Writing score above a 4/8. The introduction paragraph introduces the reader to english writing, what you’ll be talking about and allows you to set up the structure for Research payment, the rest of the essay. Plus, an introduction can be a pretty good indicator of the quality for the rest of the essay – a poorly constructed introduction is often a warning that the anlaysis paper use, essay that follows will be equally discombobulated. It's best to have both an introduction and a conclusion, but if you’re running short on time and can only have one, definitely pick the introduction. A good introduction includes your thesis statement. For the SAT essay, as I discussed in Research paper payment the previous point, your thesis (or your precise central claim) should be a statement about what devices the author uses to build her/his argument. Short Hardship. Introductions can be tricky to paper, write, because whatever you write in that paragraph can then make you feel like you’re locked into writing just about Help with writing, that.

If you’re struggling, leave yourself 10 blank lines at the beginning of the essay and jump into writing your body paragraphs. Research Paper Payment. Just make sure you remember to go back and write in your introduction before time’s up! #3: Use Effective Language and Word Choice. There are a couple of parts of the essays for ap english, Writing score section on the SAT essay rubric that pertain directly to style. First, the SAT essay rubric states: The response is cohesive and paper demonstrates a highly effective use and essay for scholarship letter command of language. For most of paper payment, us, this is an area that takes a long time to develop, so unless your language skills are really rough or you're prepping a year ahead of Writing for ap english, time (or both), you'll probably get more out of focusing on Research payment the other components of the essay. The SAT essay rubric also states: “The response has a wide variety in sentence structures.

The response demonstrates a consistent use of Help with english, precise word choice. The response maintains a formal style and objective tone.” This basically boils down to: don't be repetitive and Research paper payment don't make grammar mistakes. In addition, you should avoid using first person statements like I or My in the essay, along with any other informality. You're writing the Help writing, equivalent of Research paper, a school paper, not an opinion piece. “I think that Sam’s super persuasive in this article cause she’s just so passionate. It made me feel kinda bad that I don’t really monster it up in my everyday life.” “Lindsay’s passionate defense of how drawing monsters 'allows us to laugh at Dissertation consulting service editing our personal foibles' causes her audience to put themselves in her shoes and empathize with her position.” Finally, try to use different words to Research, describe the with english, same idea - don't use shows 15 times. Take the payment, chance to show off your vocabulary ( if, and use only if , the paper payment, vocabulary is internet, appropriate and makes sense) . This component is the biggest reason why revising your SAT Essay is essential - it's fast and Research paper payment easy to change repeated words to How to write short essay letter, other ones after you're finished, but it can slow you down during writing to worry about your word choice. If you're aiming for a top score, using advanced vocabulary appropriately is vital. #4: Only Use Information From the Passage. All the relevant information is in Research the passage, so avoid getting drawn into the topic and using your outside knowledge – you want to Pay for literary paper use, be sure to show that you’ve read the passage. In real life, there are many ways to support a thesis, depending on the topic. But on the SAT, there's one kind of correct support: specific details drawn from the passage you’re asked to analyze . We'll show you more below. #5: Focus Your Essay on Relevant Details.

You don’t have to mention every single detail that makes the argument effective. In fact, your essay will be more coherent and more likely to score higher in Analysis if you focus your discussion on just a few points . Research Paper. It's more important to show that you're able to Help english message, pick out the most important parts of the argument and explain their function that it is to be able to identify every single persuasive device the author used. Think about it as if you were asked to write a 50-minute essay describing the human face and payment what each part does. A clear essay would just focus on major features - eyes, nose, and mouth. A less effective essay might also try to Essay internet pdf, discuss cheekbones, eyebrows, eyelashes, skin pores, chin clefts, and payment dimples as well. While all of these things are part of the face, it would be hard to get into detail about each of the parts in just 50 minutes.

And this is the eye, and this is the Essay writing internet pdf, other eye, and this is the. other eye. and the other eye. and paper the other. wait. what's going on here? What the College Board Doesn’t Tell You: 5 Secrets. Even though the editing, SAT essay has clearly stated, publicly-available guidelines, there are a few secrets to writing the paper, essay that most students don't know and that can give you a major advantage on the test. #1: Read the Prompt Before the Passage. Why? Because the prompt includes the description of the author’s claim. Knowing what the author’s claim is service editing, going into payment the article can help keep you focused on Essay writing internet pdf the argument, rather than getting caught up in reading the passage (especially if the topic is one you're interested in). Research Payment. #2: Your Facts Must Be Accurate…But Your Interpretation Doesn’t Have to Be. A big part of the Dissertation editing, Analysis score for the SAT essay is not just identifying the Research paper payment, devices the author uses to build her argument, but explaining the effect that the use of these devices has on the reader . You don’t have to write essay hardship, be completely, 100% accurate about the Research, effect the passage has on the reader, because there is no one right answer. As long as you are convincing in your explanation and cite specific examples, you’ll be good. Here's an example of an interpretation about what effect a persuasive device has on essays english the reader (backed by evidence from the passage): Lindsay appeals to the emotions of her readers by describing the forlorn, many-eyed creatures that stare reproachfully at her from old school notebook margins. The sympathy the readers feel for these forgotten doodles is expertly transferred to paper payment, Lindsay herself when she draws the connection between the drawn monsters and her own life: “Often, I feel like one of these monsters – hidden away in my studio, brushes yearning to create what no one else cares to see.” Now, you don't necessarily know for sure if sympathy for the doodles is what the author was going for in her passage.

The SAT essay graders probably don't know either (unless one of them wrote the passage). But as long as you can make a solid case for your interpretation, using facts and quotes from the passage to back it up , you'll be good. #3: You Should Write More Than One Page. This has always been true for Dissertation service, the SAT essay, but for the first time ever, the College Board actually came out in The Official SAT Study Guide and explicitly said that length really does matter . Here's the description of a 1-paragraph, 120-word-long student response that received a Writing score of 2/8 (bolding mine). “Due to the brief nature of the response , there is not enough evidence of writing ability to merit a score higher than one. Overall, this response demonstrates inadequate writing .” (source: The Official SAT Study Guide (March 2016 Beyond) , p. 206) You’ll have one page for Research paper payment, (ungraded) scrap paper that you can use to plan out your essay, and four pages of writing paper for the essay – plan on writing at least two pages for your essay . #4: Be Objective When Reading the Passage. How To Write. Being able to stay detached while reading the passage you'll be writing the essay about can be tricky. This task might be especially difficult for students who were used to the old SAT essay (which pretty much made it mandatory for you to payment, choose one side or the literary anlaysis use, other). You’ll have to practice reading persuasive essays and gaining objectivity (so that you are able to write about how the argument is constructed, not whether it’s good or bad). A good way to practice this is to read news articles on topics you care deeply about by people who hold the opposite Research paper view that you do . For instance, as a composer and with english writing message violist/violinist, I might read articles about how children should not be encouraged to Research paper, play musical instruments, since it holds no practical value later on in life (a view I disagree with vehemently).

I would then work on my objectivity by jotting down the central ideas, most important details, and how these details relate to the central ideas of the article . Writing For Ap. Being able to understand the payment, central ideas in the passage and service details without being sidetracked by rage (or other emotions) is key to writing an effective SAT essay. Don't let the monster of rage distract you from your purpose. #5: Memorize and Identify Specific Persuasive Techniques. Once you’re able to read articles objectively (as discussed in point 4 above), the next step is to be able to break down the argument in Research payment the articles . To do this successfully, you'll need to be aware of some of the techniques that are frequently used to build arguments. Literary Use. The SAT essay prompt does mention a few of these techniques (bolding mine): As you read the passage below, consider how Lindsay uses. evidence, such as facts or examples , to paper, support claims. reasoning to develop ideas and to connect claims and evidence. Dissertation Service Editing. stylistic or persuasive elements, such as word choice or appeals to paper payment, emotion , to add power to the ideas expressed. It’s certainly possible to wing it and go into the test without knowing specific names of particular persuasive devices and literary just organically build up your essay from features you notice in the article.

However, it's way easier to go into the essay knowing certain techniques that you can then scan the passage for . For instance, after noting the central ideas and important details in the article about how more works of art should feature monsters, I would then work on paper payment analyzing the way the author built her argument. Does she use statistics in the article? Personal anecdotes? Appeal to emotion? I discuss the letter, top persuasive devices you should know in Research more detail in the article 6 SAT Essay Examples to essay reviews, Answer Every Prompt. How to Get All the Necessary Components in 50 Minutes: 5 Step-By-Step Strategies. Research Paper. When you write an SAT essay, you only have 50 minutes to with message, read, analyze, and write an essay, which means that you need a game plan going in. Here's a short step-by-step guide on how to write an effective SAT essay. Don’t just summarize the passage in your essay, or identify persuasive devices used by the author - instead, be sure to actually analyze the paper payment, way the author of the passage builds her argument.

As The Official SAT Study Guide states, [Y]our discussion should focus on what the author does, why he or she does it, and what effect this is likely to have on readers. College Board makes a point of specifying this very point in its grading rubric as well - an paper essay that scores a 2 (out of 4) or below in Analysis merely asserts, rather than explains [the persuasive devices'] importance. If you want to get at Research least a 3/4 (or a 6/8) in Analysis, you need to heed this warning and Pay for anlaysis use stay on task . Research Payment. #2: Support Your Points With Concrete Evidence From the Passage. The best way to get a high Reading score for your essay is to quote from the passage appropriately to support your points . This shows not only that you’ve read the passage (without your having to summarize the How to short essay for scholarship hardship, passage at all), but also that you understand what the author is saying and the way the author constructed her argument. As an alternative to using direct quotations from the passage, it’s also okay to paraphrase some of what you discuss. If you are explaining the author's argument in your own words, however, you need to be extra careful to make sure that the facts you're stating are accurate - in contrast to scoring on the old SAT essay, scoring on the new SAT essay takes into account factual inaccuracies and penalizes you for them. The SAT essay rubric states: “The response demonstrates a deliberate and highly effective progression of paper, ideas both within paragraphs and throughout the essay.” The main point to take away from this is that you should follow the standard structure for an SAT essay (introduction-body-body-conclusion) . Essay Internet. Using a basic 4-5 paragraph essay structure will both keep you organized AND make it easier for the essay graders to paper payment, follow your reasoning - a win-win situation!

Furthermore, you should connect each paragraph to writing internet, each other through effective transitions. We'll give you ways to paper payment, improve your performance in this area in the articles linked at the end of this article. #4: Make Time to Read, Analyze, Plan, Write, and Revise. Writing Essays For Ap English. Make sure you allocate appropriate amounts of time for each of the steps you’ll need to Research payment, take to write the Writing for ap, essay – 50 minutes may seem like a long time, but it goes by awfully quick with all the things you need to do. Payment. Reading the passage, analyzing the Dissertation consulting editing, argument, planning your essay, writing your essay, and Research revising are all important components for Dissertation editing, writing an 8/8/8 essay. For a breakdown of how much time to spend on each of these steps, be sure to check out our article on how to Research payment, write an SAT essay, step-by-step. The more you practice the analysis and the writing, the better you’ll get at the task of writing an SAT essay (as you work up to Writing, it a little at a time). It's especially important to practice the analysis and writing components of the essay if you are a slow reader (since reading speed can be difficult to change). Being able to analyze and write quickly can help balance out the extra time you take to read and comprehend the material (plus, the time you put into working on paper payment analysis and Essay internet writing will yield greater rewards than time spent trying to increase your reading speed). But don't forget : while it’s okay to Research payment, break up the practice at first, you also really do need to get practice buckling down and doing the whole task in one sitting . This is just the beginning of improving your SAT essay score.

Next, you actually need to put this into Essay practice with a real SAT essay. Want to learn more about the changes to the SAT essay? We have a comprehensive guide to what changed (and what didn't) here. Want to improve your SAT score by 160 points? Check out Research payment our best-in-class online SAT prep program. We guarantee your money back if you don't improve your SAT score by 160 points or more. Our program is entirely online, and it customizes what you study to your strengths and How to short essay for scholarship hardship letter weaknesses. If you liked this SAT Essay lesson, you'll love our program.

Along with more detailed lessons, you'll get your SAT essays hand-graded by a master instructor who will give you customized feedback on how you can improve. We'll also give you a step-by-step program to follow so you'll never be confused about what to study next. Check out our 5-day free trial: Have friends who also need help with test prep? Share this article! Laura graduated magna cum laude from Wellesley College with a BA in Music and Psychology, and earned a Master's degree in Composition from the Longy School of Music of Bard College. She scored 99 percentile scores on Research the SAT and service GRE and loves advising students on how to excel in high school. You should definitely follow us on social media. You'll get updates on our latest articles right on your feed. Paper Payment. Follow us on short for scholarship hardship all 3 of Research, our social networks: Have any questions about this article or other topics? Ask below and we'll reply! Series: How to Get 800 on Each SAT Section: Series: How to Dissertation consulting editing, Get to 600 on Each SAT Section:

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Movie The Notebook Essays and Research Papers. The Notebook The Notebook he tells about the love between a man and paper a woman, from when they met as teenagers until they are . in a nursing home, trying to overcome the trials of Alzheimer’s and loss of memory. Throughout the story it is clear that they love each other deeply. I read the book and watched the movie version of How to write short hardship, this touching story. There was one thing that I found surprising, that I enjoyed the Research movie more than I did the book, which is rare for me. When I have watched other movie versions. Emotion , Interpersonal relationship , James Marsden 1451 Words | 4 Pages. The Notebook : As if Reading from a Notebook People often refer to the movie The Notebook as a sappy, . predictable chick flick that plays with your emotions, making you spill a few tears here and there.

Even though I’ve seen this movie a million times, everytime I enjoy watching the Help with english story of paper payment, two young lovers who can’t find a way to Help with english writing message be together due to their social backgrounds. It’s a heartbreaking and achingly real love story that will keep you hooked from the Research payment beginning leaving you gasping for more. Billboard Hot Country Songs number-one singles , Film , James Garner 1208 Words | 3 Pages. Comparison Between the Notebook Movie and Book. Enduring power of service, love: The Notebook The Notebook , written by Nicolas Sparks, can be named one of the paper payment best American romantic . novels. Service? The book portrays every trait in Research paper payment, a guy or girl would desire to internet pdf have in a significant other. According to Nicolas Sparks, “it is a celebration of how passion can be ageless and timeless, tales that moves us to laughter and tears and makes us believe in true love all over again”. Research Paper Payment? The Notebook was on the New York Times best-seller list within the very first week. 2004 in film , Love , Nicholas Sparks 1082 Words | 3 Pages.

?The movie The Notebook brings forth a great amount of emotion and affection. This story, originally written by writing internet author . Nicholas Sparks, follows a couple through the ups and downs of love. The great portion of the movie is paper a flashback looking into the lives of two young people smitten for each other. Even when distance and other lovers separate them, the two find their way back to each other. In this movie the theory that love conquers all proves to be a major theme.

This. Lebanon, Tennessee , Love , Need 857 Words | 5 Pages. The Notebook is one of my favorite love movies of all time. How To Write Short Essay? The reason I love this movie so much is because that main characters . Noah and Allie go through so many trials and finally end up together in Research, the end. This movie I feel shows me how strong their love for each other really was and paper I now feel as if it is meant to Research be it will always find a way. Looking at the movie as a reference to Dissertation consulting get a better understanding of paper, how lifespan development works, I realized that most of the trials that Noah and. Adult , Adulthood , Developmental psychology 1033 Words | 3 Pages. and her parents are crazy about.

Allie decides that her love for Noah is too strong to let go, and she decides to begin her life with Noah knowing that it . will not be easy it is going to be a long fight and struggle everyday but its worth it. Consulting Editing? The movie then flashes to the present where Noah is reading their love story to her and they are both sitting in an old folk home where they take care of the sick or needy. Allie wrote if I ever leave you read our love story to paper payment me and I shall come back to you. Hippocampus , Implicit memory , Long-term memory 1247 Words | 3 Pages. THE NOTEBOOK By Nicholas Sparks The love story between two different teenagers that come . from completely different worlds is the reviews most remarkable. Research Paper? The Notebook is Writing essays for ap english about two young teenagers who fell head over heels with each other. They got separated by Allie’s upper-class parents who insist that Noah isn’t right for paper payment her. But that obstacle didn’t stop these two young lovers from being together even if it took years. Write Essay For Scholarship Hardship? This beautiful tale has a special. 2004 in film , Emotion , Interpersonal relationship 810 Words | 3 Pages. Running head: THE NOTEBOOK The Notebook This paper will analyze the movie “The Notebook ” . directed by Nick Cassavetes.

Different elements of paper payment, analyzing the film will be examined. Essay Writing Internet Pdf? These elements will be discussed in detail with examples provided. The elements being discussed are as follows: intent, story, plot and meaning, theatrical elements, cinematography, editing, sound, and the summary. The filmmaker’s intent in the movie “The Notebook ” is to make the story believable. Throughout. Editing , Emotion , English-language films 2139 Words | 7 Pages. at a Carnival in Seabrook, South Carolina. Noah and Allie meet for the first time and paper payment Noah falls instantly in love but Allie is not that quick. Noah and . Allie are thrown together by mutual friends Fin and with english message Sara.

Allie, Noah, Sarah and Fin go to a movie and paper Allie and literary anlaysis Noah walk home together and that is when the romance picks up. Allie falls for Noah. Allie and Noah spend almost every waking moment together, they fight they make up. One night Allie goes to Noah’s house and Noah decides to take Allie. 2007 films , 2007 singles , Elliott Smith 2032 Words | 5 Pages. the hypocritical relationship with people. He abandoned his old car, burned cash, and started on payment his exploration on foot. “I don’t need money. Make people . caution.

Rather than love, than money, than faith, than fame, than fairness, give me truth.”( Movie ). Help English Writing Message? During that time, he felt confused. Although seemed to Research payment understand, yet just only How to write short for scholarship hardship letter half-comprehended Thoreau’s poetry, one of the books he brought with hin during his journey. As Thoreau wrote in his book Walden, “I went to the woods because I whished. Christopher McCandless , Civil disobedience , Emotion 1042 Words | 3 Pages. ? the notebook Emmy de Munnik Wiesje Martens Table of content Assignment 1 - front page 2 - introduction roles 3 - plot . story 3, 4 - universal conflict storytelling device 5 - narrative pattern of Research paper payment, parallelism 5 - difference and Help writing message variation, similarity and repetition 5 Assignment 2 - front page 6 - introduction 7 - scene description 7 - internal external analysis 7 - three planes analysis 7, 8 Assignment. English-language films , Love 4903 Words | 23 Pages. TiHeather Winegardner March 13th, 2013 English 2367.0 Dr. Sonya Fix Formulation of Constructive Relations The two artifacts I chose to write about . are the films The Notebook and Research paper Titanic. The Notebook is a romantic film directed by Nick Cassavetes and based on the best-selling novel written by Nicholas Sparks. The two main characters are played by Ryan Gosling and Rachel McAdams who are madly in love. The film was released May 20th of 2004.

The next is Titanic, it is Pay for literary anlaysis paper use a romantic film directed. Kate Winslet , Leonardo DiCaprio , Love 1773 Words | 5 Pages. Corina Termini. My favorite movie : “The Notebook ” Movies give you inspiration to do or change many things in Life. Research? This is a . huge benefit on watching movies because they often give you something to Pay for literary anlaysis paper learn from, you can see probably how a bad decision can change you life forever, how people influence can sometimes be bad for you, how everyone is capable of paper, good thing in Help english writing, life, how by working hard you can achieve you goals, etc. So, trough movies you can get motivated and look forward in your life. English-language films , Horror film , Love 973 Words | 3 Pages. Analysis of paper payment, The Notebook The Notebook begins at a nursing home where an elderly man called “Duke” reads a love story that is . written in a notebook to an elderly woman who is also a patient. The story is set in Seabrook Island, South Carolina where a local boy by the name of essays for ap english, Noah Calhoun falls in love with a young heiress named Allie Hamilton. In order to get her to go on a date with him, Noah climbs up a Ferris wheel at the local carnival and threatens to jump off unless she agrees to go out.

2004 in film , Interpersonal relationship , Love 1085 Words | 2 Pages. issues, add a young actress who has really only shown her chops as a Mean Girl and a Hot Chick, bring them together in 1940's South Carolina, and don’t . Research Paper? forget to throw in two old fogies reflecting back at their youth. That, basically, is How to essay for scholarship hardship what The Notebook looks like on Research paper paper. Though a cookie cutter “love story” this may be, it still leaves some room for Dissertation service editing a few surprises to keep the super familiar subject matter just the paper slightest bit fresh. Allie (Rachel McAdams) is the rich girl on vacation. Gena Rowlands , James Garner , James Marsden 864 Words | 2 Pages. The Notebook By Nicholas Sparks Major Characters * Allison Hamilton – seventeen year old heiress, who shared an with, epic summer romance to . Noah. * Noah Calhoun – local country boy who fell in love to a city girl, Allison. * Anne Hamilton – Allison’s mother. * Lon Hammond – Allison’s fiance. Research Payment? Minor Characters * Martha Saw – a war widow, Noah’s girlfriend. * Frank Calhoun – Noah’s father. * John Hamilton – Allison’s father. * Fin – Noah’s friend. * Nurse Esther. Drama films , Love , Nicholas Sparks 2467 Words | 7 Pages. Proof Proof is a film by John Madden. This movie is based on literary anlaysis paper use a play written by David Aubum which was a Pulitzer Prize winning play.

This . was originally produced by the Manhattan Theatre Club on May 23, 2000. It was made into a movie in 2005. Paper Payment? Proof was acted out as in today’s times, not a replica that would have taken place decades ago. Pdf? The main cast members were Gwyneth Paltrow as Catherine, Anthony Hopkins as Catherine’s father and Research paper payment Jake Gyllenhaal as Hal. This film is Essay writing about a professor that. Anthony Hopkins , Coming out , Gwyneth Paltrow 1078 Words | 3 Pages. Brianna Efaw English Comp II Evaluation Happily Ever After I am evaluating the movie The Notebook directed by Research Nick Cassavetes . and written by Nicolas Sparks.

It features the perfect couple, Ryan Gosling and Rachel McAdams, who have a steamy romance throughout the movie . The couple goes through real life situations, ups and downs in for ap, their relationship, and end up together in the end of it all. It portrays the perfect romance with a twist viewers don’t see coming. To be a good romance film, it. A Walk to Remember , Romance , Romance film 842 Words | 2 Pages. Sweet Home Alabama vs. Paper? The Notebook an excess of movies in a particular genre.

The similarity is Pay for anlaysis use obvious in Research paper payment, Sweet Home Alabama and The Notebook since in with english message, both there is payment a seven . year absence period for the couples, their choices in How to write short letter, the types of lives they want to live are uncanny in appearance and the two girl's reasoning towards the end of the movie are the same. Research Payment? The differences are plenty and they include the genre of the movie itself and its effect on the differences in both, their reasons for turning back to the countryside, and. Alabama , Love , Marriage 863 Words | 3 Pages. ?The Notebook By Addison Hull, Sarah Hanson, Katey Reiff The Notebook , a novel written by Nicholas Sparks and published in . 1996, has become one of the most famous pieces of literature of its time, due to being considered a The New York Times Best Seller within the first week of the Help with book’s release and the novel stayed there for Research payment over a year. The Notebook tells the story of a contemporary love story set in internet pdf, the pre- and payment post – World War II era.

The seventeen year-old, Allie Hamilton, is message spending her. Adolescence , Fiction , Love 773 Words | 3 Pages. The Notebook During World War II a love between two social classes was something parents didn’t agree to. It wasn’t completely the parents’ . choice, but they still did pretty much anything to prevent it from happening. Paper? The Notebook comes from the novel written by Nicholas Sparks. It is a story of a girl born into a wealthy, upper class family, and a boy from a not-so-wealthy middle class family who fall in love but are torn apart because of social class. What I like about Essay this movie is how it.

Actor , Family , Middle class 756 Words | 2 Pages. The movie focuses on an old man reading a story to Research paper an old woman in a nursing home. The story he reads follows two young lovers named Allie . Consulting Service Editing? Hamilton and Noah Calhoun, who meet one evening at Research payment a carnival. But they are separated by Allie's parents who dissaprove of Noah's unwealthy family, and move Allie away. After waiting for Noah to write her for several years, Allie meets and gets engaged to a handsome young soldier named Lon. Pay For Literary Anlaysis Paper? Allie, then, with her love for Research payment Noah still alive, stops by Noah's 200-year-old. American films , English-language films , Interpersonal relationship 568 Words | 2 Pages. sense of the Help message impossible being overcome by true love, and Research this is enough to keep me, as well as the rest of the country, reading. The setting of all of . Sparks’ novels is in How to essay hardship letter, the coastal region of North Carolina, where Sparks currently resides. The Notebook takes place in New Bern, North Carolina, in the years 1932, 1946, and Research the present day, which is consulting service perfect for this novel as it adds an extra spark of Research payment, romanticism, since the beach naturally carries an Pay for paper, air of budding love.

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Operating Systems: IBM-AIX 4.2/4.3/5.x, Sun Solaris 8,9,10, Linux, Windows 2000/NT. Development/Build Tools: WSAD, RAD, JCreator, JDeveloper, ANT. GUI Front End Tools: Java Server Pages, Swing, Visual Basic 5.0/6.0, and Dissertation consulting service, Developer 2000. State Farm Insurance, Bloomington, IL Mar 07 to Till Date. Sr. WebSphere Administrator. #8226; Worked as a WebSphere Administrator designing and implementing solutions for Customer Satisfaction and Monitor applications. #8226; Build, deploy, and administer applications in WAS, Websphere MQ and Webserver environments. #8226; Written and used WSAdmin scripting (Jython, JACL and Ant) to automate Websphere builds and deployments for all environments leading to huge savings in deployment time for the company and also configuring and paper, testing the environment. Paper? #8226; Installed and Configured IBM Websphere Application Server, JDBC Drivers and Servlet Engines along with troubleshooting and recovery on AIX, Solaris and Windows. #8226; Work with Java developers throughout the software development cycle (Dev, Test, UAT and paper, Production) to Dissertation consulting, design, implement, and maintain Websphere websites throughout B2C applications. #8226; Recommend design considerations for Websphere apps in an enterprise application environment including clustering strategy, application deployment strategy, separation of Research presentation and business logic layer, monitoring and load testing all the Help message, resources. #8226; Implement workload management/fail-over strategy for all Websphere application servers including planning geographic fail-over for all Websphere websites. #8226; Daily backups, log archival, and other tasks using shell scripts using the Korn shell. #8226; Set-up security permissions in Websphere environments to paper payment, authenticate against LDAP servers to access Websphere consoles and secure it using SSL. #8226; Configured database resources like JDBC Providers, Data sources, and security resources like JAAS authentication (J2C) aliases in order to Help with, provide connectivity to Oracle, DB2 (mainframe and UDB), AS400 databases. #8226; Used Tivoli Performance Viewer (TPV) and Wily Introscope to payment, identify performance bottlenecks including application memory leaks, server process degradation, database connections, http threads, etc. #8226; Tune databases resource configurations including connection pooling, timeouts, etc. #8226; Troubleshoot problems with Websphere websites in all environments including Production using knowledge of the end-to-end architecture, log files (IHS plug-in and Websphere log files). Essay Writing? #8226; Responsible for Research, research and implementation of short essay for scholarship hardship letter latest software and fix packs for Research, Websphere Application Servers and some development tools. #8226; Planning and implementation of a stress-testing/load testing environment using Mercury Load Runner to test websites for load, amount of stress before an object breaks, number of hits, etc. With Message? #8226; Worked with Load testing team, sysadmin team to identify performance bottlenecks using LoadRunner, Wily Introscope, and payment, Tivoli Performance Viewer.

Environment: WebSphere Application Server 5.x,6.x, Solaris 8,9,10, AIX 5.3, Windows, JDBC, DB2, Oracle, IBM HTTP Server 1.x,2.x,6.x, Apache Web Server, Tivoli Access Manger 5.1, Wily Introscope 6, 7.x. Sr. WebSphere Administrator. #8226; Set-up new QA and How to write essay hardship, PROD environments by creating and managing the Nodes, Application Servers, and horizontal Clusterering for Load Balancing and Fail Over. #8226; Deployed application ears on WASND in QA, Staging and Production environments on a daily basis and troubleshot various configuration and Research payment, application issues like database issues and Dissertation consulting, http server issues. #8226; Trouble shooting various problems in different stages of development, QA and production using logs files, JVM Count and JDBC Connections, log analyzers and Research paper, custom shell scripts to look at the app. #8226; Performed WebSphere configuration, backup and restoration tasks (by using backupConfig, restoreConfig commands etc). #8226; Improved performance, reliability, and Custom essay writing reviews, scalability of the application server and its interaction with Web Servers, Database Servers. #8226; Tutored junior websphere admins and other windows staff on websphere clustering and scripting jacl and shell and documenting it. #8226; Worked with all the teams -- change control, oracle dba, db2 dba, mq team on a regular basis to resolve production issues and also in QA. #8226; Involved in Tuning of WebSphere Application Server for performance improvements. #8226; Managed multiple high-profile, complex projects and implement with minimal disruption to end users. #8226; Managed complex environments for the customer IT environments from a software support perspective for IBM WebSphere Application Server on both UNIX and windows platforms. #8226; Worked with QA Team for paper, Load Tests and Performance tests and identified the short hardship letter, bottlenecks of the applications. #8226; Worked with Security team for possible security threats to WebSphere Platform and configured Web servers to their recommendations. #8226; Responsible for applying patches and fixes to WebSphere 5.x to bring it up-to-date. #8226; Setup conference calls in paper the event of How to write short a PROD outage or slowness and efficiently resolve the issues as quickly as possible by getting all the Research paper payment, concerned teams together and writing pdf, co-coordinating the effort. #8226; Worked closely with AIX Server Team for Operating System tweaks for Performance. #8226; Responsible for configuring various performance monitoring tools like Wily Introscope. #8226; Involved in documentation of everyday activities and maintaining the doc-library. #8226; On-call support (24x7), Monitoring and maintaining multiple Applications. WAS Administrators / Application Support Analyst. #8226; Automate application install, uninstall and Research payment, application enhancements through Shell scripts and WSCP scripts. #8226; Experienced in Installing and Configuration of Application server Websphere 4.0/5.0. #8226; Experience in Installing and service editing, Configuration of Research paper Websphere servers like IBM Http server and Tomcat. #8226; Install, configure and maintain Internet, Intranet, Application and Essay internet, Database Servers like WebSphere, HTTP Server, DB2 on diverse UNIX flavors that includes AIX and Windows Platforms (NT/2000) in paper a multi clustered high availability environments. #8226; Developed UNIX shell scripts, JACL scripts to automate the WebSphere Administration (recycling the application server, deploying customer applications, logs rotation, monitor applications state, etc).

#8226; Package, build, Integrate and editing, deploy enterprise J2EE applications on WebSphere 4.0/5.0 that involves EAR (Enterprise Archives) and WAR (Web Archives). Paper Payment? #8226; Deploy on WAS and maintain the CCDR environment, work with developers and QA in troubleshooting problems related to the applications and essays for ap english, works with IBM on resolving complex websphere issues. #8226; Involved in trouble shooting and performance tuning using Resource Analyzer and Log Analyzer. Paper? #8226; Managed the security and performance optimizations for Custom essay writing reviews cheap, EJB containers and Research paper, web applications in IBM WebSphere, IBM HTTP Server and Apache web server. #8226; Ensure application dependencies are integrated on system level components such as database, Data Source Name (DSN), and Application Server connection pooling (DB2) including identification and documentation. #8226; Installed and configured IBM WebSphere Application Server 5.0/4.0, JDBC drivers and Served engines along with trouble shooting and recovery. #8226; Responsible for application changes across different platforms- development, testing and production. #8226; Involved in Dissertation consulting service monitoring, shutdown and boot up, Network Support and Trouble Shooting. #8226; Installation of Netegrity Siteminder and Research payment, and its agent on webserver and integration, creating rules and policies or different applications and settings like timeout, cookies. #8226; Used import/export ldif commands and changed user passwords and activate/deactivate accounts using ldapmodify. #8226; Worked closely with Project manager, development, testing and production team to align project deliverables, dates and report issues/concerns. Environment: WebSphere Application Server 4.0,s5.x, Solaris 8,9 AIX, DB2, Oracle, SQL Server, Sun-one webserver, Sun-one Directory Server, Netegrity Siteminder. SBC, St.Louis, MO Jun 01 -- Nov 03. Essays? #8226; Maintained separate development, test, and production environments Application Server. Research? #8226; Installed MQ Series on the Solaris environment for the Development and internet, Test environments. #8226; Installed JDBC drivers and Servlet engines on Sun Solaris. #8226; Network Administration - involving day-to-day routine checks, Configuration of Research paper payment LAN adapters, Routing, NFS, DNS and Troubleshooting. #8226; Developed WSCP, XMLConfig scripts for the Production, Test environments. Essay Reviews Cheap? #8226; Configured Workload Management (WLM) for Application Server. #8226; Installed and implemented the CVS repository on the Solaris environment. Maintained the repository for the Development, Test and Production environments. #8226; Performed Stress and Performance testing of applications. #8226; Involved in pre-production staging and production deployment of application code. #8226; Analyze user requirements in order to determine scope, develop implementation strategies, and manage user expectations. Research Paper Payment? #8226; Experienced in designing and developing applications using UML and Rational Tools. #8226; Working knowledge of Visual Age for Java, Eclipse, CVS (Open source configuration management tool), and Cactus (for unit testing). #8226; Involved in Regression Testing of functional areas where defects or bugs were logged or reported. #8226; Tested Performance of Client /Server Application.

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compliance resume SUBJECT: EEOC COMPLIANCE MANUAL. PURPOSE: This transmittal covers the paper issuance of Section 12 of the new Compliance Manual on “Religious Discrimination.” The section provides guidance and instructions for investigating and anlaysis, analyzing charges alleging discrimination based on Research payment religion. EFFECTIVE DATE: Upon receipt. DISTRIBUTION: EEOC Compliance Manual holders.

OBSOLETE DATA: This Section of the Compliance Manual replaces Section 628: Religious Accommodation , EEOC Compliance Manual, Volume II and its Appendices: Appendix A, Policy Statement on Ansonia Board of Education v. Philbrook and Religious Accommodation ; Appendix B, Policy Guidance On ‘New Age’ Training Programs Which Conflict With Employees’ Religious Beliefs ; and Appendix C, Religious Objections to Unionism . It also replaces the following policy documents: Religious Organizations that Pay Women Less than Men in Accordance with Religious Beliefs ; Religious Organization Exemption Under Title VII of the Civil Rights Act of 1964, as amended ; and Policy Statement on Writing for ap Goldman v. Weinberger (Accommodation of the Wearing of Religious Dress) . The Commission’s Guidelines on Discrimination Because of Research Religion, 29 C.F.R. Part 1605, remain in effect. SECTION 12: RELIGIOUS DISCRIMINATION. SECTION 12: RELIGIOUS DISCRIMINATION. This Section of the Compliance Manual focuses on with english writing message religious discrimination under Title VII of the Civil Rights Act of 1964 (Title VII). [2] Title VII protects workers from employment discrimination based on their race, color, religion, sex, national origin, or protected activity. Payment? Solely with respect to religion, Title VII also requires reasonable accommodation of Pay for literary anlaysis use employees’ [3] sincerely held religious beliefs, observances, and practices when requested, unless accommodation would impose an undue hardship on business operations. [4] Undue hardship under Title VII is defined as “more than de minimis ” cost or burden -- a substantially lower standard for payment, employers to How to short for scholarship hardship, satisfy than the “undue hardship” defense under the Americans with Disabilities Act (ADA), which is defined instead as “significant difficulty or expense.” [5] The prohibition on discrimination and the requirement of reasonable accommodation apply whether the paper religious views in question are mainstream or non-traditional, and even if not recognized by any organized religion. Essay Writing? These protections also extend to those who profess no religious beliefs. [6] Questions about religion in paper, the workplace have increased as religious pluralism has increased.

In a 2001 survey of human resource professionals conducted by Custom essay writing reviews the Society for Human Resource Management and the Tanenbaum Center for Interreligious Understanding, 36% of human resource professionals who responded reported an increase in the religious diversity of their employees in the preceding five years. [7] Further, the number of religious discrimination charges filed with EEOC has more than doubled from 1992 to 2007, although the total number of paper such charges remains relatively small compared to charges filed on for ap other bases. [8] Many employers seek legal guidance in managing the issues that arise as religious diversity in the American workplace continues to increase. [9] This Section of the Compliance Manual is designed to paper, be a practical resource for employers, employees, practitioners, and How to write essay for scholarship letter, EEOC enforcement staff on Title VII’s prohibition against religious discrimination. The Section defines religious discrimination, discusses typical scenarios in which religious discrimination may arise, and provides guidance to employers on how to balance the needs of individuals in a diverse religious climate. [10] The Section is organized by Research paper legal topic, as follows: I - Coverage issues , including the Writing essays definition of “religion” and “sincerely held,” the paper religious organization exception, and the ministerial exception. II - Disparate treatment analysis of employment decisions based on editing religion, including recruitment, hiring, promotion, discipline, and compensation, as well as differential treatment with respect to paper payment, religious expression; customer preference; security requirements; and bona fide occupational qualifications. III - Harassment analysis , including religious belief or practice as a condition of employment or advancement, hostile work environment, and employer liability issues.

IV - Reasonable accommodation analysis , including notice of the Pay for literary anlaysis paper use conflict between religion and work, scope of the accommodation requirement and undue hardship defense, and Research paper, common methods of accommodation. V - Related forms of discrimination , including discrimination based on national origin, race, or color, as well as retaliation. Some charges of religious discrimination may raise multiple claims, for example requiring analysis under disparate treatment, harassment, and denial of reasonable accommodation theories of liability. In addition, there are some instances where Title VII religious discrimination cases implicate federal constitutional provisions. [11] For example, a government employer may contend that granting a requested religious accommodation would pose an undue hardship because it would constitute government endorsement of religion in violation of the Establishment Clause of the First Amendment. [12] A private sector employer may contend that its own First Amendment rights under the Free Exercise or Free Speech Clauses would be violated if it is compelled by Title VII to grant a particular accommodation. [13] In addition, government employees often raise claims under the First Amendment parallel to their Title VII accommodation claims. [14] Defining the Writing english exact parameters of the First Amendment is beyond the scope of this document. However, these First Amendment issues are referenced throughout this document in order to illustrate how they often arise in Title VII cases. [15] Title VII prohibits covered employers, employment agencies, and unions [16] from: (1) treating applicants or employees differently (disparate treatment) based on Research their religious beliefs or practices or lack thereof in How to write short essay hardship, any aspect of employment, including recruitment, hiring, assignments, discipline, promotion, and benefits; (2) subjecting employees to harassment because of their religious beliefs or practices or lack thereof or because of the Research payment religious practices or beliefs of people with whom they associate ( e.g. , relatives, friends, etc.); (3) denying a requested reasonable accommodation of an applicant’s or employee’s sincerely held religious beliefs or practices or lack thereof if an accommodation will not impose an undue hardship on the conduct of the business; [17] and, (4) retaliating against Custom essay cheap an applicant or employee who has engaged in protected activity, including participation ( e.g. Research Paper Payment? , filing an EEO charge or testifying as a witness in someone else’s EEO matter), or opposition relating to alleged religious discrimination ( e.g. , complaining to Writing for ap, human resources department about alleged religious discrimination). Although more than one of these theories of liability may apply in a particular case, they are discussed in Research paper payment, separate parts of this manual for ease of use.

Charges involving religion may give rise to claims for disparate treatment, harassment, denial of reasonable accommodation, and/or retaliation. Therefore, these charges should be investigated and analyzed under all four theories of liability to the extent applicable, even if the charging party only raises one claim. Overview: Religion is very broadly defined under Title VII. Religious beliefs, practices, and observances include those that are theistic [18] in nature, as well as non-theistic “moral or ethical beliefs as to what is right and wrong which are sincerely held with the strength of traditional religious views.” Religious beliefs can include unique views held by a few or even one individual; however, mere personal preferences are not religious beliefs. Title VII requires employers to accommodate religious beliefs, practices, and observances if the beliefs are “sincerely held” and the reasonable accommodation poses no undue hardship on the employer. Title VII defines “religion” to include “all aspects of religious observance and practice as well as belief.” [19] Religion includes not only traditional, organized religions such as Christianity, Judaism, Islam, Hinduism, and Buddhism, but also religious beliefs that are new, uncommon, not part of a formal church or sect, only write hardship subscribed to by a small number of people, or that seem illogical or unreasonable to paper payment, others. [20] Further, a person’s religious beliefs “need not be confined in either source or content to traditional or parochial concepts of Essay religion.” [21] A belief is “religious” for Research payment, Title VII purposes if it is “‘religious’ in the person’s own scheme of things,” [22] i.e. , it is “a sincere and meaningful belief that occupies in the life of its possessor a place parallel to consulting service editing, that filled by God.” [23] An employee’s belief or practice can be “religious” under Title VII even if the employee is affiliated with a religious group that does not espouse or recognize that individual’s belief or practice, or if few or no other people adhere to it. [24]

Religious beliefs include theistic beliefs as well as non-theistic “moral or ethical beliefs as to what is right and wrong which are sincerely held with the strength of traditional religious views.” [25] Although courts generally resolve doubts about particular beliefs in favor of finding that they are religious, [26] beliefs are not protected merely because they are strongly held. Rather, religion typically concerns “ultimate ideas” about “life, purpose, and death.” [27] Social, political, or economic philosophies, as well as mere personal preferences, are not “religious” beliefs protected by Title VII. [28] Religious observances or practices include, for example, attending worship services, praying, wearing religious garb or symbols, displaying religious objects, adhering to certain dietary rules, proselytizing or other forms of religious expression, or refraining from paper certain activities. Pay For Literary Paper? Determining whether a practice is religious turns not on the nature of the activity, but on the employee’s motivation. Research Paper Payment? The same practice might be engaged in Writing, by one person for religious reasons and by paper another person for purely secular reasons.

Whether or not the practice is “religious” is therefore a situational, case-by-case inquiry. [29] For example, one employee might observe certain dietary restrictions for religious reasons while another employee adheres to the very same dietary restrictions but for secular ( e.g. , health or environmental) reasons. [30] In that instance, the same practice might in one case be subject to service, reasonable accommodation under Title VII because an paper payment employee engages in the practice for Pay for use, religious reasons, and in another case might not be subject to reasonable accommodation because the practice is engaged in for secular reasons. The following examples illustrate these concepts: Employment Decisions Based on “Religion” An otherwise qualified applicant is not hired because he is Research payment, a self-described evangelical Christian. A qualified non-Jewish employee is denied promotion because the supervisor wishes to give a preference based on Custom religion to a fellow Jewish employee. An employer terminates an employee based on his disclosure to the employer that he has recently converted to the Baha’i Faith. Each of these is an example of an employment decision based on the religious affiliation of the applicant or employee, and payment, therefore is paper, based on “religion” within the Research payment meaning of writing cheap Title VII.

Religious Practice versus Secular Practice. A Seventh-day Adventist employee follows a vegetarian diet because she believes it is religiously prescribed by the scriptural passage “[b]ut flesh with the life thereof, which is the blood thereof, shall ye not eat,” (Genesis 9:4). Paper? Her vegetarianism is Custom writing reviews, a religious practice, even though not all Seventh-day Adventists share this belief or follow this practice, and payment, even though many individuals adhere to a vegetarian diet for purely secular reasons. Types of Religious Practice or Observance. A Catholic employee requests a schedule change so that he can attend church services on Good Friday. How To Write For Scholarship Hardship Letter? A Muslim employee requests an exception to the company’s dress and grooming code allowing her to wear her headscarf, or a Hindu employee requests an exception allowing her to wear her bindi (religious forehead marking). An atheist asks to be excused from the religious invocation offered at Research the beginning of staff meetings. An adherent to Native American spiritual beliefs seeks unpaid leave to Pay for, attend a ritual ceremony. An employee who identifies as Christian but is Research, not affiliated with a particular sect or denomination requests accommodation of his religious belief that working on his Sabbath is prohibited.

Each of these accommodation requests relates to a “religious” belief or practice within the meaning of Custom reviews Title VII. By contrast, a request for a schedule change to help set up decorations or prepare food for payment, a church event, for instance, typically does not involve a “religious” belief or practice within the write essay for scholarship meaning of Title VII. [31] Supervisor Considers Belief Illogical. Morgana asks for time off on October 31 to attend the “Samhain Sabbat,” the New Year observance of Research Wicca, her religion. Her supervisor refuses, saying that Wicca is not a “real” religion but an “illogical conglomeration” of “various aspects of the occult, such as faith healing, self?hypnosis, tarot card reading, and spell casting, which are not religious practices.” The supervisor’s refusal to accommodate her on the ground that he believes her religion is illogical violates Title VII unless the employer can show her request would impose an undue hardship.

The law applies to religious beliefs even though others may find them “incorrect” or “incomprehensible.” [32] Unique Belief Can Be Religious. Edward practices the Kemetic religion, based on ancient Egyptian faith, and pdf, affiliates himself with a tribe numbering fewer than ten members.He states that he believes in Research paper payment, various deities, and follows the editing faith’s concept of Ma’at, a guiding principle regarding truth and order that represents physical and moral balance in the universe. During a religious ceremony he received small tattoos encircling his wrist, written in the Coptic language, which express his servitude to Ra, the Egyptian god of the sun. When his employer asks him to Research, cover the tattoos, he explains that it is with message, a sin to cover them intentionally because doing so would signify a rejection of Ra. These can be religious beliefs and practices even if no one else or few other people subscribe to paper payment, them. [33] Personal Preference That is Not a Religious Belief. Sylvia wears several tattoos and has recently had her nose and eyebrows pierced. A newly hired manager implements a dress code that requires that employees have no visible piercings or tattoos. Pay For Literary Anlaysis Paper? Sylvia says that her tattoos and Research paper payment, piercings are religious because they reflect her belief in body art as self-expression and should be accommodated.

However, the Writing essays for ap evidence demonstrates that her tattoos and piercings are not related to any religious belief system. For example, they do not function as a symbol of any religious belief, and do not relate to any “ultimate concerns” such as life, purpose, death, humanity’s place in the universe, or right and Research paper, wrong, and they are not part of a moral or ethical belief system. Therefore, her belief is a personal preference that is not religious in nature. [34] Title VII requires employers to Dissertation consulting, accommodate only those religious beliefs that are “sincerely held.” [35] Therefore, whether or not a religious belief is “sincerely held” by an applicant or employee is only relevant to religious accommodation, not to claims of disparate treatment or harassment because of payment religion. In those claims, it is the motivation of the discriminating official, not the actual beliefs of the individual alleging discrimination, that are typically relevant in determining if the discrimination that occurred was because of religion. A detailed discussion of reasonable accommodation of write for scholarship sincerely held religious beliefs appears in § IV, but the meaning of Research paper payment “sincerely held” is addressed here. Like the “religious” nature of a belief or practice, the “sincerity” of an employee’s stated religious belief is usually not in dispute. Nevertheless, there are some circumstances in which an english message employer may assert as a defense that it was not required to Research paper payment, provide accommodation because the employee’s asserted religious belief was not sincerely held.

Factors that either alone or in combination might undermine an employee’s assertion that he sincerely holds the Dissertation consulting religious belief at issue include: whether the employee has behaved in Research payment, a manner markedly inconsistent with the professed belief; [36] whether the accommodation sought is a particularly desirable benefit that is likely to be sought for secular reasons; whether the essays english timing of the request renders it suspect ( e.g. , it follows an paper earlier request by the employee for the same benefit for write essay for scholarship hardship, secular reasons); and whether the employer otherwise has reason to believe the accommodation is not sought for paper, religious reasons. Pay For Literary Anlaysis Paper? However, none of these factors is Research payment, dispositive. For example, although prior inconsistent conduct is relevant to the question of sincerity, an individual’s beliefs or degree of adherence may change over time, and Dissertation service, therefore an employee’s newly adopted or inconsistently observed religious practice may nevertheless be sincerely held. [37] An employer also should not assume that an Research paper payment employee is insincere simply because some of his or her practices deviate from the commonly followed tenets of his or her religion. [38] 3. Employer Inquiries into Religious Nature or Sincerity of service editing Belief. Because the definition of religion is broad and Research paper, protects beliefs and practices with which the employer may be unfamiliar, the employer should ordinarily assume that an employee’s request for religious accommodation is based on a sincerely-held religious belief. If, however, an writing employee requests religious accommodation, and an employer has an objective basis for questioning either the religious nature or the sincerity of Research a particular belief or practice, the employer would be justified in writing, seeking additional supporting information. Payment? See infra § IV-A-2. If the Respondent (R) disputes that the Charging Party’s (“CP’s”) belief is “religious,” consider the following: Begin with the CP’s statements. Pay For Anlaysis? What religious belief or practice does the CP claim to Research, have? In some cases, the CP’s credible testimony regarding his belief or practice will be sufficient to demonstrate that it is religious.

In other cases, however, the investigator may need to ask follow-up questions about the nature and tenets of the asserted religious beliefs, and/or any associated practices, rituals, clergy, observances, etc., in order to identify a specific religious belief or practice or determine if one is at issue. Since religious beliefs can be unique to an individual, evidence from others is paper, not always necessary. Payment? However, if the write short essay letter CP believes such evidence will support his or her claim, the investigator should seek evidence such as oral statements, affidavits, or other documents from CP’s religious leader(s) if applicable, or others whom CP identifies as knowledgeable regarding the religious belief or practice in question. Remember, where an Research payment alleged religious practice or belief is at issue, a case-by-case analysis is essay writing reviews, required. Investigators should not make assumptions about a religious practice or belief. Research Paper? In some cases, to determine whether CP’s asserted practice or belief is “religious” as defined under Title VII, the investigator’s general knowledge will be insufficient, and additional objective information will have to be obtained, while nevertheless recognizing the intensely personal characteristics of adherence to Writing essays english, a religious belief. If the Respondent disputes that CP’s belief is “sincerely held,” the following evidence may be relevant:

Oral statements, an affidavit, or other documents from CP describing his or her beliefs and practices, including information regarding when CP embraced the belief or practice, as well as when, where, and how CP has adhered to the belief or practice; and/or, Oral statements, affidavits, or other documents from Research paper payment potential witnesses identified by CP or R as having knowledge of whether CP adheres or does not adhere to the belief or practice at issue ( e.g ., CP’s religious leader (if applicable), fellow adherents (if applicable), family, friends, neighbors, managers, or co-workers who may have observed his past adherence or lack thereof, or discussed it with him). Overview: Title VII jurisdictional rules apply to Help with, all religious discrimination claims under the statute. However, specially-defined “religious organizations” and Research payment, “religious educational institutions” are exempt from certain religious discrimination provisions, and a “ministerial exception” bars Title VII claims by Dissertation editing employees who serve in clergy roles. Title VII’s prohibitions apply to employers, employment agencies, and unions, [39] subject to the statute’s jurisdictional requirements.

See EEOC Compliance Manual, “Threshold Issues,” https://www.eeoc.gov/policy/docs/threshold.html. Those covered entities must carry out their activities in a nondiscriminatory manner and Research paper payment, provide reasonable accommodation unless doing so would impose an undue hardship. Paper? [40] Unions also can be liable if they knowingly acquiesce in employment discrimination against their members, join or tolerate employers’ discriminatory practices, or discriminatorily refuse to represent employees’ interests. [41] Under Title VII, religious organizations are permitted to give employment preference to members of their own religion. [42] The exception applies only to those institutions whose “purpose and character are primarily religious.” [43] That determination is to be based on “[a]ll significant religious and secular characteristics.” [44] Although no one factor is dispositive, significant factors to consider that would indicate whether an entity is religious include: Do its articles of incorporation state a religious purpose? Are its day-to-day operations religious ( e.g. , are the services the entity performs, the product it produces, or the educational curriculum it provides directed toward propagation of the religion)? Is it not-for-profit? Is it affiliated with or supported by a church or other religious organization? [45] This exception is not limited to religious activities of the organization. [46] However, it only allows religious organizations to prefer to employ individuals who share their religion. [47] The exception does not allow religious organizations otherwise to paper payment, discriminate in employment on Help with writing message protected bases other than religion, such as race, color, national origin, sex, age, or disability. [48] Thus, a religious organization is not permitted to engage in racially discriminatory hiring by asserting that a tenet of its religious beliefs is not associating with people of payment other races. Pay For Anlaysis Paper? Similarly, a religious organization is not permitted to deny fringe benefits to married women but not to married men by Research payment asserting a religiously based view that only men can be the head of a household. Sex Discrimination Not Excused.

Justina works at Tots Day Care Center. Custom Writing Reviews? Tots is run by a religious organization that believes that, while women may work outside of the home if they are single or have their husband’s permission, men should be the heads of their households and Research paper, the primary providers for their families. Believing that men shoulder a greater financial responsibility than women, the organization pays female teachers less than male teachers. The organization’s practice of unequal pay based on sex constitutes unlawful discrimination. [49] Courts have held, based on First Amendment constitutional considerations, that clergy members cannot bring claims under the federal employment discrimination laws, including Title VII, the Age Discrimination in Employment Act, the Help english writing message Equal Pay Act, and the Americans with Disabilities Act, because “[t]he relationship between an organized church and its ministers is its lifeblood.” [50] This “ministerial exception” comes not from the text of the statutes, but from the First Amendment principle that governmental regulation of church administration, including the appointment of clergy, impedes the free exercise of religion and constitutes impermissible government entanglement with church authority. Research Paper? [51] Thus, courts will not ordinarily consider whether a church’s employment decision concerning one of its ministers was based on discriminatory grounds, although some courts have allowed ministers to bring sexual harassment claims. [52] The ministerial exception applies only to those employees who perform essentially religious functions, namely those whose primary duties consist of engaging in church governance, supervising a religious order, or conducting religious ritual, worship, or instruction. [53] The exception is not limited to ordained clergy, [54] and has been applied by courts to others involved in clergy-like roles who conduct services or provide pastoral counseling. Writing? However, the exception does not necessarily apply to everyone with a title typically conferred upon Research clergy ( e.g. , minister). For Scholarship Hardship? [55] In short, in each case it is necessary to Research payment, make a factual determination of whether the function of the consulting service position is one to Research, which the exception applies. Title VII’s prohibition against disparate treatment based on religion generally functions like its prohibition against disparate treatment based on race, color, sex, or national origin.

Disparate treatment violates the statute whether motivated by bias against or preference toward an applicant or employee due to Custom essay reviews, his religious beliefs, practices, or observances or lack thereof. Thus, for example, except to the extent permitted by the religious organization and Research payment, ministerial exceptions, an employer may not refuse to recruit, hire, or promote individuals of a certain religion, may not impose stricter promotion requirements for persons of a certain religion, and may not impose more or different work requirements on an employee because of that employee’s religious beliefs or practices. English Message? [56] The following sub-sections address work scenarios that may lead to claims of religious discrimination. 1. Recruitment, Hiring, and Promotion. Employers that are not religious organizations may neither recruit individuals of a particular religion nor adopt recruitment practices, such as word-of-mouth recruitment, that have the purpose or effect of discriminating based on religion. Title VII permits employers that are not religious organizations to Research paper payment, hire and employ employees on the basis of with english message religion only if religion is “a bona fide occupational qualification reasonably necessary to the normal operation of that particular business or enterprise.” [57]

For example, an employer may not refuse to Research paper payment, hire an applicant simply because he does not share the employer’s religious beliefs, and conversely may not select one applicant over another based on a preference for employees of a particular religion. [58] Similarly, employment agencies may not comply with requests from Pay for literary employers to engage in discriminatory recruitment or referral practices, for example by paper payment screening out applicants who have names often associated with a particular religion ( e.g., Mohammed). Moreover, an employer may not exclude an with message applicant from hire merely because he or she may need a reasonable accommodation that could be provided absent undue hardship. [59] Charles, the president of a company that owns several gas stations, needs managers for the new convenience stores he has decided to add to Research paper payment, the stations. Write Letter? He posts a job announcement at the Hindu Temple he attends and asks other members of the temple to Research payment, refer only Hindu friends or family members who may be interested in Pay for literary anlaysis, the position. He does no other recruitment. Research? By limiting his recruitment to Hindus, Charles is engaging in Writing, unlawful discrimination. Mary is Research payment, a human resources officer who is Pay for literary anlaysis, filling a vacant administrative position at paper her company. During the application process, she performs an Internet search on the candidates and writing reviews cheap, learns that one applicant, Jonathan, has written an article for the local chapter of the Ethical Society setting forth his view that religion has been historically divisive and explaining why he subscribes to Research paper, no religious beliefs or practices.

Although Mary believes he is the Help english message most qualified candidate, she does not hire him because she knows that many current company employees are observant Christians like her, and she believes they would be more comfortable working with someone like-minded. By not hiring Jonathan because of paper payment his lack of religious identification, the company violated Title VII. Darpak, who practices Buddhism, holds a Ph.D. degree in engineering and applied for with english, a managerial position at the research firm where he has worked for ten years. He was rejected in paper payment, favor of a non-Buddhist candidate who was less qualified. The company vice president who made the literary paper use promotion decision advised Darpak that he was not selected because “we decided to go in Research paper payment, a different direction.” However, the vice president confided to co-workers at essay writing reviews a social function that he did not select Darpak because he thought a Christian manager could make better personal connections with the firm’s clients, many of whom are Christian. The vice president’s statement, combined with the lack of any legitimate non-discriminatory reason for Research, selecting the less qualified candidate, as well as the evidence that Darpak was the best qualified candidate for the position, suggests that the proffered reason was a pretext for discrimination against Darpak because of his religious views. [60] Title VII also prohibits employers from disciplining or discharging employees because of essay cheap their religion. [61] Joanne, a retail store clerk, is frequently 10-15 minutes late for her shift on several days per paper payment week when she attends Mass at a Catholic Church across town. Her manager, Donald, has never disciplined her for this tardiness, and instead filled in for her at the cash register until she arrived, stating that he understood her situation. On the other hand, Yusef, a newly hired clerk who is Muslim, is disciplined by Donald for arriving 10 minutes late for his shift even though Donald knows it is due to his attendance at services at the local Mosque.

While Donald can require all similarly situated employees to be punctual, he is engaging in disparate treatment based on religion by disciplining only Yusef and not Joanne absent a legitimate nondiscriminatory reason for Pay for, treating them differently. A charge alleging the above facts might also present a claim for denial of reasonable accommodation. While the Research payment employer may require employees to Pay for use, be punctual, it may have to paper payment, accommodate an employee who seeks leave or a schedule change to pdf, resolve the conflict between religious services and a work schedule, unless the accommodation would pose an undue hardship. [62] 3. Compensation and payment, Other Terms, Conditions, or Privileges of Employment. Title VII prohibits discrimination on a protected basis “with respect to . . Essays English? . Research? compensation, terms, conditions, or privileges of employment,” for example, setting or adjusting wages, granting benefits, and/or providing leave in with english writing, a discriminatory fashion. [63] Wages and Benefits. Janet, who practices Native American spirituality, is a newly hired social worker for an agency. As a benefit to its employees, the agency provides tuition reimbursement for professional continuing education courses offered by Research payment selected providers. Janet applied for tuition reimbursement for an approved course that was within permitted cost limit. Janet’s supervisor denied her request for tuition reimbursement, stating that since Janet believes in “voodoo” she “won’t make a very good caseworker.” By refusing, because of Janet’s religious beliefs, to provide the tuition reimbursement to literary use, which Janet was otherwise entitled as a benefit of payment her employment, Janet’s supervisor has discriminated against Janet on the basis of religion. Title VII’s prohibition on disparate treatment based on religious beliefs also can apply to disparate treatment of religious expression in the workplace. [64]

Eve is a secretary who displays a Bible on her desk at work. English Message? Xavier, a secretary in the same workplace, begins displaying a Quran on his desk at work. Their supervisor allows Eve to retain the Research paper Bible but directs Xavier to put the Quran out of view because, he states, co-workers “will think you are making a political statement, and with everything going on in the world right now we don’t need that around here.” This differential treatment of similarly situated employees with respect to the display of a religious item at work constitutes disparate treatment based on religion in violation of How to hardship Title VII. Payment? [65] Charges involving religious expression may present claims not only of disparate treatment, but also of harassment and/or denial of reasonable accommodation. Investigation of claims of harassment and denial of Essay internet pdf reasonable accommodation are addressed respectively in §§ III and IV of this document. As discussed in greater detail in those sections, Title VII requires employers to accommodate expression that is based on a sincerely held religious practice or belief, unless it threatens to paper, constitute harassment or otherwise poses an consulting editing undue hardship on the conduct of the business. Thus, for example, an employer can restrict religious expression where it would cause customers or co-workers reasonably to perceive the materials to express the employer’s own message, or where the Research payment item or message in question is harassing or otherwise disruptive. [66] For further discussion of how to analyze when accommodation of write essay religious expression would pose an undue hardship, refer to the sections on paper Harassment at service § III-C and Accommodation at Research paper § IV-C-6. If an employer takes an essays english action based on the discriminatory preferences of others, including co-workers or clients, the employer is unlawfully discriminating. Employment Decision Based on Research paper Customer Preference. Harinder, who wears a turban as part of his Sikh religion, is hired to work at the counter in a coffee shop. A few weeks after Harinder begins working, the literary anlaysis manager notices that the work crew from the construction site near the shop no longer comes in for coffee in the mornings.

When he inquires, the crew complains that Harinder, whom they mistakenly believe is Muslim, makes them uncomfortable in light of the paper September 11 th attacks. The manager tells Harinder that he has to Custom reviews cheap, let him go because the customers’ discomfort is understandable. The manager has subjected Harinder to unlawful religious discrimination by taking an Research payment adverse action based on customers’ preference not to have a cashier of Harinder’s perceived religion. Harinder’s termination based on Dissertation editing customer preference would violate Title VII regardless of whether he was Muslim, Sikh, or any other religion. In general, an employer may adopt security requirements for its employees or applicants, provided they are adopted for nondiscriminatory reasons and are applied in a nondiscriminatory manner. Payment? For example, an employer may not require Muslim applicants to literary use, undergo a background investigation or more extensive security procedures because of paper payment their religion while not imposing the same requirements on similarly situated applicants who are non-Muslim, unless such job requirements are imposed by federal statute or Executive Order in Dissertation service, the interest of national security. [67]

D. Bona Fide Occupational Qualification. Title VII permits employers to hire and employ employees on the basis of religion if religion is “a bona fide occupational qualification [“BFOQ”] reasonably necessary to the normal operation of Research payment that particular business or enterprise.” [68] Religious organizations do not typically need to rely on this BFOQ defense, however, because the “religious organization” exception in Title VII permits them to english message, prefer their co-religionists. Research? See supra § I-C. It is well settled that for employers that are not religious organizations and therefore seek to rely on the BFOQ defense to justify a religious preference, the defense is a narrow one and can rarely be successfully invoked. Essay Writing? [69] Employers can reduce the risk of discriminatory employment decisions by establishing written objective criteria for evaluating candidates for hire or promotion and applying those criteria consistently to all candidates. In conducting job interviews, employers can ensure nondiscriminatory treatment by asking the same questions of all applicants for a particular job or category of payment job and writing, inquiring about matters directly related to the position in question. Research Payment? Employers can reduce the risk of religious discrimination claims by carefully and timely recording the accurate business reasons for disciplinary or performance?related actions and sharing these reasons with the affected employees. When management decisions require the exercise of reviews subjective judgment, employers can reduce the risk of discriminatory decisions by providing training to inexperienced managers and payment, encouraging them to consult with more experienced managers or human resources personnel when addressing difficult issues.

If an employer is confronted with customer biases, e.g., an adverse reaction to being served by Pay for literary anlaysis paper use an employee due to religious garb, the employer should consider engaging with and educating the customers regarding any misperceptions they may have and/or the equal employment opportunity laws. Overview: Religious harassment is payment, analyzed and proved in literary anlaysis paper use, the same manner as harassment on other Title VII bases, e.g., race, color, sex, or national origin. [70] However, the facts of religious harassment cases may present unique considerations, especially where the alleged harassment is based on another employee’s religious practices a situation that may require an employer to Research payment, reconcile its dual obligations to take prompt remedial action in internet, response to alleged harassment and to accommodate certain employee religious expression. Religious harassment in violation of Title VII occurs when employees are: (1) required or coerced to abandon, alter, or adopt a religious practice as a condition of Research paper payment employment (this type of “quid pro quo” harassment may also give rise to a disparate treatment or denial of accommodation claim in some circumstances), [71] or (2) subjected to unwelcome statements or conduct that is based on Dissertation service religion and is so severe or pervasive that the individual being harassed reasonably finds the work environment to be hostile or abusive, and paper payment, there is literary use, a basis for holding the employer liable. [72] 1. Religious Coercion That Constitutes a Tangible Employment Action. Title VII is violated when an employer or supervisor explicitly or implicitly coerces an employee to abandon, alter, or adopt a religious practice as a condition of receiving a job benefit or avoiding an adverse action. [73] Religious Conformance Required for Promotion. Wamiq was raised as a Muslim but no longer practices Islam. His supervisor, Arif, is a very devout Muslim who tries to persuade Wamiq not to abandon Islam and advises him to follow the paper teachings of the Quran. Arif also says that if Wamiq expects to How to short essay, advance in the company, he should join Arif and other Muslims for weekly prayer sessions in Arif’s office. Notwithstanding this pressure to conform his religious practices in order to be promoted, Wamiq refused to Research payment, attend the weekly prayer sessions, and was subsequently denied the promotion for which he applies even though he was the most qualified. Arif’s conduct indicates that the promotion would have been granted if Wamiq had participated in the prayer sessions and had become an observant Muslim.

Absent contrary evidence, the employer will be liable for harassment for conditioning Wamiq’s promotion on his adherence to Arif’s views of appropriate religious practice. [74] This would also be actionable as disparate treatment based on essays english religion. Research? In addition, if the prayer sessions were made mandatory and Wamiq had asked to be excused on religious grounds, Arif would have been required to Dissertation consulting service editing, excuse him from the prayer sessions as a reasonable accommodation. A claim of harassment based on coerced religious participation or non-participation, however, only arises where it was intended to make the employee conform to or abandon a religious belief or practice. By contrast, an employer would not be engaging in coercion if it required an employee to participate in a workplace activity that conflicts with the employee’s sincerely held religious belief, so long as the employer demonstrates that it would impose an undue hardship to paper, accommodate the essay reviews employee’s request to be excused. However, the same fact pattern may give rise to claims of disparate treatment, harassment, and/or denial of paper accommodation. For example, terminating rather than accommodating an employee may give rise to How to write short essay for scholarship hardship letter, both denial of accommodation and discriminatory discharge claims. Payment? [75] For discussion of the accommodation issue, see § IV, infra .[76] Title VII’s prohibition against religious discrimination can also be violated if the writing cheap employee is subjected to Research payment, a hostile work environment because of writing internet pdf religion. Payment? [77] An unlawful hostile environment based on religion might take the form of either verbal or physical harassment or unwelcome imposition of religious views or practices on service an employee. A hostile work environment is created when the “workplace is permeated with discriminatory intimidation, ridicule, and insult that is sufficiently severe or pervasive to alter the conditions of the victim’s employment and Research paper, create an abusive working environment.” [78] To establish a case of Pay for paper religious harassment, an Research employee must show that the harassment was: (1) based on his religion; (2) unwelcome; (3) sufficiently severe or pervasive to alter the conditions of employment by creating an intimidating, hostile, or offensive work environment; and, (4) that there is a basis for employer liability. Pay For Literary Use? [79] To support a religious harassment claim, the adverse treatment must be based on religion. [80] This standard can be satisfied regardless of whether the harassment is motivated by the religious belief or observance or lack thereof of Research paper payment either the harasser or the targeted employee.

Moreover, while verbally harassing conduct clearly is based on religion if it has religious content, harassment can also be based on religion even if religion is not explicitly mentioned. [81] Harassing Conduct Based on Religion Religion Mentioned. Mohammed is an Indian-born Muslim employed at a car dealership. Because he takes scheduled prayer breaks during the How to write essay for scholarship hardship letter work day and observes Muslim dietary restrictions, his co-workers are aware of his religious beliefs. Paper? Upset about the Writing essays for ap english 9/11 terrorist attacks, his co-workers and managers began making mocking comments about his religious dietary restrictions and need to Research paper, pray during the Essay writing internet workday. They repeatedly referred to him as “Taliban” or “Arab” and asked him “why don’t you just go back where you came from Research paper payment since you believe what you believe?” When Mohammed questioned why it was mandatory for all employees to attend a United Way meeting, his supervisor said: “This is America.

That’s the Pay for anlaysis paper use way things work over here. This is Research paper, not the Islamic country where you come from.” After this confrontation, the Custom essay writing cheap supervisor issued Mohammed a written warning stating that he “was acting like a Muslim extremist” and that the supervisor could not work with him because of his “militant stance.” This harassment is “based on” religion and national origin. [82] Harassing Conduct Based on Religion Religion Not Mentioned. Shoshanna is a Seventh-day Adventist whose work schedule was adjusted to accommodate her Sabbath observance, which begins at sundown each Friday. When Nicholas , the Research new head of Shoshanna’s department, was informed that he must accommodate her, he told a colleague that “anybody who cannot work regular hours should work elsewhere.” Nicholas then moved the regular Monday morning staff meetings to late Friday afternoon, repeatedly scheduled staff and client meetings on Friday afternoons, and often marked Shoshanna AWOL when she was not scheduled to work.

In addition, Nicholas treated her differently than her colleagues by, for example, denying her training opportunities and Essay internet, loudly berating her with little or no provocation. Although Nicholas did not mention Shoshanna’s religion, the evidence shows that his conduct was because of Shoshanna’s need for religious accommodation, and therefore was “based on” religion. Research Paper Payment? [83] To be unlawful, harassing conduct must be unwelcome. Conduct is “unwelcome” when the employee did not solicit or incite it and regards it as undesirable or offensive. [84] It is necessary to evaluate all of the surrounding circumstances to determine whether or not particular conduct or remarks are unwelcome. [85] For example, where an employee is paper use, upset by repeated mocking use of payment derogatory terms or comments [86] about for ap his religious beliefs or observance by a colleague, it may be evident that the conduct is unwelcome. This would stand in stark contrast to a situation where the same two employees were engaged in Research paper, a consensual conversation that involves a spirited debate of Essay writing internet pdf religious views, and neither employee indicates that he was upset by Research payment it. The distinction between welcome and unwelcome conduct is especially important in english writing, the religious context in situations involving proselytizing of employees who have not invited such conduct. [87] Where a religious employee attempts to persuade a non-religious employee of the correctness of his belief, or vice versa, the conduct may or may not be welcome. When an employee objects to particular religious expression, unwelcomeness is evident. [88] Beth’s colleague, Bill, repeatedly talked to her at work about her prospects for salvation. For several months, she did not object and discussed the matter with him. Research Payment? When he persisted even after she told him that he had “crossed the literary paper use line” and should stop having non-work related conversations with her, the conduct was clearly unwelcome. [89] Even unwelcome religiously motivated conduct is not unlawful unless “the victim . . . subjectively perceive[s] the environment to Research, be abusive” and the conduct is Pay for literary anlaysis paper, “severe or pervasive enough to create an objectively hostile or abusive work environment -- an environment that a reasonable person would find hostile or abusive.” [90] Whether a reasonable person would perceive the Research paper payment conduct as abusive turns on Custom writing reviews cheap common sense and context, looking at the totality of the circumstances. [91] Relevant factors include whether the conduct was abusive, derogatory, or offensive; [92] whether the paper payment conduct was frequent; [93] and whether the conduct was humiliating or physically threatening. [94]

Reasonable Person Perceives Conduct To Be Hostile. Although he hired employees of all religions, the Director of “Get Drug Free Today” required employees to sign a statement that they would support the values of the Church of Scientology. He regularly chastised those whose conduct did not conform to those values. A reasonable person would perceive this to How to short for scholarship hardship, be a religiously hostile work environment. [95] To “alter the conditions of employment,” conduct need not cause economic or psychological harm. [96] It need not impair work performance, discourage employees from Research paper payment remaining on the job, or impede their advancement. [97] The presence of one or more of those factors would buttress the claim, but is not required. [98] However, Title VII is not a general civility code, and does not render all insensitive or offensive comments, petty slights, and annoyances illegal. [99] Offhand or isolated incidents (unless extremely serious) will not rise to the level of illegality. [100] Insensitive Comments Not Enough To Constitute Hostile Environment. Marvin is an Orthodox Jew who was hired as a radio show host. When he started work, a co-worker, Stacy, pointed to his yarmulke and asked, “Will your headset fit over that?” On a few occasions, Stacy, made other remarks about the essay reviews yarmulke, such as: “Nice hat. Is that a beanie?” and paper payment, “Do they come in different colors?” Although the co-worker’s comments about his yarmulke were insensitive, they were not sufficiently severe or pervasive to Pay for anlaysis paper, create a hostile work environment for Research paper, Marvin. [101] Isolated Comments Not Enough to Constitute Hostile Environment.

Bob, a supervisor, occasionally allowed spontaneous and voluntary prayers by employees during office meetings. Help English Writing Message? During one meeting, he referenced Bible passages related to “slothfulness” and “work ethics.” Amy complained that Bob’s comments and paper, the few instances of allowing voluntary prayers during office meetings created a hostile environment. The comments do not create an actionable harassment claim. They were not severe, and because they occurred infrequently, they were not sufficiently pervasive to state a claim. [102] The severity and pervasiveness factors operate inversely. The more severe the harassment, the less frequently the incidents need to recur. At the same time, incidents that may not, individually, be severe may become unlawful if they occur frequently or in close proximity. [103] Although a single incident will seldom create an unlawfully hostile environment, it may do so if it is unusually severe, particularly if it involves physical threat. Essay Writing? [104] One Instance of Physically Threatening Conduct Is Enough to payment, Constitute Hostile Environment. Ihsaan is Essay writing internet, a Muslim.

Shortly after the terrorist attacks on September 11, 2001, Ihsaan came to work and found the words “You terrorists go back where you came from! We will avenge the victims!! Your life is next!” scrawled in red marker on his office door. Because of the timing of the payment statement and the direct physical threat, this incident, alone, is essay hardship, sufficiently severe to constitute hostile environment harassment based on religion and Research payment, national origin. [105] Persistent Offensive Remarks Constitute Hostile Environment. Betty is Help message, a Mormon. Research Paper? During a disagreement regarding a joint project, a co-worker, Julian, tells Betty that she doesn’t know what she is talking about and that she should “go back to Salt Lake City.” When Betty subsequently proposes a different approach to the project, Julian tells her that her suggestions are as “flaky” as he would expect from anlaysis “her kind.” When Betty tries to resolve the conflict, Julian tells her that if she is uncomfortable working with him, she can either ask to paper payment, be transferred, or she can “just pray about it.” Over the next six months, Julian regularly makes similar negative references to Custom essay writing reviews cheap, Betty’s religion. His persistent offensive remarks create a hostile environment. Religious expression that is repeatedly directed at an employee can become severe or pervasive, whether or not the content is intended to payment, be insulting or abusive. Thus, for example, persistently reiterating atheist views to a religious employee who has asked that it stop can create a hostile environment. However, the extent to which the expression is directed at essay for scholarship letter a particular employee is payment, relevant to determining whether or when it could reasonably be perceived to be severe or pervasive by that employee. [106] For example, although it is How to short essay for scholarship letter, conceivable that one employee may allege that he is offended by a colleague’s wearing of religious garb, expressing one’s religion by wearing religious garb is not religious harassment.

It merely expresses an individual’s religious affiliation and does not demean other religious views. As such, it is not objectively hostile. Nor is it directed at any particular individual. Similarly, workplace displays of religious artifacts or posters that do not demean other religious views generally would not constitute religious harassment. No Hostile Environment from Comments That Are Not Abusive and Not Directed at Complaining Employee. While eating lunch in the company cafeteria, Clarence often overhears conversations between his co-workers Dharma and Khema. Dharma, a Buddhist, is paper, discussing meditation techniques with Khema, who is interested in Buddhism. Writing Essays For Ap? Clarence strongly believes that meditation is an occult practice that leads to devil worship and complains to Research payment, their supervisor that Dharma and Khema are creating a hostile environment for him.

Such conversations do not constitute severe or pervasive religious harassment of Clarence because they do not insult other religions and Writing for ap english, they were not directed at him. Overview: An employer is always liable for a supervisor’s harassment if it results in Research, a tangible employment action. However, if it does not, the employer may be able to avoid liability or limit damages by establishing an write essay hardship letter affirmative defense that includes two necessary elements: (a) the employer exercised reasonable care to prevent and correct promptly any harassing behavior, and (b) the employee unreasonably failed to take advantage of any preventive or corrective opportunities provided by the employer or to Research, avoid harm otherwise. In cases of harassment by Help with english writing message a co-worker or a third party over whom the employer had some control, an employer is liable if it knew or should have known about the harassment and failed to take immediate and appropriate corrective action. 1. Harassment by Supervisors or Managers. Employers are automatically liable for supervisory harassment that results in a tangible employment action such as a denial of promotion, demotion, discharge, or constructive discharge. If the harassment does not result in paper, a tangible employment action, the employer can attempt to prove, as an affirmative defense to liability, that: (1) the employer exercised reasonable care to prevent and promptly correct any harassing behavior, and Dissertation service, (2) the employee unreasonably failed to Research payment, take advantage of any preventive or corrective opportunities provided by Dissertation the employer or to otherwise avoid harm. Paper Payment? [107] Supervisory Harassment with Tangible Employment Action. George, a high level official in a state agency, is an atheist who has frequently been heard to say that he thinks anyone who is essay for scholarship hardship letter, deeply religious is a zealot with his own agenda and Research paper, cannot be trusted to act in literary anlaysis paper, the best interests of the Research paper payment public.

George particularly ridicules Debra, a devoutly observant Jehovah’s Witness, and with english writing, consistently withholds the Research payment most desirable assignments from Dissertation service her. He denies her request for a promotion to a more prestigious job in another division, saying that he can’t let her “spread that religious poppycock any further.” Debra files a religious harassment charge. Respondent asserts in paper, its position statement that it is not liable because Debra never made a complaint under its internal anti-harassment policy and complaint procedures. Because the harassment culminated in a tangible employment action (failure to promote), the employer is liable for Help with writing, the harassment even if it has an Research paper payment effective anti-harassment policy, and even if Debra never complained. Additionally, the writing pdf denial of Research paper promotion would be actionable as disparate treatment based on religion. Supervisory Harassment Without Tangible Employment Action. Jennifer’s employer, XYZ, had an anti-harassment policy and complaint procedure that covered religious harassment.

All employees were aware of it, because XYZ widely and Writing essays for ap english, regularly publicized it. Despite his knowledge of the policy, Jennifer’s supervisor frequently mocked her religious beliefs. When Jennifer told him that his comments bothered her, he told her that he was just kidding and she should not take everything so seriously. Paper Payment? Jennifer never reported the How to write short for scholarship problem. When one of Jennifer’s co-workers eventually reported the supervisor’s harassing conduct, the employer promptly investigated, and acted effectively to paper, stop the supervisor’s conduct. Jennifer then filed a religious harassment charge. Because the harassment of Jennifer did not culminate in a tangible employment action, XYZ may assert as an affirmative defense that it is not liable because Jennifer failed to make a complaint under its internal anti-harassment policy and complaint procedures. On these facts, XYZ will not be liable for the harassment because Jennifer unreasonably failed to utilize XYZ’s available, effective complaint mechanisms, and because XYZ took prompt and anlaysis use, reasonable corrective measures once it did learn of the payment harassment. An employer is liable for Custom essay writing, harassment by co-workers where it: knew or should have known about the harassment, and failed to take prompt and appropriate corrective action. [108] Harassment by Co-Workers.

John, who is a Christian Scientist, shares an payment office with Rick, a Mormon. Rick repeatedly tells John that he is practicing a false religion, and that he should study Mormon literature. Despite John’s protestations that he is very happy with his religion and has no desire to convert, Rick regularly leaves religious pamphlets on John’s desk and tries to talk to writing, him about religion. After vainly asking Rick to paper payment, stop the behavior, John complains to their immediate supervisor, who dismisses John’s complaint on the ground that Rick is a nice person who believes that he is just being helpful. If the harassment continues, the employer is liable because it knew, through the supervisor, about Essay writing internet pdf Rick’s harassing conduct but failed to take immediate and Research, appropriate corrective action. How To Short Essay For Scholarship Hardship? [109] An employer is liable for Research payment, harassment by non-employees where it: knew or should have known about the harassment, could control the harasser’s conduct or otherwise protect the employee, and Custom essay writing reviews, failed to take prompt and appropriate corrective action. [110] Harassment by payment a Contractor. Tristan works for XYZ, a contractor that manages Crossroads Corporation’s mail room. When Tristan delivers the mail to Julia, the Crossroads receptionist, he gives her religious tracts, attempts to How to short hardship letter, convert her to his religion, and persists even after she tells him to stop. Research Paper Payment? Julia reports Tristan’s conduct to her supervisor, who tells her that he cannot do anything because Tristan does not work for Crossroads. If the Pay for use harassment continues, the supervisor’s failure to payment, act will subject Crossroads to liability because Tristan’s conduct is pervasive and Pay for, Crossroads refused to take preventive action within its control.

Options available to Julia’s supervisor or the appropriate individual in paper payment, the supervisor’s chain of command might include initiating a meeting with Tristan and XYZ management regarding the harassment and demanding that it cease, that appropriate disciplinary action be taken if it continues, and/or that a different mail carrier be assigned to Julia’s route. C. Special Considerations for Employers When Balancing Anti-Harassment and Accommodation Obligations With Respect to Religious Expression. While some employees believe that religion is intensely personal and private, others are open about their religion. [111] There are employees who may believe that they have a religious obligation to consulting editing, share their views and to try to persuade co-workers of the truth of paper their religious beliefs, i.e. How To Write For Scholarship Letter? , to Research, proselytize. Some employers, too, may wish to express their religious views and consulting service editing, share their religion with their employees. [112] As noted above, however, some employees may perceive proselytizing or other religious expression as unwelcome harassment based on their own religious beliefs and observances, or lack thereof. Payment? This mix of divergent beliefs and essay writing reviews, practices can give rise to conflicts requiring employers to balance the Research payment rights of english employees who wish to express their religious beliefs with the paper rights of How to write hardship other employees to be free from religious harassment under the foregoing Title VII harassment standards. [113] As discussed in Research paper, more detail in § IV-C-6 of this document, an consulting service employer never has to Research payment, accommodate expression of a religious belief in the workplace where such an Help writing message accommodation could potentially constitute harassment of co-workers, because that would pose an undue hardship for Research paper payment, the employer. Therefore, while Title VII requires employers to accommodate an employee’s sincerely held religious belief in engaging in religious expression ( e.g. , proselytizing) in the workplace, an Pay for literary use employer does not have to allow such expression if it imposes an undue hardship on the operation of the business. For example, it would be an undue hardship for paper payment, an employer to accommodate proselytizing by an employee if it constituted potentially unlawful religious harassment of a co-worker who found it unwelcome, or if it otherwise interfered with the Dissertation consulting service operation of the business. [114] Because employers are responsible for maintaining a nondiscriminatory work environment, they are liable for perpetrating or tolerating religious harassment of their employees. An employer can reduce the chance that employees will engage in conduct that rises to paper payment, the level of essays for ap english unlawful harassment by implementing an anti-harassment policy and an effective procedure for reporting, investigating, and correcting harassing conduct. [115] Even if the paper payment policy does not prevent all such conduct, it will likely limit the internet employer’s liability where the affected employee allows the conduct to rise to the level of illegality by failing to report it. However, Title VII violations may result if an employer tries to avoid potential co-worker objections to employee religious expression by Research payment preemptively banning all religious communications in the workplace, since Title VII requires that employees’ sincerely held religious practices and beliefs be accommodated as long as no undue hardship is posed.

Employers should have a well-publicized and Writing for ap english, consistently applied anti-harassment policy that: (1) covers religious harassment; (2) clearly explains what is prohibited; (3) describes procedures for bringing harassment to Research payment, management’s attention; and, (4) contains an How to write essay letter assurance that complainants will be protected against retaliation. The procedures should include a complaint mechanism that includes multiple avenues for Research payment, complaint; prompt, thorough, and impartial investigations; and essays english, prompt and appropriate corrective action. Employers should allow religious expression among employees to the same extent that they allow other types of Research paper payment personal expression that are not harassing or disruptive. How To Write Essay Letter? Once an employer is on notice that an employee objects to Research payment, religious conduct that is directed at him or her, the employer should take steps to end the conduct because even conduct that the employer does not regard as abusive can become sufficiently severe or pervasive to affect the conditions of employment if allowed to persist in Custom essay reviews cheap, the face of the employee’s objection. If harassment is perpetrated by a non-employee assigned by a contractor, the supervisor or other appropriate individual in the chain of command should initiate a meeting with the contractor regarding the harassment and demand that it cease, that appropriate disciplinary action be taken if it continues, and/or that a different individual be assigned by the contractor.

To prevent conflicts from escalating to the level of a Title VII violation, employers should immediately intervene when they become aware of objectively abusive or insulting conduct, even absent a complaint. Employers should encourage managers to Research paper, intervene proactively and discuss with subordinates whether particular religious expression is welcome if the Help with english writing message manager believes the expression might be construed as harassing to a reasonable person. While supervisors are permitted to engage in paper payment, certain religious expression, they should avoid expression that might due to their supervisory authority reasonably be perceived by subordinates as coercive, even when not so intended. Employees who are the recipients of essay writing reviews cheap unwelcome religious conduct should inform the individual engaging in the conduct that they wish it to stop. If the conduct does not stop, employees should report it to their supervisor or other appropriate company official in accordance with the procedures established in the company’s anti-harassment policy. Employees who do not wish to paper payment, personally confront an individual who is directing unwelcome religious or anti-religious conduct towards them should report the conduct to Dissertation consulting, their supervisor or other appropriate company official in accordance with the company’s anti-harassment policy. Overview: Title VII requires an employer, once on Research payment notice, to reasonably accommodate an employee whose sincerely held religious belief, practice, or observance conflicts with a work requirement, unless providing the accommodation would create an undue hardship. [116] However, the Title VII “undue hardship” defense is defined very differently than the “undue hardship” defense for disability accommodation under the Americans with Disabilities Act (ADA). Under Title VII, the undue hardship defense to Help english writing, providing religious accommodation requires a showing that the Research proposed accommodation in a particular case poses a “more than de minimis” cost or burden, which is How to short for scholarship hardship, a far lower standard for an employer to meet than undue hardship under the ADA, which is payment, defined in that statute as “significant difficulty or expense.” [117] A religious accommodation claim is distinct from a disparate treatment claim, in Essay writing pdf, which the payment question is whether employees are treated equally. An individual alleging denial of religious accommodation is seeking an Writing for ap english adjustment to Research paper payment, a neutral work rule that infringes on the employee’s ability to practice his religion. The accommodation requirement is “plainly intended to relieve individuals of the Help with burden of Research paper choosing between their jobs and their religious convictions, where such relief will not unduly burden others.” [118]

A reasonable religious accommodation is short letter, any adjustment to paper payment, the work environment that will allow the employee to comply with his or her religious beliefs. Writing Essays For Ap? However, it is subject to the limit of more than de minimis cost or burden. The need for religious accommodation most frequently arises where an individual’s religious beliefs, observances, or practices conflict with a specific task or requirement of the job or the application process. The employer’s duty to accommodate will usually entail making a special exception from, or adjustment to, the particular requirement so that the employee or applicant will be able to practice his or her religion. Accommodation requests often relate to paper payment, work schedules, dress and grooming, or religious expression or practice while at Custom essay cheap work. 1. Notice of the Conflict Between Religion and Work.

An applicant or employee who seeks religious accommodation must make the employer aware both of the need for accommodation and that it is Research, being requested due to a conflict between religion and work. The employee is obligated to explain the religious nature of the belief or practice at issue, and anlaysis paper, cannot assume that the employer will already know or understand it. [119] Similarly, the employer should not assume that a request is invalid simply because it is Research paper, based on religious beliefs or practices with which the employer is unfamiliar, but should ask the employee to explain the religious nature of the practice and service, the way in which it conflicts with a work requirement. No “magic words” are required to place an employer on notice of an payment applicant’s or employee’s conflict between religious needs and a work requirement. Help With English Writing Message? To request an accommodation, an individual may use plain language and need not mention any particular terms such as “Title VII” or “religious accommodation.” However, the applicant or employee must provide enough information to make the employer aware that there exists a conflict between the individual’s religious practice or belief and a requirement for applying for or performing the job. [120] Failure to Advise Employer That Request Is Due to Research paper, Religious Practice or Belief. Jim agreed to take his employer’s drug test but was terminated because he refused to sign the accompanying consent form.

After his termination, Jim filed a charge alleging that the employer failed to accommodate his religious objection to swearing an Pay for use oath. Until it received notice of the charge, the employer did not know that Jim’s refusal to sign the payment form was based on his religious beliefs. Because the employer was not notified of the conflict at Help with writing message the time Jim refused to sign the form, or at any time prior to Jim’s termination, it did not have an Research paper opportunity to writing, offer to accommodate him. The employer has not violated Title VII. [121] While an payment employer is writing, not required by Title VII to conduct a discussion with an employee before denying the Research employee’s accommodation request, as a practical matter it can be important to do so. Both the Essay writing employer and the employee have roles to play in resolving an Research accommodation request. In addition to consulting editing, placing the employer on notice of the need for accommodation, the employee should cooperate with the employer’s efforts to Research payment, determine whether a reasonable accommodation can be granted.

Once the employer becomes aware of the employee’s religious conflict, the employer should obtain promptly whatever additional information is Essay writing internet pdf, needed to determine whether an Research paper accommodation is available that would eliminate the religious conflict without posing an undue hardship on the operation of the employer’s business. [122] This typically involves the employer and employee mutually sharing information necessary to process the accommodation request. Employer?employee cooperation and flexibility are key to the search for a reasonable accommodation. If the accommodation solution is essay writing reviews, not immediately apparent, the employer should discuss the request with the Research paper payment employee to determine what accommodations might be effective. If the employer requests additional information reasonably needed to evaluate the with english message request, the employee should provide it. Failure to confer with the employee is not an independent violation of Title VII but, as a practical matter, such failure can have adverse legal consequences for paper, both an employee and an employer. For example, in some cases where an employer has made no effort to act on an accommodation request, courts have found that the employer lacked the evidence needed to meet its burden of Help english writing proof to establish that the plaintiff’s proposed accommodation would actually have posed an undue hardship. [123] Likewise, courts have ruled against employees who refused to cooperate with an employer’s requests for reasonable information when, as a result, the paper payment employer was deprived of the essay writing reviews cheap information necessary to resolve the accommodation request. Research? For example, if an employee requested a schedule change to with, accommodate daily prayers, the employer might need to ask for information about the Research paper religious observance, such as time and Dissertation editing, duration of the daily prayers, in order to determine if accommodation can be granted without posing an undue hardship on the operation of the employer’s business. [124] Moreover, even if the employer does not grant the employee’s preferred accommodation but instead provides an alternative accommodation, the employee must cooperate by attempting to meet his religious needs through the paper employer’s proposed accommodation if possible. [125] Where the accommodation request itself does not provide enough information to enable the employer to make a determination, and Writing for ap english, the employer has a bona fide doubt as to the basis for the accommodation request, it is entitled to make a limited inquiry into the facts and circumstances of the employee’s claim that the belief or practice at issue is paper, religious and sincerely held, and that the belief or practice gives rise to the need for the accommodation. See “Sincerely Held” and “Employer Inquiries into Religious Nature or Sincerity of consulting editing Belief,” supra §§ I-A-2 and I-A-3. Paper Payment? [126] Whether an employer has a reasonable basis for seeking to verify the employee’s stated beliefs will depend on Pay for anlaysis paper use the facts of a particular case.

Sincerity of Religious Belief Questioned. Bob, who had been a dues-paying member of the paper CDF union for fourteen years, had a work-related dispute with a union official and one week later asserted that union activities were contrary to his religion and that he could no longer pay union dues. The union doubted whether Bob’s request was based on for ap english a sincerely held religious belief, given that it appeared to be precipitated by an unrelated dispute with the union, and he had not sought this accommodation in Research paper, his prior fourteen years of employment. In this situation, the union can require him to provide additional information to support his assertion that he sincerely holds a religious conviction that precludes him from editing belonging to or financially supporting a union. Research Paper Payment? [127] When an employer requests additional information, employees should provide information that addresses the Essay pdf employer’s reasonable doubts. That information need not, however, take any specific form. For example, written materials or the employee’s own first-hand explanation may be sufficient to alleviate the employer’s doubts about the sincerity or religious nature of the employee’s professed belief such that third-party verification is unnecessary. Research Payment? Further, since idiosyncratic beliefs can be sincerely held and writing pdf, religious, even when third-party verification is needed, it does not have to come from a church official or member, but rather could be provided by others who are aware of the employee’s religious practice or belief. [128] An employee who fails to Research, cooperate with an employer’s reasonable request for verification of the sincerity or religious nature of a professed belief risks losing any subsequent claim that the employer improperly denied an accommodation. Editing? By the same token, employers who unreasonably request unnecessary or excessive corroborating evidence risk being held liable for denying a reasonable accommodation request, and having their actions challenged as retaliatory or as part of payment a pattern of harassment.

It also is important to remember that even if an employer concludes that an individual’s professed belief is sincerely held and religious, it is only required to consulting service editing, grant those requests for accommodation that do not pose an undue hardship on the conduct of its business. Clarifying a Request. Diane requests that her employer schedule her for “fewer hours” so that she can “attend church more frequently.” The employer denies the request because it is not clear what schedule Diane is requesting or whether the change is Research payment, sought due to a religious belief or practice. While Diane’s request lacked sufficient detail for consulting service, the employer to make a final decision, it was sufficient to constitute a religious accommodation request. Research? Rather than denying the request outright, the employer should have obtained the information from Diane that it needed to make a decision. The employer could have inquired of Diane precisely what schedule change was sought and for what purpose, and how her current schedule conflicted with her religious practices or beliefs. Diane would then have had an obligation to essay writing reviews cheap, provide sufficient information to permit her employer to make a reasonable assessment of whether her request was based on paper payment a sincerely held religious belief, the precise conflict that existed between her work schedule and church schedule, and whether granting the accommodation would pose more than a de minimis burden on the employer’s business. 3. What is a “Reasonable” Accommodation?

Although an employer never has to provide an essays for ap english accommodation that would pose an undue hardship, see infra § IV-B, the accommodation that is provided must be a reasonable one. An accommodation is not “reasonable” if it merely lessens rather than eliminates the conflict between religion and work, provided eliminating the conflict would not impose an Research paper payment undue hardship. Essays For Ap? [129] Eliminating the conflict between a work rule and an employee’s religious belief, practice, or observance means accommodating the Research employee without unnecessarily disadvantaging the employee’s terms, conditions, or privileges of employment. [130] Where there is more than one reasonable accommodation that would not pose an undue hardship, the employer is not obliged to provide the accommodation preferred by the employee. [131] However, an employer’s proposed accommodation will not be “reasonable” if a more favorable accommodation is write short essay, provided to other employees for non-religious purposes, [132] or, for payment, example, if it requires the employee to accept a reduction in Help english writing, pay rate or some other loss of a benefit or privilege of employment and Research payment, there is an alternative accommodation that does not do so. [133] Ultimately, reasonableness is a fact-specific determination. “The reasonableness of an employer’s attempt at accommodation cannot be determined in a vacuum. Instead, it must be determined on Pay for literary paper a case?by?case basis; what may be a reasonable accommodation for one employee may not be reasonable for another . . Research? . . Help With English Writing? ‘The term ‘reasonable accommodation’ is a relative term and cannot be given a hard and fast meaning; each case . Research Paper Payment? . Consulting? . necessarily depends upon its own facts and circumstances, and comes down to Research, a determination of ‘reasonableness’ under the unique circumstances of the individual employer-employee relationship.’” [134] Employer Violates Title VII if it Offers Only Partial Accommodation Where Full Accommodation Would Not Pose an Undue Hardship. Rachel, who worked as a ticket agent at consulting service editing a sports arena, asked not to payment, be scheduled for any Friday night or Saturday shifts, to letter, permit her to observe the Jewish Sabbath from sunset on Friday through sunset on Saturday. The arena wanted to give Rachel only every other Saturday off.

The arena’s proposed accommodation is not reasonable because it does not fully eliminate the religious conflict. The arena may deny the accommodation request only if giving Rachel every Saturday off poses an Research payment undue hardship for the arena. [135] Employer Not Obligated To Provide Employee’s Preferred Accommodation. Tina, a newly hired part-time store cashier whose sincerely held religious belief is that she should refrain from essay work on Sunday as part of her Sabbath observance, asked her supervisor never to schedule her to work on Sundays. Tina specifically asked to paper payment, be scheduled to work Saturdays instead. In response, her employer offered to allow her to work on Thursday, which she found inconvenient because she takes a college class on that day. Even if Tina preferred a different schedule, the employer is essay writing reviews cheap, not required to grant Tina’s preferred accommodation. Research Payment? [136] Accommodation By Transfer Where Accommodation in Current Position Would Pose Undue Hardship. Yvonne, a member of the Pentecostal faith, was employed as a nurse at a hospital.

When she was assigned to the Labor and Delivery Unit, she advised the nurse manager that her faith forbids her from participating “directly or indirectly in ending a life,” and that this proscription prevents her from assisting with abortions. She asked the reviews hospital to accommodate her religious beliefs by allowing her to trade assignments with other nurses in paper payment, the Labor and Delivery Unit as needed. The hospital concluded that it could not accommodate Yvonne within the Labor and Writing english, Delivery Unit because there were not enough staff members able and paper payment, willing to trade with her. The hospital instead offered to permit Yvonne to transfer, without a reduction in pay or benefits, to consulting service editing, a vacant nursing position in the Newborn Intensive Care Unit, which did not perform any such procedures. Payment? The hospital’s solution complies with Title VII. The hospital is not required to grant Yvonne’s preferred accommodation where it has offered a reasonable alternative solution that eliminates the conflict between work and a religious practice or belief under its existing policies and procedures. [137] If there had been no other position to which she could transfer, the employer would have been entitled to terminate her since it would pose an for ap undue hardship to accommodate her in the Labor and paper, Delivery Unit. Title VII is violated by an employer’s failure to accommodate even if to avoid adverse consequences an letter employee continues to paper, work after his accommodation request is denied. “An employee does not cease to be discriminated against because he temporarily gives up his religious practice and submits to the employment policy.” [138] Thus, the fact that an Pay for literary anlaysis paper employee acquiesces to the employer’s work rule, continuing to paper, work without an writing pdf accommodation after the employer has denied the request, should not defeat the employee’s legal claim. [139] In addition, the obligation to paper payment, provide reasonable accommodation absent undue hardship is a continuing obligation. Writing Essays? Employers should be aware that an employee’s religious beliefs and practices may evolve over time, and that this may result in requests for additional or different accommodations. [140] Similarly, the employer has the right to discontinue a previously granted accommodation that is no longer utilized for religious purposes or poses an undue hardship. An employer can refuse to paper, provide a reasonable accommodation if it would pose an undue hardship. Undue hardship may be shown if the accommodation would impose “more than de minimis cost” on the operation of the employer’s business. [141] The concept of “more than de minimis cost” is Pay for paper use, discussed below in sub-section 2. Although the payment employer’s showing of undue hardship under Title VII is easier than under the ADA, the burden of Essay persuasion is still on the employer. [142] If an Research paper employee’s proposed accommodation would pose an Writing essays undue hardship, the Research paper payment employer should explore alternative accommodations.

The determination of whether a particular proposed accommodation imposes an undue hardship “must be made by considering the particular factual context of each case.” [143] Relevant factors may include the Custom essay type of workplace, the nature of the Research payment employee’s duties, the identifiable cost of the accommodation in Pay for, relation to the size and operating costs of the payment employer, and Essay writing internet, the number of employees who will in fact need a particular accommodation. Research Payment? [144] For example, an employer with multiple facilities might be better able than another employer to accommodate a Muslim employee who seeks a transfer to a location with a nearby mosque that he can attend during his lunch break. To prove undue hardship, the Essay writing employer will need to paper, demonstrate how much cost or disruption the employee’s proposed accommodation would involve. [145] An employer cannot rely on potential or hypothetical hardship when faced with a religious obligation that conflicts with scheduled work, but rather should rely on objective information. [146] A mere assumption that many more people with the same religious practices as the Pay for anlaysis individual being accommodated may also seek accommodation is not evidence of undue hardship. Research Paper Payment? The determination of english whether a proposed accommodation would pose an undue hardship is based on concrete, fact-specific considerations. [147] To establish undue hardship, the employer must demonstrate that the accommodation would require more than de minimis cost. [148] Factors to be considered are “the identifiable cost in relation to the size and operating costs of the employer, and Research paper payment, the number of individuals who will in fact need a particular accommodation.” [149] Generally, the write short essay for scholarship letter payment of paper administrative costs necessary for an accommodation, such as costs associated with rearranging schedules and recording substitutions for payroll purposes or infrequent or temporary payment of premium wages ( e.g. , overtime rates) while a more permanent accommodation is sought, will not constitute more than de minimis cost, whereas the regular payment of premium wages or the hiring of additional employees to provide an accommodation will generally cause an undue hardship to the employer. [150] “[T]he Commission will presume that the infrequent payment of premium wages for a substitute or the payment of premium wages while a more permanent accommodation is being sought are costs which an employer can be required to bear as a means of providing reasonable accommodation.” [151] Costs to be considered include not only direct monetary costs but also the burden on the conduct of the How to write essay for scholarship hardship employer’s business. Payment? For example, courts have found undue hardship where the accommodation diminishes efficiency in other jobs, [152] infringes on other employees’ job rights or benefits, [153] impairs workplace safety, or causes co-workers to carry the accommodated employee’s share of writing cheap potentially hazardous or burdensome work. [154] Whether the proposed accommodation conflicts with another law will also be considered. [155] Religious Need Can Be Accommodated. David wears long hair pursuant to payment, his Native American religious beliefs.

David applies for a job as a server at a restaurant which requires its male employees to wear their hair “short and neat.” When the restaurant manager informs David that if offered the position he will have to cut his hair, David explains that he keeps his hair long based on his religious beliefs, and Dissertation consulting service, offers to wear it in a pony tail or held up with a clip. The manager refuses this accommodation, and Research, denies David the position based on his long hair. Since the evidence indicated that David could have been accommodated, without undue hardship, by wearing his hair in a ponytail or held up with a clip, the employer will be liable for denial of reasonable accommodation and discriminatory failure to hire. Safety Risk Poses Undue Hardship. Patricia alleges she was terminated from essay her job as a steel mill laborer because of her religion (Pentecostal) after she notified her supervisor that her faith prohibits her from wearing pants, as required by the mill’s dress code, and requested as an accommodation to be permitted to wear a skirt. Management contends that the dress code is essential to the safe and efficient operation of the paper mill, and has evidence that it was imposed following several accidents in which skirts worn by employees were caught in the same type of mill machinery that Patricia operates. Because the evidence establishes that wearing pants is truly necessary for safety reasons, the accommodation requested by Patricia poses an essay writing cheap undue hardship. Research Paper Payment? [156]

3. Seniority Systems and Collectively Bargained Rights. A proposed religious accommodation poses an undue hardship if it would deprive another employee of How to write for scholarship hardship a job preference or other benefit guaranteed by a bona fide seniority system or collective bargaining agreement (CBA). [157] Of course, the mere existence of Research payment a seniority system or CBA does not relieve the employer of the duty to attempt reasonable accommodation of its employees’ religious practices; the question is whether an accommodation can be provided without violating the seniority system or CBA. [158] Allowing voluntary substitutes and Pay for literary paper use, swaps does not constitute an undue hardship to the extent the arrangements do not violate a bona fide seniority system or CBA. [159] Schedules Based on a Seniority System or Collectively Bargained Rights. Susan, an employee of payment QRS Corp., asks not to work on literary anlaysis use her Sabbath. QRS and its employees’ union have negotiated a CBA which provides that weekend shifts will rotate evenly among employees. If Susan can find qualified co-workers voluntarily willing to swap shifts to accommodate her sincerely held religious beliefs, the employer could be found liable for denial of paper reasonable accommodation if it refuses to permit the swap to occur. Custom Essay Cheap? The existence of the collectively bargained system for determining weekend shifts should not result in paper, the denial of accommodation if a voluntary swap can be arranged by the employee without violating the system or otherwise posing an Help message undue hardship.

The result would be the same if QRS had a unilaterally imposed seniority system (rather than a CBA) pursuant to which weekend shifts are determined. However, if other employees were unwilling to swap shifts or were otherwise harmed by not requiring Susan to work on the shift in question, or the employer would be subject to other operational costs that were more than de minimis by allowing Susan to swap shifts, then the employer can demonstrate undue hardship. [160] Although infringing on co-workers’ ability to paper, perform their duties [161] or subjecting co-workers to a hostile work environment will generally constitute undue hardship, [162] the general disgruntlement, resentment, or jealousy of co-workers will not. Literary Paper? [163] Undue hardship requires more than proof that some co-workers complained; a showing of undue hardship based on co-worker interests generally requires evidence that the accommodation would actually infringe on Research paper payment the rights of co-workers or cause disruption of work. [164] See also §§ III-C and IV-C-6 (discussing specifically complaints regarding proselytizing and other forms of religious expression), infra . If a religious practice actually conflicts with a legally mandated federal, state, or local security requirement, an employer need not accommodate the practice because doing so would create an undue hardship. If a security requirement has been unilaterally imposed by for ap english the employer and is not required by law or regulation, the employer will need to decide whether it would be an undue hardship to modify or eliminate the requirement to accommodate an employee who has a religious conflict. Accommodation Implicating Security Concerns. Patrick is employed as a correctional officer at paper a state prison, and his brother William is employed as a grocery store manager. Both Patrick and William seek permission from Dissertation consulting service their respective employers to wear a fez at work as an act of faith on a particular holy day as part of their religious expression. Both employers deny the request, citing a uniformly applied workplace policy prohibiting employees from wearing any type of paper head covering. The prison’s policy is based on Custom writing cheap security concerns that head coverings may be used to conceal drugs, weapons, or other contraband, and may spark internal violence among prisoners.

The grocery store’s policy is based on a stated desire that all employees wear uniform clothing so that they can be readily identified by customers. Payment? If both brothers file EEOC charges challenging the denial of their accommodation requests, Patrick will likely not prevail because the prison’s denial of his request was based on legitimate security considerations posed by the particular religious garb sought to essays for ap english, be worn. William will likely prevail because there is no indication it would pose an undue hardship for Research payment, the grocery store to modify its policy with respect to his request. [165] Harvinder, a baptized Sikh who works in a hospital, wears a small (4-inch), dull and sheathed kirpan (miniature sword) strapped and hidden underneath her clothing, as a symbol of her religious commitment to defend truth and moral values. When Harvinder’s supervisor, Bill, learned about her kirpan from a co-worker, he instructed Harvinder not to wear it at work because it violated the consulting editing hospital policy against weapons in payment, the workplace. Harvinder explained to Bill that her faith requires her to wear a kirpan in order to comply with the Dissertation service editing Sikh Code of Conduct, and Research, gave him literature explaining that the essay reviews cheap kirpan is a religious artifact, not a weapon. Paper? She also showed him the kirpan, allowing him to consulting editing, see that it was no sharper than butter knives found in the hospital cafeteria. Research Paper? Nevertheless, Bill told her that she would be terminated if she continued to wear the kirpan at work. Absent any evidence that allowing Harvinder to wear the kirpan would pose an undue hardship in the factual circumstances of this case, the with english writing hospital is Research, liable for denial of accommodation. [166] C. Internet? Common Methods of Accommodation in the Workplace. Under Title VII, an Research payment employer or other covered entity may use a variety of Writing english methods to Research paper, provide reasonable accommodations to its employees.

The most common methods are: (1) flexible scheduling; (2) voluntary substitutes or swaps of write essay for scholarship letter shifts and assignments; (3) lateral transfer and/or change of job assignment; and, (4) modifying workplace practices, policies, and/or procedures. An employer may be able to Research payment, reasonably accommodate an reviews employee by allowing flexible arrival and departure times, floating or optional holidays, flexible work breaks, use of paper lunch time in exchange for early departure, staggered work hours, and other means to enable an employee to make up time lost due to the observance of religious practices. Essay Writing Internet Pdf? [167] However, EEOC’s position is that it will be insufficient merely to eliminate part of the conflict, unless eliminating the conflict in its entirety will pose an paper payment undue hardship by disrupting business operations or impinging on other employees’ benefits or settled expectations. Break Schedules/Prayer at Work. Rashid, a janitor, tells his employer on his first day of work that he practices Islam and will need to pray at anlaysis paper several prescribed times during the Research workday in order to Help with writing message, adhere to his religious practice of praying at five specified times each day, for Research payment, several minutes, with hand washing beforehand. The employer objects because its written policy allows one fifteen-minute break in the middle of each morning and afternoon.

Rashid’s requested change in break schedule will not exceed the writing internet pdf 30 minutes of total break time otherwise allotted, nor will it affect his ability to Research paper payment, perform his duties or otherwise cause an undue hardship for Custom, his employer. Thus, Rashid is entitled to accommodation. [168] Blanket Policies Prohibiting Time Off for Religious Observance. A large employer operating a fleet of buses had a policy of Research payment refusing to accept driver applications unless the applicant agreed that he or she was available to be scheduled to work any shift, seven days a week. This policy violates Title VII to the extent that it discriminates against applicants who refrain from work on certain days for religious reasons, by failing to allow for the provision of religious accommodation absent undue hardship. [169] 2. Voluntary Substitutes and Shift Swaps. Although it would pose an undue hardship to require employees involuntarily to substitute for one another or swap shifts, the reasonable accommodation requirement can often be satisfied without undue hardship where a volunteer with substantially similar qualifications is available, either for a single absence or an extended period of Dissertation consulting service time. The employer’s obligation is to make a good faith effort to allow voluntary substitutions and payment, shift swaps, under circumstances which do not discourage employees from substituting for one another or trading shifts to accommodate a religious conflict. [170] However, if the employer is on notice that the employee’s religious beliefs preclude him not only from working on his Sabbath but also from inducing others to do so, reasonable accommodation requires more than merely permitting the employee to swap. Dissertation Consulting Service? [171] Nevertheless, an employer does not have to Research payment, permit a substitute or swap if it would pose more than de minimis cost or burden to essay, business operations. As noted above, if a swap or substitution would result in paper, the employer having to pay premium wages (such as overtime pay), the frequency of the arrangement will be relevant to determining if it poses an undue hardship; “the Commission will presume that the infrequent payment of premium wages for Writing essays english, a substitute or the payment of premium wages while a more permanent accommodation is being sought are costs which an employer can be required to Research paper, bear as a means of providing reasonable accommodation.” [172] An employer may have to make an exception to pdf, its scheduling policies, procedures, or practices in order to grant religious accommodation. [173] For example, if it does not pose an undue hardship, an employer must make an payment exception to Essay pdf, its policy of Research requiring all employees, regardless of seniority, to work an “equal number of weekend, holiday, and night shifts,” and literary, instead permit voluntary shift swaps between qualified co-workers in order to accommodate a particular employee’s sincerely held religious belief that he should not work on Research payment the Sabbath. Essay? Of course, if allowing a swap or other accommodation would not provide the coverage the employer needs for its business operations or otherwise pose an undue hardship, the accommodation does not have to be granted.

3. Change of Research paper Job Tasks and Lateral Transfer. When an employee’s religious belief or practice conflicts with a particular task, appropriate accommodations may include relieving the employee of the task or transferring the Essay writing pdf employee to Research, a different position or location that eliminates the Custom essay writing reviews cheap conflict with the employee’s religion. Whether or not such accommodations pose an undue hardship will depend on factors such as the nature or importance of the duty at issue, the availability of others to perform the function, the availability of other positions, and the applicability of a CBA or seniority system. Restaurant Server Excused from Singing Happy Birthday. Kim, a server at paper payment a restaurant, informed her manager that she would not be able to join other waitresses in singing “Happy Birthday” to customers because she is a Jehovah’s Witness whose religious beliefs do not allow her to celebrate holidays, including birthdays. With English Message? There were enough servers on duty at any given time to perform this singing without affecting service.

The manager refused any accommodation. Paper? If Kim files a Title VII charge alleging denial of religious accommodation, she will prevail because the restaurant could have accommodated her with little or no expense or disruption. [174] Pharmacist Excused from Providing Contraceptives. Neil, a pharmacist, was hired by a large corporation that operates numerous large pharmacies at which more than one pharmacist is on Essay writing internet pdf duty during all hours of Research paper operation. Neil informed his employer that he refused on religious grounds to participate in distributing contraceptives or answering any customer inquiries about contraceptives. The employer reasonably accommodated Neil by offering to allow Neil to signal to a co-worker who would take over servicing any customer who telephoned, faxed, or came to the pharmacy regarding contraceptives. [175] Pharmacist Not Permitted to Writing for ap, Turn Away Customers.

In the above example, assume that instead of Research paper facilitating the assistance of such customers by a co-worker, Neil leaves on writing internet hold indefinitely those who call on payment the phone about literary use a contraceptive rather than transferring their calls, and walks away from in-store customers who seek to fill a contraceptive prescription rather than signaling a co-worker. The employer is payment, not required to accommodate Neil’s request to remain in such a position yet avoid all situations where he might even briefly interact with customers who have requested contraceptives, or to accommodate a disruption of business operations. The employer may discipline or terminate Neil for How to write essay for scholarship hardship, not meeting legitimate expectations. [176] The employee should be accommodated in his or her current position if doing so does not pose an undue hardship. [177] If no such accommodation is possible, the employer needs to consider whether lateral transfer is a possible accommodation. [178] For example, if a pharmacist who has a religious objection to dispensing contraceptives can be accommodated without undue hardship by allowing the pharmacist to Research, signal a co-worker to assist customers with such prescriptions, the employer cannot choose instead to accommodate by transferring the Custom essay reviews cheap pharmacist to a different position. Research Paper Payment? Moreover, if the Dissertation service pharmacist cannot be accommodated within his position, the employer cannot transfer the pharmacist to paper payment, a position that entails less pay, responsibility, or opportunity for advancement unless a lateral transfer is english, unavailable or would otherwise pose an undue hardship.[179] Lateral Transfer Versus Transfer to a Lower-Paying Position. An electrical utility lineman requests accommodation of Research his Sabbath observance, but because the nature of his position requires being available to handle emergency problems at any time, there is Help with writing message, no accommodation that would permit the Research paper payment lineman to remain in his position without posing an undue hardship. The employer can accommodate the editing lineman by Research payment offering a lateral transfer to another assignment at the same pay, if available. If, however, no job at the same pay is readily available, then the employer could satisfy its obligation to How to write short essay for scholarship letter, reasonably accommodate the lineman by offering to transfer him to Research payment, a different job, even at lower pay, if one is available. Writing Internet Pdf? [180]

4. Research Paper? Modifying Workplace Practices, Policies and Help with english message, Procedures. When an employer has a dress or grooming policy that conflicts with an employee’s religious beliefs or practices, the Research paper payment employee may ask for an exception to the policy as a reasonable accommodation. [181] Religious grooming practices may relate, for example, to shaving or hair length. Religious dress may include clothes, head or face coverings, jewelry, or other items. Absent undue hardship, religious discrimination may be found where an employer fails to accommodate the employee’s religious dress or grooming practices. [182] Prakash, who works for Help with writing message, CutX, a surgical instrument manufacturer, does not shave or trim his facial hair because of his Sikh religious observance. When he seeks a promotion to manage the Research division responsible for sterilizing the writing message instruments, his employer tells him that, to work in that division, he must shave or trim his beard because otherwise his beard may contaminate the sterile field. When Prakash explains that he cannot trim his beard for paper payment, religious reasons, the employer offers to allow Prakash to wear two face masks instead of trimming his beard. Prakash thinks that wearing two masks is unreasonable and files a Title VII charge. Custom Essay Writing Cheap? CutX will prevail because it offered a reasonable accommodation that would eliminate Prakash’s religious conflict with the Research paper payment hygiene rule. Some courts have concluded that it would pose an undue hardship if an Pay for anlaysis use employer was required to accommodate a religious dress or grooming practice that conflicts with the Research public image the employer wishes to convey to Essay writing internet, customers. [183] While there may be circumstances in which allowing a particular exception to an employer’s dress and grooming policy would pose an undue hardship, an employer’s reliance on paper the broad rubric of “image” to deny a requested religious accommodation may in editing, a given case be tantamount to Research payment, reliance on pdf customer religious bias (so-called “customer preference”) in paper, violation of Title VII. [184]

Nasreen, a Muslim ticket agent for a commercial airline, wears a head scarf, or hijab, to work at the airport ticket counter. After September 11, 2001, her manager objected, telling Nasreen that the customers might think she was sympathetic to terrorist hijackers. Nasreen explains to essays for ap, her manager that wearing the hijab is her religious practice and continues to wear it. She is terminated for paper, wearing it over her manager’s objection. Customer fears or prejudices do not amount to undue hardship, and the refusal to How to for scholarship, accommodate her and the termination, therefore, violate Title VII.

In addition, denying Nasreen the position due to perceptions of customer preferences about religious attire would be disparate treatment based on religion in violation of Title VII, because it would be the same as refusing to hire Nasreen because she is a Muslim. Research Paper Payment? See supra § II-B. [185] There may be limited situations in which the need for uniformity of appearance is so important that modifying the dress code would pose an editing undue hardship. [186] However, even in Research, these situations, a case-by-case determination is advisable. [187] If any employee needs to use a workplace facility as a reasonable accommodation, for example use of a quiet area for prayer during break time, the employer should accommodate the request under Title VII unless it would pose an undue hardship. If the employer allows employees to use the facilities at issue for non-religious activities not related to work, it may be difficult for the employer to demonstrate that allowing the facilities to be used in the same manner for religious activities is not a reasonable accommodation or poses an undue hardship. [188]

Use of Employer Facilities. An employee whose assigned work area is a factory floor rather than an enclosed office asks his supervisor if he may use one of the company’s unoccupied conference rooms to pray during a scheduled break time. The supervisor must grant this request if it would not pose an undue hardship. An undue hardship would exist, for example, if the internet only conference room is used for work meetings at that time. Paper Payment? However, the Help with english message supervisor is not required to provide the employee with his choice of the available locations, and Research paper, can meet the accommodation obligation by making any appropriate location available that would accommodate the employee’s religious needs if this can be done absent undue hardship, for example by offering an Help with message unoccupied area of the work space rather than the conference room. c. Tests and Other Selection Procedures. An employer has an obligation to Research paper payment, accommodate an employee or prospective employee when scheduling a test or administering other selection procedures, where the applicant has informed the Pay for anlaysis employer of a sincerely held religious belief that conflicts with a pre-employment testing requirement, unless undue hardship would result. [189] An employer may not permit an Research paper payment applicant’s need for a religious accommodation to affect its decision whether or not to hire the applicant unless the How to write short letter employer can demonstrate that it cannot reasonably accommodate the applicant’s religious practice without undue hardship. Payment? [190] d. Writing Essays For Ap English? Providing Social Security Numbers. It will typically pose an undue hardship for an employer to Research paper payment, accommodate an for ap english applicant or employee’s asserted religious belief against providing or using a social security number. [191] 5. Research Payment? Excusing Union Dues or Agency Fees. Absent undue hardship, Title VII requires employers and unions to accommodate an with message employee who holds religious objections to joining or financially supporting a union. [192] Such an employee can be accommodated by allowing the equivalent of her union dues (payments by union members) or agency fees (payments often required from non-union members in a unionized workplace) to payment, be paid to a charity agreeable to the employee, the union, and the employer. [193] Whether a charity-substitute accommodation for payment of union dues would cause an undue hardship is an individualized determination based upon, among other things, the union’s size, operational costs, and the number of individuals that need the accommodation. [194] If an employee’s religious objection is not to joining or financially supporting the union, but rather to Essay internet pdf, the union’s support of certain political or social causes, the employee may be accommodated if it would not pose an undue hardship by, for example, reducing the Research amount owed and/or by allowing the employee to donate to a charitable organization the Custom writing full amount the Research paper payment employee owes or that portion that is attributable to the union’s support of the cause to which the cheap employee has a religious objection, or by payment diverting the full amount to the national, state, or local union in the event one of those entities does not engage in support of the cause to which the employee has a religious objection. Help? [195]

6. Permitting Prayer, Proselytizing, and Other Forms of Religious Expression. Some employees may seek to display religious icons or messages at their work stations. Research Paper Payment? Others may seek to proselytize by engaging in one-on-one discussions regarding religious beliefs, distributing literature, or using a particular religious phrase when greeting others. Still others may seek to engage in prayer at their work stations or to with english message, use other areas of the workplace for Research paper payment, either individual or group prayer or study. In some of these situations, an employee might request accommodation in advance to permit such religious expression. In other situations, the employer will not learn of the with english message situation or be called upon to consider any action unless it receives complaints about the religious expression from Research paper payment either other employees or customers. Essay Writing Pdf? As noted in §§ II-A-3 and III-C of this document, prayer, proselytizing, and other forms of religious expression do not solely raise the issue of Research religious accommodation, but may also raise disparate treatment or harassment issues. To determine whether allowing or continuing to permit an employee to pray, proselytize, or engage in with english message, other forms of paper religiously oriented expression in the workplace would pose an undue hardship, employers should consider the potential disruption, if any, that will be posed by permitting this expression of religious belief. [196] As explained below, relevant considerations may include the effect such expression has had, or can reasonably be expected to have, if permitted to continue, on co-workers, customers, or business operations. a. Effect on essays for ap Workplace Rights of Co-Workers. Expression can create undue hardship if it disrupts the work of other employees or constitutes or threatens to constitute unlawful harassment. Since an employer has a duty under Title VII to protect employees from religious harassment, it would be an undue hardship to accommodate such expression.

As explained in § III-A-2-b of this document, religious expression directed toward co-workers might constitute harassment in some situations, for example where it is Research payment, facially abusive ( i.e. , demeans people of other religions), or where, even if not abusive, it persists even though the co-workers to english writing, whom it is directed have made clear that it is unwelcome. It is necessary to make a case-by-case determination regarding whether the effect on co-workers actually is an undue hardship. However, this does not require waiting until the alleged harassment has become severe or pervasive. [197] As with harassment on any basis, it is permitted and advisable for paper payment, employers to literary use, take action to stop alleged harassment before it becomes severe or pervasive, because while isolated incidents of harassment generally do not violate federal law, a pattern of such incidents may be unlawful. [198] The determination of whether it is an undue hardship to allow employees to engage in paper, religiously oriented expression toward customers is a fact-specific inquiry and will depend on short hardship letter the nature of the expression, the Research nature of the employer’s business, and the extent of the impact on customer relations. For example, one court found that it did not impose an undue hardship for a private sector employer to allow a cashier to use the general religious greeting “Have a Blessed Day” in accepting payment where it was said in essays, the context of brief anonymous interactions and had little demonstrable adverse impact on customers or the business. Research Paper? [199] However, other courts have found undue hardship where religiously oriented expression was used in the context of a regular business interaction with a client. [200] Whether or not the short hardship letter client objects, this may be an paper payment undue hardship for an employer where the expression could be mistaken as the employer’s message. Where the religiously oriented expression is not limited to use of a phrase or greeting, but rather is in Essay pdf, the manner of individualized, specific proselytizing, an paper payment employer is far more likely to be able to demonstrate that it would constitute an Essay pdf undue hardship to accommodate an employee’s religious expression, regardless of the length or nature of the business interaction. [201] Display of Research paper payment Religious Objects By an Employee. Susan and Roger are members of the same church and are both employed at use XYZ Corporation. Susan works as an architect in a private office on an upper floor, where she occasionally interacts with co-workers, but not with clients. Paper Payment? Roger is a security guard stationed at a desk in the front lobby of the XYZ building through which all employees, clients, and other visitors must enter.

At a recent service at use Susan and Research paper payment, Roger’s church, the minister distributed posters with the message “Jesus Saves!” and encouraged parishioners to display the posters at their workplaces in order to “spread the word.” Susan and Roger each display the Essay pdf poster on the wall above their respective work stations. XYZ orders both to remove the poster despite the paper payment fact that both explained that they felt a religious obligation to display it, and despite the fact that there have been no complaints from How to essay for scholarship letter co-workers or clients. Susan and Roger file charges alleging denial of religious accommodation. Research Payment? The employer will probably be unable to show that allowing Susan to How to write essay for scholarship, display a religious message in Research payment, her personal workspace posed an undue hardship, because there was no evidence of any disruption to essay, the business or the Research payment workplace which resulted. Writing Essays English? By contrast, because Roger sits at the lobby desk and paper payment, the poster is the first thing that visitors see upon entering the building, it would appear to represent XYZ’s views and would therefore likely be shown to Essay internet, pose an undue hardship. [202] Undue Hardship to Allow Employee to Discuss Religion with Clients. Helen, an employee in a mental health facility that served a religiously and Research, ethnically diverse clientele, frequently spoke with clients about religious issues and writing reviews, shared religious tracts with them as a way to Research, help solve their problems, despite being instructed not to do so. After clients complained, Helen’s employer issued her a letter of How to write essay hardship letter reprimand stating that she should not promote her religious beliefs to clients and Research paper payment, that she would be terminated if she persisted. Helen’s belief in the need to short hardship, evangelize to clients cannot be accommodated without undue hardship. The employer has the right to control speech that threatens to impede provision of effective and efficient services.

Clients, especially in a mental health setting, may not understand that the religious message represents Helen’s views rather than the clinic’s view of the most beneficial treatment for the patient. [203] Some employers have integrated their own religious beliefs or practices into Research payment the workplace, and they are entitled to do so. [204] However, if an essays english employer holds religious services or programs or includes prayer in business meetings, Title VII requires that the employer accommodate an paper payment employee who asks to be excused for religious reasons, absent a showing of Essay writing internet pdf undue hardship. Research Payment? [205] Excusing an employee from religious services normally does not create an undue hardship because it does not cost the employer anything and does not disrupt business operations or other workers. [206] Prayer at Meetings. Michael’s employer requires that the mandatory weekly staff meeting begin with a religious prayer. Michael objects to participating because he believes it conflicts with his own sincerely held religious beliefs. He asks his supervisor to allow him to How to for scholarship hardship letter, arrive at the meeting after the prayer. The supervisor must accommodate Michael’s religious belief by either granting his request or offering an alternative accommodation that would remove the conflict between Michael’s religious belief and Research paper payment, the staff meeting prayer, even if other employees of Michael’s religion do not object to being present for the prayer. [207] Employer Holiday Decorations.

Each December, the president of with writing message XYZ corporation directs that several wreaths be placed around the office building and a tree be displayed in the lobby. Several employees complain that to accommodate their non-Christian religious beliefs, the employer should take down the wreaths and tree, or alternatively should add holiday decorations associated with other religions. Title VII does not require that XYZ corporation remove the Research payment wreaths and writing, tree or add holiday decorations associated with other religions. The result under Title VII on these facts would be the same whether in a private or government workplace. [208] Similarly, an employer is required, absent undue hardship, to excuse an employee from Research payment compulsory personal or professional development training where it conflicts with the employee’s sincerely held religious beliefs or practices. Pay For Literary Anlaysis Paper? [209] There may be cases, however, where an employer can show that it would pose an undue hardship to provide an alternative training or to Research paper, excuse an employee from Essay internet pdf any part of a particular training, even if the employee asserts it is contrary to his religious beliefs to attend ( e.g. , where the training provides information on how to perform the Research paper payment job, on how to comply with equal employment opportunity obligations, or on other workplace policies, procedures, or applicable legal requirements). Religious Objection to Training Program Employee Must Be Excused. As part of Custom essay its effort to promote employee health and productivity, the new president of a company institutes weekly mandatory on-site meditation classes led by a local spiritualist. Angelina explains to her supervisor that the paper meditation conflicts with her sincerely held religious beliefs, and asks to be excused from participating.

Because it would not pose an undue hardship, the company must accommodate Angelina’s religious belief by excusing her from the weekly meditation classes, even if the writing reviews cheap company and other employees believe that this form of meditation does not conflict with any religious beliefs. Religious Objection to Training Program Employee Need Not Be Excused. Employer XYZ holds an annual training for payment, employees on a variety of personnel matters, including compliance with EEO laws and Custom essay reviews cheap, also XYZ’s own internal anti-discrimination policy, which includes a prohibition on sexual orientation discrimination. Lucille asks to be excused from the Research paper payment portion of the training on sexual orientation discrimination because she believes that it “promotes the acceptance of homosexuality,” which she sincerely believes is immoral and Writing, sinful based on her religion. The training does not tell employees to value different sexual orientations but simply discusses and reinforces the Research employer’s conduct rule requiring employees not to discriminate against or harass other employees and to treat one another professionally. Because an reviews cheap employer needs to make sure that its employees know about and comply with such employer workplace rules, it would be an undue hardship for paper, XYZ to excuse Lucille from the Essay pdf training.[210] While not all of the payment following issues will be in dispute in every charge alleging denial of religious accommodation, if CP alleges that R failed to accommodate CP’s religious beliefs or practices, the Custom essay cheap investigator should generally follow this line of inquiry, considering these steps: Ascertain the nature of the belief or practice that CP claims R has failed to accommodate ( e.g. Research Paper Payment? , dress, grooming, holy day observance, etc.) and what accommodation was sought (e.g., exception to dress code, schedule change, leave, etc.). If disputed by R, determine whether CP’s beliefs are “religious” in nature.

If disputed by R, determine whether CP “sincerely holds” the short essay hardship particular religious belief or practice at issue. Ascertain whether CP actually notified R of the need for a religious accommodation, i.e. , whether it was made known to R that an accommodation was needed and that it was for religious reasons. The investigator should seek evidence of when, where, how, and to whom such notice was given, and Research, the names of any witnesses to the notification. If R claims that it was not notified of essay for scholarship hardship CP’s need for an accommodation, the Research paper investigator should attempt to resolve the discrepancies between R’s contention and CP’s allegation by literary anlaysis gathering additional available evidence corroborating or refuting CP’s and R’s contentions. Determine R’s response, if any, to the accommodation request. Was an paper payment accommodation offered, and Essay, if so, what? The investigator should obtain R’s statement of all attempts to accommodate CP, if any attempts were made. The investigator should seek a specific and complete explanation from R as to the facts on which it relied ( e.g. , why R concluded CP did not have a sincerely-held religious belief or practice, or why R concluded that accommodation would have posed an Research undue hardship in terms of cost, disruption, effect on co-workers, or any other reason).

For example, in the event R is How to write short for scholarship letter, a union and the accommodation claim relates to payment of agency fees or union dues, the investigator should obtain any relevant information regarding how the particular union at issue may have handled payment by this religious objector in order to provide accommodation. If R asserts that it did not accommodate CP’s request because it would have posed an undue hardship, obtain all available evidence regarding whether or not a hardship would in fact have been posed, i.e. , whether the alleged burden is more than de minimis . If R’s undue hardship defense is based on cost, ascertain the cost of the accommodation in relation to R’s size, nature of Research paper payment business operations, operating costs, and the impact, if any, of similar accommodations already being provided to other employees. If R’s undue hardship defense is based on a factor other than cost ( i.e. Essay For Scholarship Hardship? , disruption, production or staffing levels, security, or other factor), similarly ascertain the impact of the Research paper accommodation with respect to R’s particular workplace and business. When there is more than one method of accommodation available that would not cause undue hardship, the Essay writing internet investigator should evaluate whether the paper accommodation offered is reasonable by Dissertation consulting examining: (1) whether any alternative reasonable accommodation was available; (2) whether R considered any alternatives for accommodation; (3) the alternative(s) for accommodation, if any, that R actually offered to CP; and (4) whether the alternative(s) the employer offered eliminated the conflict. [211] If R asserts CP failed to cooperate with R in reaching an accommodation, obtain any available evidence regarding the relevant communications, including whether CP refused any offer of reasonable accommodation. Reasonable Accommodation - Generally. Employers should inform employees that they will make reasonable efforts to paper payment, accommodate the employees’ religious practices.

Employers should train managers and supervisors on how to recognize religious accommodation requests from employees. Employers should consider developing internal procedures for processing religious accommodation requests. Service Editing? Employers should individually assess each request and avoid assumptions or stereotypes about Research paper what constitutes a religious belief or practice or what type of accommodation is appropriate. Employers and Help, employees should confer fully and promptly to Research, the extent needed to share any necessary information about the Help writing message employee’s religious needs and the available accommodation options. Research Payment? An employer is not required to provide an employee’s preferred accommodation if there is more than one effective alternative to choose from. An employer should, however, consider the employee’s proposed method of accommodation, and if it is Pay for literary anlaysis, denied, explain to the employee why his proposed accommodation is not being granted. Managers and Research paper, supervisors should be trained to consider alternative available accommodations if the particular accommodation requested would pose an undue hardship. When faced with a request for a religious accommodation which cannot be promptly implemented, an Essay writing employer should consider offering alternative methods of accommodation on a temporary basis, while a permanent accommodation is Research paper payment, being explored. In this situation, an employer should also keep the employee apprised of the status of the employer’s efforts to implement a permanent accommodation. The de minimis undue hardship standard refers to the legal requirement. As with all aspects of employee relations, employers can go beyond the requirements of the law and essay, should be flexible in evaluating whether or not an Research accommodation is Dissertation service editing, feasible.

An employer should not assume that an accommodation will conflict with the terms of a seniority system or CBA without first checking if there are any exceptions for religious accommodation or other avenues to allow accommodation consistent with the seniority system or CBA. An employer should not automatically reject a request for religious accommodation just because the accommodation will interfere with the existing seniority system or terms of a CBA. Research Payment? Although an employer may not upset co-workers’ settled expectations, an Help english employer is payment, free to seek a voluntary modification to a CBA in order to accommodate an employee’s religious needs. Employers should train managers to be aware that, if the requested accommodation would violate the CBA or seniority system, they should confer with the employee to determine if an Essay writing internet alternative accommodation is available. Employers should ensure that managers are aware that reasonable accommodation may require making exceptions to policies or procedures that are not part of a CBA or seniority system, where it would not infringe on Research other employees’ legitimate expectations. Employers should work with employees who need an adjustment to Dissertation consulting, their work schedule to accommodate their religious practices. Notwithstanding that the legal standard for Research paper payment, undue hardship is “more than de minimis ,” employers may of course choose voluntarily to incur whatever additional operational or financial costs they deem appropriate to Dissertation service editing, accommodate an employee’s religious need for paper payment, scheduling flexibility. Employers should consider adopting flexible leave and scheduling policies and Help with english writing message, procedures that will often allow employees to meet their religious and other personal needs. Research Paper? Such policies can reduce individual requests for exceptions. For example, some employers have policies allowing alternative work schedules and/or a certain number of “floating” holidays for each employee. While such policies may not cover every eventuality and english message, some individual accommodations may still be needed, the number of such individual accommodations may be substantially reduced.

Voluntary Substitutes or Swaps. An employer should facilitate and encourage voluntary substitutions and swaps with employees of substantially similar qualifications by Research payment publicizing its policy permitting such arrangements, promoting an atmosphere in which substitutes are favorably regarded, and providing a central file, bulletin board, group e-mail, or other means to help an employee with a religious conflict find a volunteer to substitute or swap. Change of Job Assignments and Lateral Transfers. An employer should consider a lateral transfer when no accommodation which would keep the employee in his or her position is possible absent undue hardship. Custom Essay? However, an employer should only resort to transfer, whether lateral or otherwise, after fully exploring accommodations that would permit the employee to Research payment, remain in his position. Writing For Ap English? Where a lateral transfer is unavailable, an employer should not assume that an Research payment employee would not be interested in service editing, a lower-paying position if that position would enable the employee to abide by his or her religious beliefs.

If there is Research, no accommodation available that would permit the employee to for ap, remain in his current position or an equivalent one, the employer should offer the available position as an accommodation and permit the employee to decide whether or not to take it. Modifying Workplace Practices, Policies, and payment, Procedures. Employers should make efforts to accommodate an employee’s desire to Pay for paper, wear a yarmulke, hijab, or other religious garb. If the employer is concerned about uniform appearance in a position which involves interaction with the Research public, it may be appropriate to consider whether the essay writing employee’s religious views would permit him to Research, resolve the religious conflict by, for example, wearing the item of religious garb in the company uniform color(s). Managers and employees should be trained not to engage in stereotyping based on religious dress and grooming practices and should not assume that atypical dress will create an How to write essay for scholarship undue hardship. Employers should be flexible and creative regarding work schedules, work duties, and selection procedures to the extent practicable. Employers should be sensitive to the risk of payment unintentionally pressuring or coercing employees to attend social gatherings after the employees have indicated a religious objection to attending. Permitting Prayer, Proselytizing, and Help writing, Other Forms of Religious Expression. Employers should train managers to gauge the paper actual disruption posed by essay for scholarship hardship letter religious expression in the workplace, rather than merely speculating that disruption may result.

Employers should also train managers to identify alternative accommodations that might be offered to avoid actual disruption ( e.g. , designating an unused or private location in the workplace where a prayer session or Bible study meeting can occur if it is disrupting other workers). Research Paper? Employers should incorporate a discussion of religious expression, and the need for all employees to be sensitive to the beliefs or non-beliefs of others, into any anti-harassment training provided to managers and Writing, employees. Employees should advise their supervisors or managers of the nature of the payment conflict between their religious needs and with writing, the work rules. Employees should provide enough information to enable the employer to understand what accommodation is needed, and why it is paper, necessitated by a religious practice or belief. Employees who seek to proselytize in the workplace should cease doing so with respect to any individual who indicates that the communications are unwelcome.

12-V RELATED FORMS OF DISCRIMINATION. A. National Origin, Race , and writing, Color. Title VII’s prohibition against religious discrimination may overlap with Title VII’s prohibitions against payment discrimination based on national origin, race, and color. Where a given religion is strongly associated or perceived to Pay for anlaysis paper, be associated with a certain national origin, the same facts may state a claim of both religious and national origin discrimination. [212] All four bases might be implicated where, for example, co-workers target a dark-skinned Muslim employee from Saudi Arabia for harassment because of his religion, national origin, race, and/or color. [213] Title VII prohibits retaliation by an employer, employment agency, or labor organization because an Research payment individual has engaged in writing internet pdf, protected activity. [214] Protected activity consists of opposing a practice the Research paper payment employee reasonably believes is made unlawful by one of the employment discrimination statutes or of filing a charge, testifying, assisting, or participating in any manner in write short essay, an investigation, proceeding, or hearing under the statute. EEOC has taken the position that requesting religious accommodation is protected activity. [215] Retaliation for paper payment, Requesting Accommodation. Jenny requests that she be excused from daily employer-sponsored Christian prayer meetings because she is an atheist.

Her supervisor insists that she attend, but she persists in her request that she should be excused, and explains that requiring her to consulting service, attend is offensive to her religious beliefs. She takes her request to human resources, and informs them that requiring her to attend these prayer meetings is offensive to paper, her religious beliefs. Despite her supervisor’s objections, the human resources department instructs the supervisor that in the circumstances no undue hardship is posed and he must grant the Pay for anlaysis use request. Research Paper Payment? Motivated by reprisal, her supervisor shortly thereafter gives her an unjustified poor performance rating, and denies her requests to attend training that is approved for reviews cheap, similarly situated employees. This violates Title VII. Employers can reduce the risk of retaliation claims by training managers and paper payment, supervisors to be aware of their anti-retaliation obligations under Title VII, including specific actions that may constitute retaliation. Employers can help reduce the risk of retaliation claims by consulting editing carefully and timely recording the payment accurate business reasons for disciplinary or performance related actions and sharing these reasons with the consulting service employee. HOW APPLICANTS OR EMPLOYEES CAN FILE A CHARGE. If you believe you have been discriminated against by a private sector or state or local government employer, labor union, or employment agency when applying for a job or while on the job because of your race, color, religion, sex, national origin, age (40 or over), or disability, or believe that you have been discriminated against Research payment because you opposed unlawful discrimination or participated in Essay writing, an equal employment opportunity (EEO) proceeding, you may file a charge of discrimination with the U.S.

Equal Employment Opportunity Commission (EEOC). Charges against private sector and local and state government employers may be filed in person, by mail, or by telephone by contacting the nearest EEOC office. If there is no EEOC office in the immediate area, call toll free 1-800?669?4000 or 1?800?669?6820 (TTY) for more information. To avoid delay, call or write beforehand if you need special assistance, such as an payment interpreter, to file a charge. Essay Writing Internet Pdf? Federal sector employees and applicants should contact the EEO office of the agency responsible for the alleged discrimination to initiate EEO counseling. There are strict time frames in payment, which charges of employment discrimination must be filed or your agency’s EEO office must be contacted. Consulting Editing? When charges or complaints are filed beyond these time frames, you may not be able to obtain any remedy. Charges against private sector or state or local governments must be filed with EEOC within 180 days of the alleged discriminatory act.

The time frame is extended to paper, 300 days if the alleged discrimination arose in a state or locality that has a fair employment practices agency (FEPA) with the authority to Custom reviews cheap, grant or seek relief for the alleged discrimination. Paper Payment? Federal sector employees and applicants must initiate EEO counseling at the agency responsible for the alleged discrimination within 45 days of the alleged discriminatory event. Allegations of service editing harassment based on race, color, religion, sex, or national origin are timely if at least one incident of harassment that is part of the larger pattern of harassment occurred within the filing period. If you wish to remain anonymous during the period when an Research payment EEOC charge is being processed involving a private sector or state or local government employer, another individual or an organization may file a charge on your behalf. In some circumstances, an EEOC Commissioner may file a charge against a private sector or state or local government employer. Federal sector employees and applicants may remain anonymous during EEO counseling, but lose the Dissertation consulting service editing right to anonymity after filing a formal complaint. WHEN A CHARGE IS FILED AGAINST A PRIVATE SECTOR OR STATE OR LOCAL GOVERNMENT EMPLOYER. This appendix provides general information regarding the processing of a charge alleging discrimination by a private sector or state or local government employer under the EEO statutes. Research Paper? The information presented in this appendix applies to private sector and state and local government employers only. For information on the processing of complaints against federal agencies, visit the EEOC’s “Federal Sector Information” page on the Internet at service http://eeoc.gov/federal/fed_employees/index.cfm. Anyone who believes that a private sector or state or local government employer has violated his or her employment rights based on race, color, sex, religion, national origin, age (40 or over), disability, opposition to Research paper, unlawful discrimination, or participation in an EEO proceeding, may file a charge of discrimination with the EEOC.

A charge does not constitute a finding that your company did, in fact, discriminate. The EEOC has a responsibility to investigate and determine whether there is reasonable cause to internet, believe discrimination occurred. That process begins with the EEOC sending your company a copy of the charge, which will briefly identify the charging party, the basis ( e.g. , race, religion, etc.) and payment, issues (hiring, promotion, etc.), and the date(s) of the alleged discrimination. You also may be asked to provide a response to the charge and supporting documentation. The EEOC also may ask to visit your work site or to interview some employees. Writing Essays English? It is important that your company retain records relating to paper payment, issues under investigation as a result of the How to write short essay for scholarship hardship charge until the charge or any lawsuit based on the charge is resolved. In some cases, the EEOC notice may offer mediation as a method of resolving the charge before an investigation. EEOC’s mediation program is payment, a free service, and participation is voluntary. The process is confidential, and there is a firewall ( i.e. , total separation) between the essay cheap mediation program and EEOC’s enforcement activities. Payment? Mediation provides employers and Custom essay writing, charging parties the opportunity to reach mutually agreeable solutions early in the process.

The EEOC will notify your company if a charge is eligible for mediation. In the event that mediation does not succeed, the Research paper charge is write, referred for Research paper, investigation. If the How to for scholarship EEOC finds reasonable cause to believe that your company discriminated against a charging party, it will invite you to conciliate the charge ( i.e. , the EEOC will offer you a chance to resolve the matter informally). In some cases, where conciliation fails, the EEOC will file a civil court action. If the EEOC does not find discrimination, or if conciliation fails and the EEOC chooses not to file suit, it will issue a notice of paper payment a right to sue, which gives the charging party 90 days to file a civil court action. The EEOC also must issue a notice of right to sue to the charging party on request if its handling of the charge is still pending after 180 days, or earlier if the EEOC knows it will take more than 180 days to complete action on Writing for ap the charge. In all cases, your company should remember that it is unlawful to retaliate against the charging party for filing the charge, even if you believe the charge is without merit. You should submit a response to paper payment, the EEOC and provide the information requested, even if you believe the charge is Help message, frivolous.

If the charge was not dismissed by the EEOC when it was received, that means there was some basis for proceeding with further investigation. There are many cases where it is unclear whether discrimination may have occurred and an investigation is necessary. You are encouraged to present any facts that you believe show the allegations are incorrect or do not amount to paper, a violation of the Pay for anlaysis law. [1] This document uses examples that refer to Research, the practices and beliefs of various religions. These examples are intended to short for scholarship hardship letter, clarify the legal principles for which they are used and do not purport to represent the Research paper religious beliefs or practices to which they refer.

In some instances, links to non-EEOC Internet sites are also provided for the reader’s convenience in obtaining additional information. EEOC assumes no responsibility for their content and short essay hardship letter, does not endorse their organizations or guarantee the accuracy of these sites. [2] This Section of the Compliance Manual replaces Section 628: Religious Accommodation , EEOC Compliance Manual, Volume II and payment, its Appendices: Appendix A, Policy Statement on Ansonia Board of Education v. Philbrook and Essay writing, Religious Accommodation ; Appendix B, Policy Guidance On ‘New Age’ Training Programs Which Conflict With Employees’ Religious Beliefs ; and Appendix C, Religious Objections to Unionism . It also replaces the following policy documents: Religious Organizations that Pay Women Less than Men in Accordance with Religious Beliefs ; Religious Organization Exemption Under Title VII of the Civil Rights Act of paper 1964, as amended ; and How to for scholarship letter, Policy Statement on Goldman v. Weinberger (Accommodation of the Wearing of payment Religious Dress ). The Commission’s Guidelines on Discrimination Because of Religion (hereafter Commission Guidelines ) are not affected by this Section. Writing Reviews? See Commission Guidelines , 29 C.F.R. Part 1605. [3] Use of the term “employee” in Research payment, this document should be presumed to include an applicant and, as appropriate, a former employee. [4] 42 U.S.C. § 2000e-2(a) provides that it is an unlawful employment practice for an employer: (1) to fail or refuse to hire or to discharge any individual, or otherwise to discriminate against any individual with respect to his compensation, terms, conditions or privileges of employment, because of such individual’s race, color, religion, sex, or national origin; or.

(2) to limit, segregate, or classify his employees or applicants for employment in any way which would deprive or tend to deprive any individual of employment opportunities or otherwise adversely affect his status as an employee, because of such individual’s race, color, religion, sex, or national origin. 42 U.S.C. § 2000e(j) provides that: The term “religion” includes all aspects of religious observance and practice, as well as belief, unless an employer demonstrates that he is unable to Pay for anlaysis, reasonably accommodate an employee’s or prospective employee’s religious observance or practice without undue hardship on the conduct of the employer’s business. [5] Federal legislation known as the Workplace Religious Freedom Act (“WRFA”), that has been proposed since the 1990s, would amend Title VII to change the current “ de minimis ” standard for Research payment, establishing undue hardship to require employers to show that the accommodation would cause significant difficulty or expense. See H.R. Consulting? 1431, 110th Cong. (2007). Payment? This compliance manual chapter interprets and applies the current federal law, and essays english, takes no position on WRFA. Note: Various state and local laws extend beyond Title VII in terms of the paper payment protected bases covered, the discrimination prohibited or accommodation required, and the legal standards and Essay writing internet, defenses that apply. [6] See, e.g., Torcaso v. Watkins , 367 U.S. Paper? 488, 495 n.11 (1961) (First Amendment does not permit government to distinguish between theistic and non-theistic religions such as Buddhism, Taoism, Ethical Culture, and Secular Humanism); Young v. Southwestern Sav. Loan Ass’n, 509 F.2d 140 (5th Cir.

1975) (Title VII violated by requiring atheist employee to attend prayer portion of business meeting). [7] Society for Human Resource Management (SHRM) and Custom essay writing reviews cheap, the Tanenbaum Center for Interreligious Understanding, Religion in the Workplace Survey, at 6 (Society for Human Resource Management, 2001) (executive summary and information on obtaining report available at http://www.tanenbaum.org/research.html (last visited July 2, 2008); Pew Forum on Religion and Public Life, U.S. Religious Landscape Survey (2008), available at http://religions.pewforum.org/reports (last visited July 2, 2008). [8] In fiscal year 2007, EEOC received 2,880 religious discrimination charges, accounting for 3.5% of all charges filed with the Commission that year. In fiscal year 1992, EEOC received 1,388 religious discrimination charges, accounting for 1.9% of all charges filed with the Commission that year. Statistics regarding the number of religious discrimination charges filed with the paper Commission can be found at http://eeoc.gov/eeoc/statistics/enforcement/charges.cfm. [9] “Religion in the Workplace is a Diversity Issue for U.S. Paper? Companies,” U.S. Paper Payment? Department of State’s Bureau of International Information Programs (Nov. 28, 2007), available at http://www.america.gov/st/ washfile-english/2007/November/20071128173019xlrennef0.1781427.html (last visited July 2, 2008). [10] The principles discussed in this Section apply to Title VII claims against private employers as well as to federal, state, and local public sector employers, unless otherwise noted.

See 42 U.S.C. §§ 2000e(a) - (b), 2000e-16(a), et seq. , and 2000e-16a. Anlaysis Paper Use? See, e.g. , infra nn.11-15, 66 (directing attention to situations where the Religious Freedom Restoration Act (RFRA) may apply), and 201-203. As explained in n.5, supra , claims under various state or local laws may be analyzed under different standards. [11] The First Amendment religion and speech clauses (“Congress shall make no law respecting an paper payment establishment of religion, or prohibiting the free exercise thereof; or abridging the freedom of speech”) protect individuals against restrictions imposed by the government, not by private entities, and How to for scholarship, therefore do not apply to rules imposed on private sector employees by their employers. The First Amendment, however, does protect private sector employers from government interference with their free exercise and speech rights. Moreover, government employees’ religious expression is protected by both the First Amendment and Title VII. See infra nn.12-15, 66, and accompanying text; Brown v. Polk County , 61 F.3d 650 (8th Cir. 1995); Guidelines on Religious Exercise and Religious Expression in the Federal Workplace (Aug. 14, 1997) (hereafter Federal Workplace Guidelines ), 158 Daily Labor Report (BNA) 1522-5968 (Aug. 15, 1997) (available at http://clinton2.nara.gov/WH/New/html/19970819-3275.html (last visited July 2, 2008)).

Although the Federal Workplace Guidelines are directed at federal employers, they provide useful guidance for private employers as well. In addition, the paper payment U.S. Anlaysis? Department of Justice maintains a website, www.firstfreedom.gov, which provides information on a variety of Research paper constitutional and statutory religious discrimination issues, including a section on literary anlaysis paper Title VII employment protections based on religion. [12] See Daniels v. City of Arlington , 246 F.3d 500 (5th Cir.) (as a government entity, police department may be able to demonstrate that providing the payment requested accommodation would have posed an undue hardship because allowing the officer to Dissertation service, wear a cross on Research paper payment his uniform would give the appearance of public agency endorsement of the officer’s religious views, in Essay, violation of the department’s constitutional obligations), cert. denied , 534 U.S. 951 (2001); Helland v. South Bend Cmty. Sch. Corp. , 93 F.3d 327 (7th Cir. 1996) (public school did not violate either plaintiff’s Title VII religious accommodation right or his First Amendment free exercise right by removing plaintiff from substitute teacher list due to his proselytizing in class); Brown v. Polk County , 61 F.3d at 656-59 (where there was no evidence that subordinates objected on religious grounds , it would not have posed an undue hardship under Title VII, or violated the First Amendment Establishment Clause, to accommodate supervisor’s occasional affirmations of Christianity and spontaneous voluntary prayers during meetings). [13] See, e.g., EEOC v. Paper? Townley Eng’g Mfg.

Co. , 859 F.2d 610, 621 (9th Cir. Literary Anlaysis Use? 1988) (court must balance the application of Title VII to the employment policy against private employers’ right under First Amendment Free Exercise clause to payment, practice their religion; private secular employer’s free exercise right to hold mandatory religious services for employees did not outweigh its Title VII obligation to english, accommodate atheist employee’s request to payment, be exempt from attending the services on religious grounds; excusing plaintiff’s attendance would not pose an undue hardship on operation of employer’s business). [14] See, e.g., Knight v. Connecticut Dep’t of anlaysis use Pub. Research? Health , 275 F.3d 156, 164-65 (2d Cir. 2001) (state agency did not violate either Title VII or First Amendment Free Exercise Clause by refusing to allow employee to writing message, evangelize clients of state agency while performing job duties; in addition, employer would have risked First Amendment Establishment Clause violation by permitting the accommodation); Fraternal Order of Police v. City of Newark , 170 F.3d 359 (3d Cir. 1999) (police department violated Sunni Muslim officer’s First Amendment free exercise rights by refusing to make a religious exception to its “no beard” policy to accommodate his beliefs, while exempting other officers for medical reasons); Draper v. Logan County Pub. Library , 403 F. Supp. 2d 608 (W.D.

Ky. 2005) (public library employee’s First Amendment free speech and free exercise rights were violated when she was prohibited from Research payment wearing a necklace with a cross ornament). [15] Guidance for government workplaces on the First Amendment religious free exercise issues, much of which is Pay for anlaysis, also useful for the private sector, is available in the Federal Workplace Guidelines , supra n.11 ; see also Brown , 61 F.3d at 658 (applying First Amendment test governing free speech of payment public employees to First Amendment free exercise claims, court balanced an Essay writing internet employee’s right to Research paper, free exercise with the employer’s interest in Writing essays for ap english, providing effective and efficient public services; public employee’s termination constituted both denial of religious accommodation under Title VII and violation of Research paper First Amendment Free Exercise Clause). [16] 42 U.S.C. § 2000e-2. To determine whether an entity is covered by Title VII, see EEOC Compliance Manual, “Threshold Issues,” https://www.eeoc.gov/policy/docs/threshold.html. Although this document concerns Title VII, employers and employees should note that there may be state and Writing, local laws in their jurisdiction prohibiting religious discrimination in payment, employment, some of which may be parallel to Title VII and Essay, some of paper which may afford narrower or broader coverage.

[18] “Theistic” is defined as “believing in a god or gods.” The American Heritage Dictionary of the English Language , Fourth Ed , Houghton Mifflin Co. (2004), available at http://dictionary.reference.com/browse/theistic (last visited July 2, 2008). [19] 42 U.S.C. § 2000e(j). Redmond v. GAF Corp. , 574 F.2d 897, 900 (7th Cir. Essays? 1978) (the statutory language “all aspects of religious practice and belief” is interpreted broadly; “to restrict the act to those practices which are mandated or prohibited by a tenet of the religion, would involve the Research payment court in determining not only what are the tenets of a particular religion, which by itself perhaps would not be beyond the province of the court, but would frequently require the courts to decide whether a particular practice is or is not required by the tenets of the How to hardship religion”); s ee also Employment Div., Dep’t of Human Res. of Research payment Oregon v. Help With English Writing? Smith , 494 U.S. 872, 887 (1990) (in holding that the Free Exercise Clause did not prohibit application of paper Oregon drug laws to ceremonial ingestion of Writing essays english peyote, Court noted that “[r]epeatedly and in many different contexts, we have warned that courts must not presume to determine the Research place of a particular belief in a religion or the plausibility of a religious claim”). [20] Thomas v. Review Bd. of the Indiana Employment Sec. Div. , 450 U.S. How To Essay For Scholarship Hardship Letter? 707, 714 (1981) (“religious beliefs need not be acceptable, logical, consistent, or comprehensible to others in order to merit First Amendment protection”); see also Church of Lukumi Babalu Aye, Inc. v. City of Hialeah , 508 U.S. Payment? 520, 531 (1993) (although animal sacrifice may seem “abhorrent” to Help message, some, Santerian belief is religious in nature and is protected by the First Amendment); U.S. v. Meyers , 906 F. Research Payment? Supp. Internet? 1494, 1499 (D. Wyo.

1995) (“one man’s religion will always be another man’s heresy”). [21] Thomas , 450 U.S. at 716 (“[I]t is not within the Research judicial function and judicial competence to Pay for literary paper, inquire whether the petitioner or [another practitioner] . . . more correctly perceived the commands of their common faith. Courts are not arbiters of scriptural interpretation.”). [22] Redmond , 574 F.2d at 901 n.12 (Title VII case citing United States v. Seeger , 380 U.S. 163 (1969), and Research, Welsh v. United States , 398 U.S. 333 (1970), which defined protected “religion” for purposes of the internet pdf Universal Military Training and paper payment, Service Act). Custom Essay Reviews? Unless otherwise noted, cases are cited in this document for Research paper payment, their Title VII holdings.

[23] Seeger , 380 U.S. at 176. Write Short Essay For Scholarship Letter? “This standard was developed in Research payment, [ Seeger ] and [ Welsh ]. How To Short Essay For Scholarship? The Commission has consistently applied this standard in paper payment, its decisions.” 29 C.F.R. § 1605.1. [24] Commission Guidelines , 29 C.F.R. Dissertation Editing? § 1605.1 (“The fact that no religious group espouses such beliefs or the fact that the religious group to which the individual professes to belong may not accept such belief will not determine whether the Research paper belief is a religious belief of the employee or prospective employee.”); Welsh, 398 U.S. at 343 (petitioner’s beliefs were religious in Writing for ap, nature although the church to Research, which he belonged did not teach those beliefs); accord Africa v. Internet Pdf? Commonwealth of Pa ., 662 F.2d 1025, 1032-33 (3d Cir.1981); Bushouse v. Local Union 2209, United Auto., Aerospace Agric. Implement Workers of Am. , 164 F. Supp. 2d 1066, 1076 n.15 (N.D. Ind. 2001) (“Title VII’s intention is to Research paper payment, provide protection and accommodation for a broad spectrum of religious practices and belief not merely those beliefs based upon organized or recognized teachings of a particular sect”). [25] Commission Guidelines , 29 C.F.R. Short Hardship Letter? § 1605.1; Torcaso , 367 U.S. at 489-90 (government may not favor theism over pantheism or atheism); Welsh , 398 U.S.

333 (to be religion protected by the First Amendment, a belief system need not have a concept of Research payment a god, supreme being, or afterlife; plaintiff’s belief was deemed to be religious because it was held with strength of traditional religious beliefs); Townley , 859 F.2d 610 (Title VII prohibits an employer from Custom essay compelling its atheist employees to attend religious services); Young , 509 F.2d 140 (same). [26] United States v. Meyers, 906 F. Supp. Research Paper? 1494, 1499 (D. Wyo. Pdf? 1995) (the threshold for establishing the paper religious nature of beliefs is essays, low; under the First Amendment, “if there is any doubt about whether a particular set of beliefs constitutes a religion, the Court will err on the side of Research freedom and find that the beliefs are a religion. . . . [because the country’s] founders were animated in large part by a desire for religious liberty”), aff’d , 95 F.3d 1475, 1482-83 (10th Cir. 1996); see also Smith , 494 U.S. at 887 (in holding that the Free Exercise Clause did not prohibit application of Oregon drug laws to ceremonial ingestion of peyote, Court noted that “[r]epeatedly and in many different contexts, we have warned that courts must not presume to determine the place of a particular belief in a religion or the write for scholarship letter plausibility of a religious claim”). [27] Meyers, 906 F. Supp. at 1502 (religions address “ultimate ideas,” i.e. Research? , “fundamental questions about life, purpose, and death”; holding that single-faceted worship of marijuana was not a religion for First Amendment purposes), aff’d , 95 F.3d at 1483; accord Africa, 662 F.2d at Writing essays english 1032 (“a religion [protected by the First Amendment] addresses fundamental and ultimate questions having to do with deep and imponderable matters [and] . . . is comprehensive in nature; it consists of a belief-system as opposed to an isolated teaching”); Dettmer v. Landon , 617 F. Supp. 592, 595-96 (E.D. Va.

1985) (under the First Amendment, Wiccans’ belief is religious in nature because, among other things, the belief structure relates to “ultimate” concerns and Research paper payment, reflects a broad concern for Pay for paper, improving the Research quality of life for short essay hardship letter, others), aff’d in relevant part and Research paper payment, rev’d on other grounds , 799 F.2d 929 (4th Cir. 1986); Church of the Chosen People (No. Am. Panarchate) v. United States , 548 F. Supp. 1247 (D. Minn. 1982) (a church whose single-faceted doctrine concerned sexual preference and not ultimate questions was not a religion entitled to tax exemption); Brown v. Pena , 441 F. Supp. 1382, 1385 (S.D.

Fla. 1977) (“religious” belief under Title VII “is based on a theory of ‘man’s nature or his place in the Universe,’ [and is] not merely a personal preference”), aff’d, 589 F.2d 1113 (5th Cir. Essay Hardship Letter? 1979). Although “religion” is often marked by external manifestations such as ceremonies, rituals or clergy, such manifestations are not required for a belief to be “religious.” E.g., Malnak v. Yogi, 592 F.2d 197, 209-10 (3d Cir. Research? 1979). [28] For example, EEOC and courts have found that the Essay internet pdf Ku Klux Klan is not a religion within the meaning of Title VII because its philosophy has a narrow, temporal, and political character. Commission Decision No. 79-06, CCH EEOC Decisions ¶ 6737 (1983); Bellamy v. Mason’s Stores, Inc., 368 F. Supp. 1025, 1026 (E.D.

Va. 1973), aff’d , 508 F.2d 504 (4th Cir. 1974); Slater v. King Soopers , 809 F. Supp. 809, 810 (D. Colo. 1992) (dismissing religious discrimination claim by a member of the Ku Klux Klan who allegedly was fired for participating in Research paper payment, a Hitler rally because the short essay for scholarship letter Ku Klux Klan is “political and social in nature” and is not a religion for Title VII purposes); s ee also Brown v. Pena, 441 F. Supp.

1382 (plaintiff’s belief that eating cat food contributes to his well-being is a personal preference and not a religion). In an analogous case, Peterson v. Wilmur Communications, Inc ., 205 F. Supp. 2d 1014, 1022 (E.D. Wis. Research Payment? 2002), the court held that an employee’s membership in the World Church of the Creator was a “religious” belief, even though the organization’s central tenet is white supremacy, because “it functions as religion in [plaintiff’s] life” as evidenced by the fact that he has been a minister in it for Custom reviews cheap, more than three years, worked to put the church’s teachings into practice, and Research payment, actively proselytizes. However, the Peterson court might have reached a different conclusion had it considered whether the belief was merely one-dimensional and thus not religious, i.e. Consulting? , not part of a moral or ethical belief system concerning “ultimate ideas” about “life, purpose, and death.” [29] Compare Tiano v. Dillard Dep’t Stores, Inc ., 139 F.3d 679 (9th Cir. Research Paper Payment? 1998) (employer not liable for denying employee’s request to writing message, be absent from work on particular dates to attend a religious pilgrimage where the evidence showed that her religious needs could be met by going on the pilgrimage at another time and that the particular dates she requested were simply a personal preference), with Heller v. Paper Payment? EBB Auto Co. , 8 F.3d 1433 (9th Cir. 1993) (employer liable for failing to Pay for anlaysis paper, accommodate Jewish employee’s attendance of spouse’s conversion ceremony); see also Wessling v. Research Payment? Kroger Co. , 554 F. Supp. Literary Anlaysis Use? 548 (E.D.

Mich. 1982) (employer not liable for denial of accommodation where employee requested leave to help children get into their costumes and practice before performance of church play; employee’s own testimony revealed her participation in this instance was more in paper, the nature of a parental and social obligation); Redmond , 574 F.2d at 901 (employer liable for failing to service editing, accommodate employee’s participation in Research paper, Saturday Bible classes; the court found his attendance to be pursuant to a sincerely held religious belief given that he was appointed to be lifetime leader of his church Bible study class many years earlier, time of meeting was scheduled by literary anlaysis use church elders, and paper payment, employee felt that his participation was at dictate of his elders and Help, constituted a “religious obligation”); Weitkenaut v. Goodyear Tire Rubber Co. , 381 F. Supp. 1284, 1288?89 (D. Vt. Research Paper Payment? 1974) (employer liable for failing to protect minister’s attendance at monthly church organizational meetings where it was considered necessary to write short essay hardship letter, preparing for Research, his pastoral duties and thus essential to internet, his ability to lead his congregation). [30] Cf. LaFevers v. Research Payment? Saffle , 936 F.2d 1117 (10th Cir. 1991) (although not all Seventh-day Adventists are vegetarian, an individual adherent’s genuine religious belief in such a dietary practice warrants constitutional protection under the First Amendment). [31] See, e.g., Wessling v. Kroger Co. , 554 F. Supp. 548 (E.D.

Mich. 1982) (court held that plaintiff, who had volunteered to arrive at Essay internet Church early to set up, decorate, and receive children prior to Research payment, their performance of a play during Christmas Mass, was engaging in a social and Pay for, family obligation rather than a religious belief, practice, or observance). [32] See Dettmer v. Landon, 799 F.2d 929, 932 (4th Cir. Payment? 1986) (in First Amendment case, rejecting argument that witchcraft was a “conglomeration” of Help with writing “various aspects of the Research paper payment occult” rather than a religion; religious beliefs need not be “acceptable, logical, consistent or comprehensible to Dissertation editing, others” to be protected); Washington Ethical Soc’y v. District of Columbia , 249 F.2d 127, 128 (D.C. Cir. 1957) (Ethical Society qualifies as a “religious corporation or society” and its building is entitled to tax exemption; belief in Research payment, a Supreme Being or supernatural power is not essential to qualify for tax exemption accorded to “religious corporations,” “churches” or “religious societies”); Fellowship of Humanity v. County of Alameda , 315 P.2d 394 (Cal. App. 1957) (same holding with respect to Secular Humanists). [33] EEOC v. Red Robin Gourmet Burgers, Inc. How To Short For Scholarship Letter? , 2005 WL 2090677 (W.D. Wash.

Aug. 29, 2005) (denying employer’s motion for payment, summary judgment on anlaysis paper use accommodation claim arising from employee’s refusal to cover his Kemetic religious tattoos in Research paper, order to pdf, comply with employer’s dress code). [34] These facts are similar to those in Cloutier v. Costco Wholesale Corp. , 390 F.3d 126 (1st Cir. Paper? 2004). However, the court in Cloutier did not resolve the issue of Help english writing whether or not the plaintiff’s facial piercing, which she alleged was displayed pursuant to payment, her adherence to the beliefs of the Church of Body Modification, was part of Dissertation service a “religious” belief, practice, or observance, instead finding that the paper proposed accommodation of allowing display of the piercing would have posed an undue hardship. [35] Seeger , 380 U.S. at How to short essay hardship letter 185 (“[w]hile the ‘truth’ of a belief is not open to question, there remains the significant question of Research whether it is ‘truly held’”). [36] EEOC v. Union Independiente De La Autoridad De Acueductos, 279 F.3d 49, 56 (1st Cir. 2002) (evidence that Seventh-day Adventist employee had acted in ways inconsistent with the tenets of Pay for literary his religion, for example that he worked five days a week rather than the required six, had lied on an employment application, and took an oath before a notary upon becoming a public employee, can be relevant to the evaluation of sincerity but is not dispositive); Hansard v. Johns-Manville Prods. Corp ., 1973 WL 129 (E.D.

Tex. Feb. 16, 1973) (employee’s contention that he objected to Sunday work for religious reasons was undermined by his very recent history of Sunday work); see also Hussein v. Waldorf-Astoria , 134 F. Supp. 2d 591 (S.D.N.Y. Research Paper? 2001) (employer had a good faith basis to doubt sincerity of Essay internet pdf employee’s professed religious need to wear a beard because he had not worn a beard at any time in Research, his fourteen years of Dissertation service employment, had never mentioned his religious beliefs to anyone at the hotel, and simply showed up for work one night and asked for an on-the-spot exception to the no?beard policy), aff’d , 2002 WL 390437 (2d Cir. Mar. Payment? 13, 2002) (unpublished). [37] EEOC v. Ilona of for ap Hungary, Inc ., 108 F.3d 1569 (7th Cir. 1997) (en banc) (Jewish employee proved her request for leave to observe Yom Kippur was based on a sincerely held religious belief even though she had never in her prior eight-year tenure sought leave from work for a religious observance, and conceded that she generally was not a very religious person; the evidence showed that certain events in her life, including the birth of her son and the death of her father, had strengthened her religious beliefs over the years); Cooper v. Research Payment? Oak Rubber Co ., 15 F.3d 1375 (6th Cir.

1994) (that employee had worked the Friday night shift at plant for approximately seven months after her baptism did not establish that she did not hold sincere religious belief against working on Saturdays, considering that 17 months intervened before employee was next required to work on Saturday, and Help with english, employee’s undisputed testimony was that her faith and commitment to her religion grew during this time); EEOC v. IBP, Inc., 824 F. Supp. 147 (C.D. Ill. 1993) (Seventh-day Adventist employee’s previous absence of faith and subsequent loss of paper faith did not prove that his religious beliefs were insincere at Writing essays for ap english the time that he refused to work on the Sabbath); s ee also Union Independiente, 279 F.3d at Research payment 57 n.8 (the fact that the alleged conflict between plaintiff’s beliefs and union membership kept changing might call into paper question the sincerity of the beliefs or “might simply reflect an evolution in plaintiff’s religious views toward a more steadfast opposition to union membership”). [38] Commission Guidelines , 29 C.F.R. § 1605.1; Anderson v. U.S.F. Logistics (IMC), Inc. , 274 F.3d 470, 475 (7th Cir.

2001) (employee’s belief that she needed to use the phrase “Have a Blessed Day” was a religious practice covered by Title VII even though using the payment phrase was not a requirement of her religion); Rivera v. Choice Courier , 2004 WL 1444852 (S.D.N.Y. Help With English? June 25, 2004) (the statutory language providing that Title VII encompasses “all aspects of religious observance and practice, as well as belief,” means that Title VII “protects more than . . . practices specifically mandated by an employee’s religion”). [39] For the text of 42 U.S.C. § 2000e-2(a), which applies to employers, see supra n.4. Under 42 U.S.C. § 2000e-2(b), it is unlawful for employment agencies to “fail or refuse to refer for employment, or otherwise to discriminate against, any individual because of his . . Paper? . religion . . . or to classify or refer for employment any individual on the basis of his . Essay Writing Internet Pdf? . . Research Payment? religion . . . Write Short Essay For Scholarship Letter? .” Under 42 U.S.C. Paper Payment? § 2000e-2(c), it is Writing, unlawful for unions to “(1) to exclude or expel from membership, or otherwise to discriminate against, any individual because of his . Paper? . . religion . . . ; (2) to writing reviews, limit, segregate or classify its membership or applicants . Research Paper Payment? . . or to refuse to Writing essays for ap, refer for employment any individual . . . because of such individual’s . . . religion . . . ; or (3) to cause or attempt to cause an employer to discriminate . . . in violation of this section.” [40] See, e.g., Union Independiente, 279 F.3d 49; Bushouse , 164 F. Research Payment? Supp. 2d 1066. See infra §§ II, III, and IV; see also § IV-C-5. [41] Goodman v. Lukens Steel Co . 482 U.S.

656, 668-69 (1987) (unions violated “§ 703(c)(1) [of Title VII, which] makes it an unlawful practice for a Union to ‘exclude or to Writing essays for ap, expel from its membership, or otherwise to discriminate against, any individual’” when they “ignored [racial] discrimination claims . . . , knowing that the employer was discriminating in violation of the contract”). See, e.g., Perugini v. Paper? Safeway Stores, 935 F. 2d 1083 (9th Cir. 1991) (remand to determine whether union discriminatorily failed to challenge employer’s refusal to Custom essay, give pregnant worker light duty); Rainey v. Town of Warren , 80 F. Supp. 2d 5, 17 (D.R.I. 2000) (“[i]t is axiomatic that a union’s failure to Research, adequately represent union members in the face of employer discrimination may subject the union to liability under either Title VII or its duty of fair representation”). To the extent it has been held that a union cannot be held liable where it knowingly acquiesces in discrimination, the Pay for anlaysis paper EEOC disagrees.

See EEOC v. Pipefitters Ass’n Local Union 597 , 334 F.3d 656 (7th Cir. Research? 2003). [42] Section 702(a) of Title VII, 42 U.S.C. § 2000e-1(a), provides: This subchapter shall not apply to . . . a religious corporation, association, educational institution, or society with respect to the employment of individuals of a particular religion to perform work connected with the How to write short carrying on by such corporation, association, educational institution, or society of its activities. Section 703(e)(2) of Research Title VII, 42 U.S.C. § 2000e-2(e)(2) provides: it shall not be an unlawful employment practice for a school, college, university, or educational institution or institution of learning to hire and employ employees of a particular religion if such school, college, university, or other educational institution or institution of learning is, in whole or in substantial part, owned, supported, controlled, or managed by a particular religion or by a particular religious corporation, association, or society, or if the curriculum of such school, college, university, or other educational institution or institution of learning is pdf, directed toward the Research propagation of a particular religion.

While Congress did not include a definition of the essays english § 702(a) term “religious corporation” in paper payment, Title VII, at least one judge has argued that the legislative history indicates that Congress intended “the § 703(e)(2) exemption to require a lesser degree of association between an Custom entity and a religious sect than what would be required under § 702(a).” See LeBoon v. Lancaster Jewish Cmty. Research Payment? Ctr. , 503 F.3d 217, 237 (3d Cir. 2007) (Rendell, J., dissenting). Executive Order 13279, Equal Protection of the Laws for Faith-Based and Help with writing, Community Organizations , issued on December 12, 2002, provides that certain faith-based organizations that provide social programs can deliver those services and make hiring decisions on the basis of their religious beliefs even if they receive federal funding. See 67 Fed. Paper Payment? Reg.

77,141 (12/16/02). The Guidance to Faith-Based and essays, Community Organizations on Partnering with the Federal Government , http://www.whitehouse.gov/government/fbci/guidance_document_01-06.pdf (last visited July 2, 2008), issued by the White House Office of Faith Based and Community Initiatives, explains that while religious organizations that receive federal funds to provide social services may choose to paper payment, hire persons of the same religion, they are also subject to federal, state, and local employment and anti-discrimination laws, such as Title VII. [43] Townley , 859 F.2d at 618; accord Hall v. Baptist Mem. Health Care Corp. , 215 F.3d 618, 624-25 (6th Cir. 2000) (college of health sciences qualified as a religious institution under Title VII because it was an affiliated institution of a church-affiliated hospital, had direct relationship with the Baptist church, and the college atmosphere was permeated with religious overtones). [44] Townley, 859 F.2d at 618; see also Killinger v. Samford Univ. Short? , 113 F.3d 196 (11th Cir. 1997) (Baptist university was “religious educational institution” where largest single source of Research paper funding was state Baptist Convention, all university trustees were Baptists, university reported financially to for ap english, Convention and to Baptist State Board of Research Missions, university was member of essay cheap Association of Baptist Colleges and Research, Schools, university charter designated its chief purpose as “the promotion of the Dissertation Christian Religion throughout the world by Research payment maintaining and operating institutions dedicated to the development of Christian character in high scholastic standing,” and for ap, both Internal Revenue Service (IRS) and Department of Education recognized university as religious educational institution).

[45] Townley , 859 F.2d at 619 (manufacturer of mining equipment, whose owners asserted that they made a covenant with God that their business “would be a Christian, faith?operated business,” is not a religious organization because it is for profit; it produces mining equipment, a secular product; it is not affiliated with or supported by a church; and its articles of incorporation do not mention any religious purpose) . Cf. EEOC v. Kamehameha Sch./Bishop Estate , 990 F.2d 458, 461 (9th Cir. 1993) (non-profit school not “religious” for Title VII purposes where ownership and affiliation, purpose, faculty, student body, student activities, and curriculum of the schools are either essentially secular, or neutral as far as religion is concerned). [46] See Corp. of the Presiding Bishop of the Church of Jesus Christ of Latter-Day Saints v. Amos , 483 U.S. 327 (1987) (a nonprofit church-run business does not violate Title VII if it refuses to hire anyone other than members of paper payment its own religion, even for enterprises or jobs that are not religious in nature). [47] Killinger , 113 F.3d at 200 (School of Divinity need not employ professor who did not adhere to the theology advanced by its leadership); Tirpanlis v. Write For Scholarship Hardship Letter? Unification Theological Seminary , 2001 WL 64739 (S.D.N.Y.

Jan. 24, 2001) (seminary operated by payment Unification Church cannot be sued for religious discrimination by Writing english Greek Orthodox employee who was allegedly terminated for refusing to accept the teachings of the Unification Church). [48] Ziv v. Valley Beth Shalom , 156 F.3d 1242 (Table), 1998 WL 482832 (9th Cir. Aug. Paper? 11, 1998) (unpublished) (religious organization can be held liable for Help message, retaliation and national origin discrimination); DeMarco v. Holy Cross High Sch. , 4 F.3d 166 (2d Cir. Paper Payment? 1993) (religious institutions may not engage in age discrimination). [49] EEOC v. Writing Pdf? Fremont Christian Sch. , 781 F.2d 1362 (9th Cir. 1986) (religious school violated Title VII and the Equal Pay Act when it provided “head of household” health insurance benefits only to single persons and married men). [50] McClure v. Research Paper? Salvation Army , 460 F.2d 553, 558-60 (5th Cir. 1972); s ee also Hollins v. Methodist Healthcare, Inc. , 474 F.3d 223 (6th Cir.

2007) (applying ministerial exception to bar claim by resident in hospital’s pastoral care program who alleged disability discrimination); Tomic v. Catholic Diocese of Peoria , 442 F.3d 1036 (7th Cir. 2006) (applying ministerial exception to message, bar age discrimination claim brought by Catholic Diocese music director who was terminated following a dispute with the bishop’s assistant regarding what to play during the Easter Mass); Hankins v. Payment? Lyght , 441 F.3d 96 (2d Cir. 2006) (applying ministerial exception to bar age discrimination claim); Combs v. Central Texas Annual Conf. of United Methodist Church, 173 F.3d 343 (5th Cir. 1999) (barring claim because court could not determine whether an employment decision concerning a minister was based on legitimate or illegitimate grounds without entering the constitutionally impermissible realm of internal church management); EEOC v. Catholic Univ. of America , 83 F.3d 455 (D.C. Cir. 1996) (ministerial exception barred Title VII sex discrimination claim brought by tenured member of with english Catholic University’s department of religious canon law); DeMarco v. Holy Cross High School , 4 F.3d 166 (2d Cir. Research Paper? 1993) (ministerial exception inapplicable to parochial school teacher’s age discrimination claim because employer’s contention that teacher was terminated specifically for Pay for paper, failing to attend Mass and to lead his students in prayers could be evaluated without risk of excessive entanglement between government and religious institution); Guianan v. Roman Catholic Archdiocese of Indianapolis, 42 F. Research Payment? Supp. 2d 849 (S.D.

Ind. Essays? 1998) (ministerial exception inapplicable to parochial school teacher’s age discrimination claim, even though teacher taught at least one class in religion per term, and organized one worship service per month, since vast majority of teacher’s duties involved teaching math, science, and other secular courses). [51] Rayburn v. Gen. Conference of paper Seventh?Day Adventists , 772 F.2d 1164, 1169 (4th Cir. 1985). [52] Rweyemamu v. Cote , 520 F.3d 198 (2d Cir. 2008) (Title VII race discrimination claim by African-American Catholic priest challenging denial of essays promotion and subsequent termination was barred by the ministerial exception); Petruska v. Gannon Univ. , 462 F.3d 294 (3d Cir. Research Paper Payment? 2006) (ministerial exception bars Title VII sex discrimination claim by write for scholarship female Catholic chaplain against school, alleging that she was forced out as chaplain after she advocated on behalf of alleged victims of sexual harassment and spoke out against the school’s president regarding alleged sexual harassment and discrimination against female employees); Werft v. Desert Southwest Annual Conf. of the United Methodist Church , 377 F.3d 1099 (9th Cir. Paper Payment? 2004) (ministerial exception barred minister’s claim against church for failure to paper use, accommodate his disabilities). However, some courts have ruled that the ministerial exception does not bar harassment claims by ministers, but rather only applies to claims involving matters such as hiring, promotion, and termination. See Elvig v. Calvin Presbyterian Church , 375 F.3d 951 (9th Cir.

2004) (ministerial exception does not bar sexual harassment claim by minister), reh’g denied , 397 F.3d 790 (9th Cir. 2005) (two concurring and three dissenting opinions); Bollard v. California Province of the Soc’y of Research paper payment Jesus , 196 F.3d 940 (9th Cir. 1999) (novice’s sexual harassment claim could be maintained without excessive entanglement between church and state because religious order did not offer a religious justification for the alleged harassment, and plaintiff did not seek reinstatement or other equitable relief); Dolquist v. Help With English Writing Message? Heartland Presbytery, 342 F. Supp. 2d 996 (D. Kan. 2004) (First Amendment Establishment and Free Exercise Clauses did not preclude minister from pursuing Title VII sexual harassment claim against her church, because claims did not involve choice of clergy); see also Bryce v. Research Paper? Episcopal Church in the Diocese of Colorado, 289 F.3d 648, 657-59 (10th Cir. Paper? 2002) (although “employment decisions may be subject to Title VII scrutiny, where the decision does not involve the church’s spiritual functions,” minister’s Title VII harassment claim was subject to dismissal because it was based on communications protected by the First Amendment under the “church autonomy” doctrine; the doctrine is broader than the ministerial exception and paper payment, bars civil court review of Dissertation service editing internal church disputes involving matters of Research paper payment doctrine and church governance). [53] Geary v. Visitation of Blessed Virgin Mary Parish Sch. Essay Internet? , 7 F.3d 324 (3d Cir.

1993) (lay teacher at church?operated elementary school not a minister); Dole v. Shenandoah Baptist Church , 899 F.2d 1389 (4th Cir. 1990) (lay teachers of payment private religious schools who “perform no sacerdotal functions [nor] serve as church governors [and] belong to no clearly delineated religious order” are not ministers despite their sincere belief that theirs is Essay writing pdf, a ministry); but see EEOC v. Catholic Univ. of America , 83 F.3d 455 (D.C. Cir. 1996) (ministerial exception barred Title VII sex discrimination claim brought by tenured member of Catholic university’s department of Research payment religious canon law). [54] Alicea?Hernandez v. Dissertation Consulting Editing? Catholic Bishop of Chicago, 320 F.3d 698 (7th Cir.

2003) (ministerial exception applied to Communications Director who was responsible for crafting the Church’s message to the Hispanic community); EEOC v. Roman Catholic Diocese of paper payment Raleigh, 213 F.3d 795 (4th Cir. 2000) (ministerial exception applies to cathedral’s director of essay reviews cheap music ministry and part-time music teacher); Rayburn , 772 F.2d at 1168 (ministerial exception applies to associate pastor who had completed seminary training but was not ordained); Starkman v. Evans , 198 F.3d 173 (5th Cir. 1999) (ministerial exception barred Americans with Disabilities Act claim by church choir director). [55] EEOC v. Research Paper? Southwestern Baptist Theological Seminary , 651 F.2d 277, 283 (5th Cir. 1981) (“[w]hile religious organizations may designate persons as ministers for their religious purposes free from any governmental interference, bestowal of such a designation does not control their extra?religious legal status”). [56] Abramson v. William Paterson Coll. of N.J. , 260 F.3d 265, 281 (3d Cir. 2001) (prima facie case and evidentiary burdens of an employee alleging religious discrimination mirror those of an employee alleging race or sex discrimination).

A disparate impact analysis could also apply in the religion context, particularly in the area of recruitment and hiring. See, e.g., Barrow v. Greenville Indep. Sch. Dist. Literary Anlaysis Paper Use? , 480 F.3d 377 (5th Cir. Paper? 2007) (affirming summary judgment, citing lack of statistical evidence, for Writing english, employer on Research Title VII claim brought by teacher who asserted policy favoring teachers whose children attended the public schools had a disparate impact on those whose children attended private school for religious rather than secular reasons). However, because the reasonable accommodation/undue hardship analysis usually applies when a neutral work rule adversely affects religious practices, s ee infra § IV, disparate impact analysis is seldom if ever used in essay writing reviews, religion cases. [57] 42 U.S.C. § 2000e-2(e)(1); see also §§ I-C and II-D of this document. [58] See, e.g., EEOC v. Preferred Mgmt .Corp., 216 F. Supp. 2d 763, 813 (S.D. Ind. 2002) (telling applicant that “[y]ou damned humanists are ruining the world” and will “burn in hell forever” raises reasonable inference that the failure to hire her was unlawfully based on religion).

[60] In Noyes v. Kelly Servs. Inc ., 488 F.3d 1163 (9th Cir. 2007), the plaintiff alleged “reverse religious discrimination” when she was not promoted because she did not follow the religious beliefs of her supervisor and management, who were members of a small religious group and favored and payment, promoted other members of the religious group. The court ruled that while the Custom essay writing cheap employee did not adhere to a particular religion, the fact that she did not share the employer’s religious beliefs was the basis for the alleged discrimination against her, and the evidence was sufficient to paper, create an issue for trial on whether the employer’s decision to english message, promote another employee was a pretext for religious discrimination. [61] Tincher v. Wal-Mart Stores , 118 F.3d 1125, 1131 (7th Cir. 1997) (reasonable jury could conclude that employer’s articulated reason for the discharge of paper a Seventh-day Adventist was pretextual and that the real reason was religious discrimination because of the inconvenience caused by employee’s inability to work on consulting editing Saturdays); s ee also Campos v. City of Blue Springs, 289 F.3d 546 (8th Cir. Paper? 2002) (evidence supported religiously motivated constructive discharge based on plaintiff’s Native American spiritual beliefs); EEOC v. University of Chicago Hospitals , 276 F.3d 326 (7th Cir. 2002) (evidence sufficient to consulting, proceed to Research, trial in case brought on behalf of recruiter alleging constructive discharge based on her evangelical religious beliefs); Dachman v. Shalala , 2001 WL 533760 (4th Cir.

May 18, 2001) (unpublished) (Orthodox Jewish employee who was treated in the same manner as non-Jewish employees with similar performance and disciplinary records failed to show that she was terminated because of Custom reviews cheap her religion); Altman v. Minn. Dep’t of Corr. , 251 F.3d 1199, 1203 (8th Cir. Payment? 2001) (in case raising both Title VII and First Amendment claims, holding that employer may not discipline employees for Dissertation editing, religiously based conduct because it is religious in nature if it permits such conduct by other employees when not motivated by religious beliefs). However, not all employer decisions affect a term, condition, or privilege of employment as required to be actionable as disparate treatment. See, e.g. Research? , Goldmeier v. Allstate Ins. Co. English? , 337 F.3d 629 (6th Cir.

2003) (resignation 53 days prior to effective date of employer’s policy that would have posed conflict with employees’ religious beliefs did not constitute constructive discharge); Shabat v. Research? Blue Cross Blue Shield , 925 F. Supp. 977 (W.D.N.Y. 1996) (plaintiff’s contention that he received a promotion only by write hardship pressuring management did not allege an “adverse” employment action). [62] See infra § IV, Reasonable Accommodation. [63] 42 U.S.C. Research Paper? § 2000e-2(a)(1) (discriminating in hiring, discharge, or otherwise with respect to compensation, terms, conditions, or privileges of employment); see also 42 U.S.C. § 2000e-2(a)(2) (discriminating by limiting, segregating, or classifying employees or applicants in a way which would deprive or tend to Dissertation consulting editing, deprive employment opportunities or otherwise adversely affect employment status); cf. Ansonia Bd. of Educ. Research? v. Help Writing Message? Philbrook , 479 U.S. 60, 71 (1986) (a benefit “that is part and parcel of the employment relationship may not be doled out in a discriminatory fashion, even if the employer would be free . . Research Paper? . not to provide the benefit at How to write short hardship all”) (quoting Hishon v. King Spalding , 467 U.S. 69, 75 (1984)). However, at least one court has held that a private employer providing company resources to recognized employee “affinity groups” does not violate Title VII by denying this privilege to any group promoting or advocating any religious or political position, where the company excluded not only paper groups advocating a particular religious position but also those espousing religious indifference or opposition.

See Moranski v. General Motors Corp. Anlaysis Use? , 433 F.3d 537 (7th Cir. 2005). [64] Delelegne v. Kinney Sys., Inc., 2004 WL 1281071 (D. Mass. June 10, 2004) (Ethiopian Christian parking garage cashier could proceed to trial on Research payment claims of religious harassment and discriminatory termination where he was not allowed to bring a Bible to Help with english writing message, work, pray, or display religious pictures in his booth, while Somali Muslim employees were permitted to take prayer breaks and to display religious materials in their booths). [65] This fact pattern may also give rise to a denial of paper accommodation claim. See infra § IV-C-6.

[66] Determining whether religious expression disrupts co-workers or customers is How to essay for scholarship letter, discussed in Research paper payment, §§ III-C and IV-C-6, infra . Additionally, in a government workplace, the anlaysis paper First Amendment Free Exercise Clause and Establishment Clause may affect the employer’s or employee’s ability to restrict or engage in religious expression. Paper Payment? See supra nn.11-15 infra nn.201-203 ; see also Federal Workplace Guidelines , supra n.11, at writing cheap sections 2-B and 2-E, noting implications of the Religious Freedom Restoration Act (RFRA) for neutral rules that burden religion in the federal workplace. [67] 42 U.S.C. Research Payment? § 2000e-2(g) (permitting covered entities to reviews cheap, discharge or refuse to “hire and employ” or refer an Research payment individual who does not meet federal security requirements). However, the Commission is aware of with message no statute or order that requires or permits distinctions based on religion. See infra § IV-B-5 (discussion of security requirements and Research paper, Title VII’s accommodation obligation). [69] Compare Abrams v. Baylor Coll. of Med. , 805 F.2d 528 (5th Cir. 1986) (being non-Jewish was not a BFOQ for Pay for anlaysis paper, a university which had a contract to supply physicians on Research rotation at a Saudi Arabian hospital when the hospital presented no evidence to support its contention that Saudi Arabia would actually have refused an Help writing message entry visa to a Jewish faculty member), and Rasul v. District of Columbia , 680 F. Payment? Supp.

436 (D.D.C. 1988) (Department of Corrections failed to Pay for literary use, demonstrate that Protestant religious affiliation was a BFOQ for position as prison chaplain because chaplains were recruited and paper, hired on a facility-wide basis and were entrusted with the job of Dissertation consulting service planning, directing, and maintaining a total religious program for all inmates, whatever their respective denominations), with Kern v. Dynalectron Corp ., 577 F. Supp. 1196 (N.D. Tex. 1983) (requirement that pilot convert to Islam was a BFOQ which warranted employer’s refusal to hire him, inasmuch as requirement was not based on a preference of contractor performing work in Saudi Arabia, but on the fact that non?Muslim employees caught flying into Mecca would, under Saudi Arabian law, be beheaded), aff’d , 746 F.2d 810 (5th Cir. Paper Payment? 1984), and Pime v. Loyola Univ. of Chicago , 803 F.2d 351 (7th Cir. 1986) (although university was not a religious organization under Title VII, the court held that having some Jesuit presence in philosophy department was a BFOQ since university was founded by Jesuits, continues to Dissertation service, have Jesuit tradition, and requires all of its undergraduates to take philosophy).

[70] Faragher v. Paper Payment? Boca Raton , 524 U.S. 775, 788 (1998) (harassment claims are actionable on short letter any of Title VII’s protected bases); Meritor Sav. Bank, FSB v. Vinson , 477 U.S. 57, 66 (1986) (the same Title VII harassment principle applies whether the harassment is based on race, national origin, religion, or sex); see also Abramson, 260 F.3d at 276; Hafford v. Seidner , 183 F.3d 506, 512 (6th Cir. 1999); Tillery v. ATSI, Inc. , 242 F. Research Paper Payment? Supp. 2d 1051, 1063 (N.D. Ala. 2003), aff’d , 97 Fed.

Appx. 906 (11th Cir. Consulting? 2004) (Table). [71] See Venters v. Paper Payment? City of Delphi , 123 F.3d 956 (7th Cir. 1997) (employee who was terminated after she disagreed with supervisor’s religious beliefs raised a triable Title VII harassment claim based on two separate theories of harassment liability: that a “tangible employment benefit” was conditioned upon acquiescing to her supervisor’s religious beliefs, and also that a hostile work environment was created). [72] Meritor Sav. Bank, 477 U.S. at writing 66 (1986) (prohibition on discrimination “in the paper payment terms, conditions, or privileges of employment” requires employers to maintain a workplace free from harassment based upon essays english protected status).

[73] See, e.g., Venters , 123 F.3d at 964 (employee established that she was discharged on paper the basis of her religion after supervisor, among other things, repeatedly called her “evil” and stated that she had to share his Christian beliefs in How to write essay for scholarship hardship, order to Research paper payment, be a good employee). [74] Many of the example’s facts are taken from Sattar v. Dissertation Service Editing? Motorola, Inc ., 138 F.3d 1164 (7th Cir. 1998). However, in Sattar the plaintiff did not prevail because the paper payment plaintiff failed to prove that his discharge was linked to the harassment by his former supervisor. [75] Pederson v. Casey’s Gen. Stores, Inc. , 978 F. Supp.

926 (D. Neb. 1997) (employer’s refusal to accommodate employee’s need to have Easter day off, while knowing that she could not compromise her religious needs and where it would not have posed an undue hardship, amounted to constructive discharge in violation of Title VII). [76] Venters , 123 F.3d at 972 (“the accommodation framework . . . Pay For Use? has no application when the Research paper payment employee alleges that he was fired because he did not share or follow his employer’s religious beliefs”). [77] Faragher , 524 U.S. at 788 (environmental harassment claims are actionable on any of Title VII’s protected bases); Meritor Sav. Bank, 477 U.S. at Custom cheap 67 (same); see also EEOC Enforcement Guidance: Vicarious Employer Liability for Unlawful Harassment by Supervisors (1999), available at https://www.eeoc.gov/policy/docs/harassment.html. [78] Harris v. Forklift Sys., Inc. , 510 U.S. 17, 21 (1993). [79] Meritor Sav. Bank, 477 U.S. at 67. [80] Marcus v. West , 2002 WL 1263999, *11 (N.D.

Ill. June 3, 2002) (mistreatment of Sanctified Pentecostal Christian employee was not because of payment religion; supervisor mistreated all of her employees and had poor management and interpersonal skills). [81] Turner v. Custom Essay Writing Cheap? Barr , 811 F. Supp. 1, 2 (D.D.C. 1993) (hostile environment created where Jewish employee was subjected to a “joke” about the Research paper payment Holocaust, denied opportunity to Essay internet, work overtime, and Research payment, ridiculed as a “turnkey”; although the short essay for scholarship hardship latter two incidents did not refer to religion, the facts showed that he was singled out for Research payment, such treatment because of his religion). [82] See EEOC v. Sunbelt Rentals, Inc. , 521 F.3d 306 (4th Cir. Short Essay For Scholarship Hardship? 2008) (reversing summary judgment for the employer and remanding the case for trial, the court ruled that a reasonable fact finder could conclude that a Muslim employee who wore a kufi as part of his religious observance was subjected to Research, hostile work environment religious harassment when fellow employees repeatedly called him “Taliban” and “towel head,” made fun of his appearance, questioned his allegiance to the United States, suggested he was a terrorist, and made comments associating all Muslims with senseless violence); EEOC v. WCM Enter., Inc. Dissertation Consulting? , 496 F.3d 393 (5th Cir. Research? 2007) (reversing summary judgment for the employer and Pay for paper use, remanding the case for trial, the court ruled that a reasonable fact finder could conclude that harassment initiated after September 11, 2001, against a car salesman who was born in India and is a practicing Muslim was severe or pervasive and motivated by his national origin and religion). In Sunbelt , the Fourth Circuit Court of Appeals held: “we cannot regard as ‘merely offensive,’ and thus ‘beyond Title VII's purview,’ Harris , 510 U.S. at 21, constant and repetitive abuse founded upon misperceptions that all Muslims possess hostile designs against Research paper the United States, that all Muslims support jihad, that all Muslims were sympathetic to english, the 9/11 attack, and Research, that all Muslims are proponents of essays radical Islam.” 521 F.3d at 318. [83] See Abramson, 260 F.3d at Research payment 279 (supervisor’s criticism of professor’s refusal to internet pdf, work on her Sabbath, scheduling meetings on Jewish holidays, and payment, charging her for leave on those holidays could be found to have “infected [professor’s] work experience” because of her religion). [84] Henson v. Literary Paper? City of Dundee , 682 F.2d 897, 903 (11th Cir.

1982). [86] See WCM Enter. , 496 F.3d at 400-01 (plaintiff’s religious and national origin harassment claim was based on having been referred to paper, as a “Muslim extremist,” and constantly called “Taliban” among other terms); Khan v. United Recovery Sys., Inc., 2005 WL 469603 (S.D. Tex. 2005) (plaintiff’s religious harassment claim was based on alleged comments by anlaysis co-worker that court characterized as “malicious and vitriolic,” including that all Muslims are terrorists who should be killed, that he wished “all these Muslims were wiped off the Research paper face of the earth,” that plaintiff might get shot for Help with english, wearing an “Allah” pendant, and Research paper payment, questioning plaintiff about what was being taught at Custom essay writing reviews cheap her mosque and whether it was “connected with terrorists”; in addition, plaintiff alleged that her supervisor placed newspaper articles on her desk about mosques in Afghanistan that taught terrorism, along with a note telling her to paper, come into his office and justify such activity). [87] Human resources professionals who responded to a survey by Essay internet the Society for Human Resource Management (SHRM) and the Tanenbaum Center for Interreligious Understanding reported that 19% of the Research paper payment employees in their organizations engaged in proselytizing to writing internet, co-workers. While 32% of the employees perceived increased cooperation and communication within their organizations due to paper payment, acceptance of Pay for anlaysis religious diversity, 9% of the employees felt harassed by co-workers who expressed their religious beliefs.

Religion in the Workplace Survey, at 24 (Society for Human Resource Management, 2001) (executive summary and information on obtaining report available at http://www.tanenbaum.org/research.html (last visited July 2, 2008)). [88] Venters , 123 F.3d at 976 (because the employee made clear her objection to the comments by Research paper payment telling her supervisor he had “crossed the line,” she established that the comments were unwelcome). [89] Id. (“whatever questions there might have been as to whether Venters welcomed these discussions were answered as of th[e] date [that she told him he had crossed the line]”). [90] Harris , 510 U.S. at 21-22; Faragher , 524 U.S. at 788 (“We have made it clear that conduct must be extreme to pdf, amount to a change in the terms and Research paper, conditions of employment.”). [91] Faragher , 524 U.S. at 787-88; Oncale v. Consulting Service? Sundowner Offshore Servs. , 523 U.S. 75, 82-83 (1998) (“[t]he real social impact of Research payment workplace behavior often depends on with writing a constellation of surrounding circumstances, expectations, and paper payment, relationships which are not fully captured by a simple recitation of the writing internet words used or the Research physical acts performed”); Harris , 510 U.S. at Writing essays for ap 23.

[92] Bains LLC v. Arco Prods. Co ., 405 F.3d 74 (9th Cir. 2005) (upholding finding of liability for harassment in violation of 42 U.S.C. § 1981 where Sikh employees were regularly called “rag-heads” and “towel-heads,” and were asked to clean up fuel spills with their turbans). [93] Williams v. Gen. Motors Corp ., 187 F.3d 553, 564 (6th Cir. 1999) (“a work environment viewed as a whole may satisfy the legal definition of an abusive work environment, for paper payment, purposes of a hostile environment claim, even though no single episode crosses the Title VII threshold”). [94] Jones v. United Space Alliance , 2006 WL 250761 (11th Cir. Feb. Essay Reviews? 3, 2006) (unpublished) (plaintiff, a member of the Apostolic/Pentecostal faith, alleged that he was subjected to a hostile work environment based on religion when his manager made derogatory remarks to him based on his religion, a co-worker removed from the community bulletin board a flyer describing events at the plaintiff’s church, the plaintiff’s manager told him to remove the lanyard for his identification badge because it had “Jesus” on it, his manager told him not to leave his Bible on his desk, he was asked to turn down the religious music that he played at work, and he was accused of Research payment having a conflict of interest with the space program because he was a pastor; in finding there was insufficient evidence of a hostile work environment, court ruled that the alleged incidents were not objectively severe or pervasive because none occurred on a repeated basis, none were physically threatening or humiliating, and none interfered with the plaintiff’s job performance).

[95] EEOC v. Custom Essay Cheap? AKZ Mgmt., Inc. , Civil Action No. Paper? 07-8356 (S.D.N.Y. consent decree filed Sept. 26, 2007) (settlement of religious harassment and disparate treatment claims on behalf of employees who were pressured by management to with message, practice or conform to Scientology). See Johnson v. Spencer Press of payment Maine, Inc ., 364 F.3d 368 (1st Cir. 2004) (jury properly found harassment was severe and pervasive where supervisor repeatedly insulted plaintiff and mocked his religious beliefs, and threatened him with violence); Sattar , 138 F.3d at 1167 (employee harassed with a barrage of writing internet pdf e-mails with dire warnings of the Research paper divine punishments that awaited those who refuse to reviews, follow Islam) ; Preferred Mgmt. Corp ., 216 F. Supp. 2d 763 (Christian employer violated Title VII by requiring employees to Research payment, conform to her views). [96] Harris , 510 U.S. at 21; Meritor , 477 U.S. at Writing for ap english 64.

[97] Harris , 510 U.S. at 22 (“even without regard to these tangible effects, the very fact that the discriminatory conduct was so severe or pervasive that it created a work environment abusive to employees because of their race, gender, religion, or national origin offends Title VII’s broad rule of workplace equality . . Research? . . With English? Certainly Title VII bars conduct that would seriously affect a reasonable person’s psychological well?being, but the statute is not limited to such conduct”); s ee Dey v. Colt Const. Dev. Co ., 28 F.3d 1446, 1454-55 (7th Cir. 1994) (“The mention in Harris of an unreasonable interference with work performance was not intended to penalize the employee who possesses the dedication and Research, fortitude to complete her assigned tasks even in Help, the face of Research paper payment offensive and abusive [conduct] . . . . As Justice Scalia separately explained in Harris , the test under Title VII ‘is not whether work has been impaired, but whether working conditions have been discriminatorily altered.’”) (citation omitted). [98] See Harris , 510 U.S. at 23 (“whether an environment is ‘hostile’ or ‘abusive’ can be determined only by looking at all the circumstances . . Consulting Service Editing? . ; no single factor is required”). [99] Faragher , 524 U.S. at 788 (citing Oncale , 523 U.S. at 80); Sheikh v. Indep.

Sch. Dist. 535 , 2001 WL 1636504 (D. Minn. Research Paper? Oct. 18, 2001) (a Muslim employee who was ostracized by colleagues because he refused to shake hands with female colleagues did not suffer a materially adverse change in the terms and Help with writing message, conditions of employment). [100] See Marcus , 2002 WL 1263999 at *11 (asking very religious employee to swear on a Bible to Research, resolve differences with a colleague and telling her that people did not like her “church lady act” are isolated incidents that were not severe or pervasive enough to Help with english message, create a hostile work environment); Sublett v. Edgewood Universal Cabling Sys., Inc. , 194 F. Supp. 2d 692, 703 (S.D. Ohio 2002) (supervisor’s single comment to payment, Rastafarian employee that “those dread things” made him look too “radical” was not sufficiently severe to create a hostile environment). [101] Cf.

Tessler v. KHOW Radio, Inc. , 1997 WL 458489 at *8 (D. Colo. Apr. 21, 1997). [102] Cf. Brown v. Polk County , 61 F.3d at 656-57 (it did not pose an undue hardship for employer to accommodate supervisor’s sporadic and voluntary prayers during workplace meetings). [103] Williams , 187 F.3d at 563 (in determining whether the consulting alleged conduct rises to the level of severe or pervasive, a court should consider the factual “totality of the circumstances”; using a “holistic perspective is necessary, keeping in mind that each successive episode has its predecessors, that the impact of the separate incidents may accumulate, and Research payment, that the work environment created thereby may exceed the pdf sum of the individual episodes”). [104] Cf . Johnson v. Spencer Press of Maine, Inc. , 364 F.3d 368 (1st Cir.

2004) (affirming jury verdict for plaintiff on religious harassment claim, court noted that plaintiff testified supervisor who made ongoing derogatory remarks about Research paper plaintiff’s religion also once put the point of a knife under plaintiff’s chin, in addition to threatening to kill him with a hand grenade, run him over with english writing message, with a car, and shoot him with a bow and arrow). [105] As with any harassment claim, employer liability will depend on whether the Research paper employee can show, in a case of co-worker harassment, that the employer knew or should have known of the misconduct and Writing essays for ap, failed to take prompt and appropriate corrective action. Additionally, in the case of harassment by non-employees, employer liability will depend on whether the employer had control over such individuals’ misconduct. Research Paper? For standards regarding liability for harassment by supervisors, see EEOC Enforcement Guidance: Vicarious Employer Liability for Unlawful Harassment by Supervisors (1999), available at https://www.eeoc.gov/policy/docs/harassment.html. [106] See Peters v. Renaissance Hotel Operating Co. Dissertation Service? , 307 F.3d 535 (7th Cir. 2002) (the impact of actions not directed at Research paper payment a complaining employee is not as great as the impact of harassment directed at him and the combined impact of anlaysis paper all the comments was not severe or pervasive enough to create an unlawful hostile environment). [107] Burlington Indus., Inc. v. Ellerth , 524 U.S. 742, 762 (1998); Faragher , 524 U.S. at paper 788; Preferred Mgmt. Help Writing? Corp. , 216 F. Payment? Supp. 2d at 839 n.25 (employer’s anti-harassment policy was inadequate because it did not include a prohibition on religious harassment, employer did not provide training on religious harassment, and managers responded to complaints of religious harassment by requiring employees to message, participate in a training program based on religious principles). Payment? However, under agency principles an Pay for literary paper employer is automatically liable for payment, hostile work environment harassment even if it does not result in write essay for scholarship hardship, a tangible employment action if “the agent’s high rank in the company makes him or her the employer’s alter ego.” Ellerth , 524 U.S. at payment 758.

If the harasser is of a sufficiently high rank to fall “within that class of an employer organization’s officials who may be treated as the Dissertation consulting service organization’s proxy,” which would include officials such as a company president, owner, partner, or corporate officer, the harassment is automatically imputed to the employer and no affirmative defense can be raised. Faragher , 524 U.S. at 789 see also EEOC Enforcement Guidance: Vicarious Employer Liability for Unlawful Harassment by Supervisors (1999), https://www.eeoc.gov/policy/docs/harassment.html. [108] Sheikh , 2001 WL 1636504 at *5 (employer not liable because it took steps to stop alleged harassment of Muslim employee by his co-workers); see Guidelines on Discrimination Because of National Origin , 29 C.F.R. § 1606.8(d) (employer liable for co-worker harassment about which it knew or should have known and failed to Research payment, act). [109] Cf. Powell v. Yellow Book USA, Inc. , 445 F.3d 1074 (8th Cir. How To Write Essay? 2006) (employer not liable for religious harassment of plaintiff because upon learning of her complaints about paper payment a co-worker’s proselytizing, the employer promptly held a meeting and told the co-worker to stop discussing religion matters with plaintiff, and Custom writing reviews cheap, there was evidence that the company continued to payment, monitor the situation to ensure that the co-worker did not resume her proselytizing). [110] 29 C.F.R. § 1606.8(e). Berry v. Delta Airlines, Inc. , 260 F.3d 803 (7th Cir.

2001) (employer not liable for alleged sexual harassment of its female employee by a male contractor because it promptly investigated the allegations, requested a change in the contractor’s shift so that he would not have contact with the employee, and asked that all contractors be required to view sexual harassment training video). [111] When asked whether they had discussed religion in the workplace in the past twenty-four hours, 48% of Americans answered yes. See George Gallup, Jr. Timothy Jones, The Next American Spirituality: Finding God in Essay internet pdf, the Twenty-First Century , at 72 (Cook Communication Ministries 2000). [112] Employers are permitted to exercise their religion to the extent that such exercise does not infringe on paper their employees’ religious beliefs. Townley , 859 F.2d at 621 (“Where the Pay for literary anlaysis paper religious practices of employers . . . and employees conflict, Title VII does not, and payment, could not, require individual employers to abandon their religion. Rather, Title VII attempts to Writing for ap, reach a mutual accommodation of the paper conflicting religious practices.”). [113] In a survey conducted by the Tanenbaum Center for Interreligious Understanding, 66% of Pay for literary anlaysis paper use employees surveyed reported that they had witnessed religious discrimination in the workplace. Religious Bias in paper, the Workplace: The Employee’s View (Tanenbaum Center for Interreligious Understanding, 1999) (executive summary available at Dissertation consulting http://www.tanenbaum.org/research_1999.html ) (last visited July 2, 2008).

[114] See Examples 15, 18-19, 27-28, 49-50. For a further discussion of the Research payment circumstances under which reasonable accommodation of religious expression in the workplace, including proselytizing, may be denied because it poses an undue hardship on the conduct of the employer’s business, see infra § IV-C-6. [115] Cf. Bodett v. CoxCom, Inc. , 366 F.3d 736 (9th Cir. 2004) (employer prevailed on claim brought by terminated employee for disparate treatment based on religion; employee’s violation of employer’s anti-harassment policy was a legitimate nondiscriminatory reason for termination, even if the violations were motivated by the employee’s religious beliefs). [116] 42 U.S.C. § 2000e(j); Commission Guidelines , 29 C.F.R. § 1605.2(b). [117] Compare Trans World Airlines, Inc. Custom Essay Writing Cheap? v. Hardison, 432 U.S. 63, 84 (1977) (interpreting Title VII “undue hardship” standard, with 42 U.S.C. § 12111(10)(A) (defining ADA “undue hardship” standard); see infra n.139. [118] Protos v. Volkswagen of paper payment Am., Inc., 797 F.2d 129, 136 (3d Cir.

1986) (“[t]his is . . . part of our ‘happy tradition’ of avoiding unnecessary clashes with the Dissertation consulting service dictates of Research payment conscience”) (citation omitted). [119] See Seshadri v. Kasraian , 130 F.3d 798, 800 (7th Cir. 1997) (employee who seeks accommodation need not belong to an established church but cannot preclude inquiry into How to write for scholarship whether he has a religion); Chrysler Corp. v. Mann , 561 F.2d 1282, 1285 (8th Cir. 1977) (observing that the plaintiff “did little to acquaint Chrysler with his religion and its potential impact upon his ability to perform his job”); s ee also Redmond , 574 F.2d at Research paper payment 902 (relying on Mann , concluding that “an employee who is disinterested in informing his employer of english writing his religious needs ‘may forego the right to have his beliefs accommodated by Research payment his employer’”). [120] See Heller , 8 F.3d at 1439 (employee’s request for How to write essay for scholarship hardship letter, leave to participate in religious conversion ceremony of his wife and children was sufficient to place employer on notice that this was pursuant to a religious practice or belief; an employer need have “only enough information about an employee's religious needs to permit the employer to Research payment, understand the existence of a conflict between the employee's religious practices and the employer's job requirements”); Brown v. Polk County , 61 F.3d at 654 (even though employee did not explicitly ask for a religious accommodation, court held employer was on notice of the need for accommodation given that it reprimanded employee for engaging in essays for ap english, known religious activities); Hellinger v. Eckerd Corp., 67 F. Supp. 2d 1359 (S.D. Fla. 1999) (although applicant did not himself inform employer about his religious conflict on his job application, employer had learned when he contacted applicant’s former supervisor for a reference that the Research paper payment applicant had refused to sell condoms at prior job due to a religious objection, and was therefore on notice); cf. Wessling , 554 F. Supp. at 552 (employee’s request to leave work early in order to arrive early for a Christmas play at her church in order to decorate and receive children was insufficient to place her employer on notice of a religious practice; it was more in the nature of a social activity or family obligation that happened to be associated with the church). [121] Cary v. Carmichael, 908 F. Supp.

1334 (E.D. Va. 1995), aff’d , 116 F.3d 472 (4th Cir. 1997); see also Elmenayer v. ABF Freight Sys. , 2001 WL 1152815 (E.D.N.Y. Essay Writing Pdf? Sept. Research Paper? 20, 2001) (employer not liable for disciplining employee for tardiness where employee failed until after his discharge to writing, explain that tardiness was because he attended a prayer service), aff’d on payment other grounds , 318 F.3d 130 (2d Cir. 2003). [122] Notwithstanding the different legal standards for Custom essay reviews, determining when a failure to accommodate poses an undue hardship under Title VII and the ADA, see supra n.117, courts have endorsed a cooperative information-sharing process between employer and employee, similar to Research payment, the “interactive process” used for Pay for anlaysis use, disability accommodation requests under the ADA. See, e.g., Thomas v. Nat’l Ass’n of Letter Carriers , 225 F.3d 1149, 1155 n.5 (10th Cir. 2000) (“the [ADA] ‘interactive process’ rationale is equally applicable to the obligation to offer a reasonable accommodation to paper payment, an individual whose religious beliefs conflict with an employment requirement”); Elmenayer , 2001 WL 1152815, at *5 (same), aff’d on essay writing other grounds , 318 F.3d 130 ; Kenner v. Domtar Indus., Inc ., 2006 WL 662466 (W.D.

Ark. Mar. Research Paper Payment? 13, 2006) (“Title VII’s reasonable accommodation provisions contemplate an interactive process, with cooperation between the employer and the employee, but which must be initiated by the employer”); Cosme v. Henderson , 2000 WL 1682755, *6 (S.D.N.Y. Nov. 9, 2000) (“[t]he process of finding a reasonable [religious] accommodation is intended to be an interactive process in Custom writing, which both the employer and employee participate”), aff’d , 287 F.3d 152 (3d Cir. 2002); cf. Ansonia Bd. of Educ. , 479 U.S. at 69 (“courts have noted that ‘bilateral cooperation is appropriate in the search for payment, an acceptable reconciliation of the needs of the employee’s religion and with english, the exigencies of the employer’s business’”) (quoting Brener v. Diagnostic Ctr. Hosp. Research Paper Payment? , 671 F.2d 141, 145-46 (5th Cir. Short Essay For Scholarship Hardship Letter? 1982)). [123] EEOC v. Arlington Transit Mix, Inc ., 957 F.2d 219, 222 (6th Cir.

1991) (“[a]fter failing to pursue [a voluntary waiver of Research paper seniority rights] or any other reasonable accommodation, the company is in no position to argue that it was unable to Writing essays for ap english, accommodate reasonably [plaintiff’s] religious needs without undue hardship on the conduct of its business”); EEOC v. Ithaca Indus., Inc. , 849 F.2d 116 (4th Cir. 1988) (employer’s failure to attempt to accommodate violated Title VII). [124] Shelton v. Univ. of Research paper Med. Dentistry of Dissertation N.J. Research Paper? , 223 F.3d 220, 227 (3d Cir. 2000) (by refusing to Custom cheap, meet with employer’s human resources department, employee failed to satisfy her duty to cooperate in finding a reasonable accommodation). [125] Ansonia Bd. of Educ. , 479 U.S. at 69 (employer could satisfy its obligation by offering an Research payment alternative reasonable accommodation to consulting service editing, the particular one proposed by the employee); Brener , 671 F.2d at paper 146 (“employee has a correlative duty to make a good faith attempt to satisfy his needs through means offered by the employer”); EEOC v. AutoNation USA Corp ., 2002 WL 31650749 (9th Cir.

Nov. 22, 2002) (unpublished) (employer satisfied its initial burden by showing that it suggested possible accommodations but that the employee short-circuited the process by resigning without first giving the proposed accommodations the opportunity to be implemented or tested); Chrysler Corp. Help With Message? v. Mann , 561 F.2d 1282, 1286 (8th Cir. Research Paper Payment? 1977) (where employee “will not attempt to accommodate his own beliefs through the essays for ap english means already available to paper payment, him or cooperate with his employer in essays for ap english, its conciliatory efforts, he may forego the right to have his beliefs accommodated”), cert. denied , 434 U.S. 1039 (1978). [126] See also Bushouse , 164 F. Supp. 2d 1066. [127] Id. at paper payment 1078 n.18 (court held that union’s refusal to provide accommodation unless employee produced independent corroboration that his accommodation request was motivated by a sincerely held religious belief did not violate Title VII’s religious accommodation provision, but cautioned that the holding was limited to “the facts and circumstances of the present case” and that “the inquiry [into sincerity] and scope of that inquiry will necessarily vary based upon the individual requesting corroboration and the facts and circumstances of the request”).

[128] EEOC v. Tyson Foods, Inc ., Civil Action No. 99-5126 (W.D. For Ap? Ark. consent decree entered Aug. 14, 2000) (settlement of Title VII challenge to employer’s policy of requiring a letter from a church in support of all accommodation requests). [129] See EEOC v. Ilona of Hungary, Inc. , 108 F.3d 1569 (7th Cir. 1997) (employer did not satisfy reasonable accommodation requirement by offering to paper, let Jewish employees take off a day other than Yom Kippur, because that would not eliminate the conflict between religion and writing, work); Shelton , 223 F.3d at 225 (citing Ansonia Bd. of Educ ., 479 U.S. at 68-69) (employer’s accommodation of granting unpaid leave for religious observance instead of allowing use of paid personal days provided for in collective bargaining agreement (CBA), was a reasonable accommodation as long as use of the paid days was not allowed for all purposes other than religious ones); cf. Research? Bruff v. Essays English? N. Mississippi Health Serv., Inc., 244 F.3d 495 (5th Cir.

2001) (hospital offered reasonable accommodation as a matter of law where it offered plaintiff who could not be accommodated in her current position thirty days and the assistance of Research paper payment its in-house employment counselor to find another position where the conflict between the duties and Writing essays for ap, religious beliefs could be eliminated or reduced); EEOC v. Universal Mfg. Corp ., 914 F.2d 71 (5th Cir. 1990) (employer’s offer of five working days off or alternatively seven days off if employee worked one shift within that seven days, did not satisfy obligation to offer reasonable accommodation of her religious practice of refraining from work during seven-day religious festival, where employer did not show undue hardship). [130] See infra nn.131-133. Under the Commission’s approach, a reasonable accommodation must eliminate the conflict between work and Research paper payment, religion unless such accommodation would impose an undue hardship, i.e. , more than de minimis cost or disruption on the employer’s business. Some courts have approached the issue of what is a reasonable accommodation in a manner that conflicts with longstanding Commission and judicial precedent. See, e.g., EEOC v. Writing Reviews Cheap? Firestone Fibers Textiles Co. , 515 F.3d 307 (4th Cir. 2008) (analyzing reasonableness of proposed accommodation based on facts typically considered as part of undue hardship analysis); Sturgill v. Paper Payment? United Parcel Service, Inc. Custom Essay Reviews Cheap? , 512 F.3d 1024 (8th Cir. 2008) (noting that terminology which describes a reasonable accommodation as one that eliminates any work-religion conflict is imprecise, because it may incorrectly imply that reasonableness is Research, determined as a matter of law without regard to the facts of an individual case, or that an employer is not permitted to choose among alternative accommodations, or that even accommodations which conflict with a CBA or otherwise pose an Custom essay cheap undue hardship must be granted). The Commission’s approach is paper payment, more straightforward and more in keeping with the purpose of Dissertation consulting Title VII’s accommodation requirement. Concerns about issues such as conflicts with a union contract or burdens on other employees’ settled expectations can and should be addressed in the context of whether or not it would impose an paper payment undue hardship.

Moreover, the employer need not grant an employee’s requested reasonable accommodation if the employer wishes instead to offer an alternative accommodation of its own choosing that also would eliminate the work-religion conflict and does not adversely affect the employee’s terms, conditions, or privileges of english employment. [131] In Ansonia Bd. of Educ., 479 U.S. at 68-69, the Court held that an employer has met its obligation under § 701(j) of Research Title VII when it demonstrates that it has offered a reasonable accommodation to the employee; “where the Essay internet employer has already reasonably accommodated the employee’s religious needs, the statutory inquiry is at an end. The employer need not further show that each of the employee’s alternative accommodations would result in undue hardship.” Cf. Opuku?Boateng v. California, 95 F.3d 1461 (9th Cir. 1996) (where employer offered no accommodation and employee offered several possibilities, such as scheduling him instead for other equally undesirable shifts and adopting a system of voluntary or mandatory shift trades, the employer had to accept one of the employee’s proposals unless doing so would create an undue hardship). This section addresses only whether the accommodation was reasonable. Paper? An employer that does not provide a reasonable accommodation may nevertheless avoid liability if it shows that providing the accommodation would pose an undue hardship. Undue hardship is Writing essays for ap, addressed below in § IV.B. [132] Ansonia Bd. of Educ. , 479 U.S. at 70-71 (“requiring [an employee] to take unpaid leave for holy day observance rather than use personal paid leave days provided for paper payment, under CBA would generally be a reasonable accommodation” because it has “no direct effect upon either employment opportunities or job status,” but “unpaid leave is not a reasonable accommodation when paid leave is provided for all purposes except religious ones . . . Service? [s]uch an arrangement would display a discrimination against religious practices that is the antithesis of reasonableness”).

In cases involving requests for schedule changes or leave as an accommodation, an employer does not have to provide paid leave as an payment accommodation beyond that otherwise available to the employee, but may have to write essay for scholarship hardship letter, provide unpaid leave as an accommodation if it would not pose an undue hardship. [133] Commission Guidelines , 29 C.F.R. § 1605.2(c)(2)(ii) (“when there is more than one means of accommodation that would not cause undue hardship, the Research employer or labor organization must offer the alternative which least disadvantages the individual’s employment opportunities”). The Commission’s guidelines do not require an employer to Help message, accept any alternative favored by the employee, and, thus, are not inconsistent with Ansonia . In fact, the Court in Ansonia recognized that the limitation in the Commission’s guidelines that alternatives must be considered if they will not “disadvantage an individual’s employment opportunities” distinguished the Commission’s position from the Research paper payment position of the Second Circuit that was rejected in Ansonia . Pay For Literary Paper Use? 470 U.S. at 69 n.6. Appellate courts in Research paper, the wake of Ansonia have, as the Commission’s guidelines instruct, evaluated whether employer accommodations had a negative impact on the individual’s employment opportunities. See Cosme v. Henderson , 287 F.3d 152, 160 (2d Cir. 2002) (an accommodation might be unreasonable if it imposes a “significant work-related burden on the employee without justification”); Wright v. Runyon , 2 F.3d 214, 217 (7th Cir. 1993) (whether an accommodation is reasonable requires a more searching inquiry if an employee, “in order to accommodate his religious practices, had to accept a reduction in pay or some other loss of benefits”). [134] Smith v. Pyro Mining Co. , 827 F.2d 1081, 1085 (6th Cir. 1987) (quoting Redmond , 574 F.2d at 902-03). [135] Baker v. Home Depot , 445 F.3d 541 (2d Cir.

2006) (employer’s offer to with message, schedule employee to Research, work in consulting service, the afternoon or evenings on Sundays, rather than the mornings, was not a “reasonable” accommodation under Title VII where employee’s religious views required not only payment attending Sunday church services but also refraining from write short essay for scholarship hardship work on Sundays). [136] Wilshin v. Allstate Ins. Co., 212 F. Supp. 2d 1360 (M.D. Ga. 2002) (employer satisfied obligation to accommodate employee’s Saturday Sabbath observance by offering Sunday work hours instead, notwithstanding that employee would have preferred weekday hours). [137] Shelton , 223 F.3d at 226 (state hospital’s offer to transfer nurse to paper payment, newborn intensive care unit was reasonable accommodation for essay cheap, her religious beliefs which prevented her from paper payment assisting in emergency procedures to terminate pregnancies, where nurse presented no evidence that transfer would affect her salary or benefits); see also Rodriguez v. City of Chicago, 156 F.3d 771 (7th Cir.

1998) (city’s offer to allow police officer to exercise his right under CBA to transfer to for ap english, a district with no abortion clinics resolved his religious objection to being assigned to guard such facilities; Title VII did not compel employer to instead grant his preferred accommodation of remaining in paper, his district but being relieved of such assignments); Wright , 2 F.3d at 217 (7th Cir. 1993) (employer reasonably accommodated employee by suggesting he exercise his rights under CBA to bid on jobs that would have eliminated the for ap conflict between work and religion). [138] Townley , 859 F.2d at 614 n.5 (citing Am. Postal Workers Union v. Research? Postmaster , 781 F.2d 772, 774?75 (9th Cir. 1986)); see also Rodriguez v. Reviews Cheap? City of Chicago, 1996 WL 22964, at *3 (N.D. Ill. Research? Jan. Pay For Literary? 12, 1996) (rejecting employer’s argument that a threat of adverse action is not enough to state a claim; “it is nonsensical to suggest that an employee who, when forced by his employer to Research payment, choose between his job and his faith, elects to avoid potential financial and/or professional damage by Writing essays for ap english acceding to his employer’s religiously objectionable demands has not been the victim of religious discrimination”).

Moreover, a denial of accommodation claim can be brought if the employer could have provided an accommodation absent undue hardship that did not disadvantage a term, condition, or privilege of employment, but did not do so. For example, if a Muslim employee is transferred to non-customer service position because she refuses to stop wearing a religiously mandated headscarf, she states a claim for denial of accommodation under Title VII. Draper v. U.S. Pipe Foundry Co. , 527 F.2d 515 (6th Cir. 1975) (resorting to transfer where accommodation was possible in employee’s current position is payment, actionable as denial of reasonable accommodation). However, an employer need not accommodate an employee who chooses to resign before notifying the Help english message employer of the need for accommodation or fails to cooperate with the employer in the accommodation process. See, e.g., Goldmeier v. Allstate Ins. Co. , 337 F.3d 629 (6th Cir. 2003) (resignation 53 days prior to effective date of employer’s policy that would have posed conflict with employees’ religious beliefs did not constitute constructive discharge); Lawson v. Washington , 296 F.3d 799 (9th Cir. 2002) (Jehovah’s Witness who quit state patrol rather than salute the paper flag or take an oath in violation of his religious beliefs was not constructively discharged and thus was not subject to an adverse employment action where, rather than request accommodation, he informed employer that he was resigning due to his religious conflict); Shelton v. Univ. of Med.

Dentistry of N.J. , 223 F.3d 220, 227 (3d Cir. 2000) (employee who refused to meet with employer’s human resources department to pursue alternative accommodations could not argue that accommodation employer offered was not reasonable). [139] Townley , 859 F.2d at 614 n.5 ; Rodriguez, 1996 WL 22964. [140] Cooper , 15 F.3d at 1379 (Seventh-day Adventist employee’s need for accommodation to observe Sabbath had changed in the 17 months since employer had last scheduled her to paper use, work on a Friday night or Saturday; her “undisputed testimony was that her faith and commitment to her religion grew during this time”). [141] See, e.g., Hardison, 432 U.S. at 84. Payment? This “more than de minimis ” Title VII undue hardship standard is substantially lower than the service ADA undue hardship standard, which requires employers to show that the accommodation would cause “significant difficulty or expense.” [142] Both the statute, at 42 U.S.C. § 2000e(j), and the Commission Guidelines , at 29 C.F.R. § 1605.2(b), require an employer to reasonably accommodate an employee’s or applicant’s religious beliefs and paper payment, practices “unless the employer demonstrates” that doing so would pose an undue hardship. Even under the consulting service Fourth Circuit’s decision in EEOC v. Firestone , and the Eighth Circuit’s decision in Sturgill v. United Parcel Service , where courts focused on reasonableness before looking at undue hardship, the payment employer still has the burden of with writing persuasion. Firestone , 515 F.3d at 315; Sturgill , 512 F.3d at 1033 n.4. [143] Tooley v. Martin Marietta Corp. , 648 F.2d 1239, 1243 (9th Cir. Paper Payment? 1981).

[144] Commission Guidelines , 29 C.F.R. § 1605.2(e). [145] Compare Cooper , 15 F.3d at 1380(employee’s request not to be scheduled for Saturday work due to message, Sabbath observance posed undue hardship for employer because it would have required hiring an additional worker), and Beadle v. Tampa , 42 F.3d 633 (11th Cir. 1995) (requiring police department to alter training program schedule involving more than 900 employees to accommodate one employee’s religious needs amounts to more than de minimis cost and payment, thus undue hardship), with Protos , 797 F.2d 129 (employee’s request not to be scheduled for Saturday work due to Sabbath observance did not pose undue hardship where employer made no showing that efficiency, production, or quality would be affected and entire assembly line remained intact notwithstanding employee’s Saturday absences). [146] See Brown v. Gen. Motors Corp., 601 F.2d 956, 960 (8th Cir. 1979) (“projected ‘theoretical’ future effects cannot outweigh the consulting service undisputed fact that no monetary costs and de minimis efficiency problems were actually incurred during the three month period in which [employee] was accommodated”); EEOC v. Alamo Rent-A-Car, LLC , 432 F. Supp. 2d 1006 (D. Ariz. 2006) (employer incorrectly believed that if it allowed plaintiff to wear her religious headscarf it could not enforce its uniform policy with respect to other employees, and failed to show undue hardship based on its fear that allowing the accommodation would open “the floodgates to others violating the uniform policy”).

[147] Tooley , 648 F.2d at Research paper 1243 (“undue hardship cannot be supported by merely conceivable or hypothetical hardships . . Essay Pdf? . . The magnitude as well as the fact of hardship must be determined by ‘actual imposition on co-workers or disruption of the work routine’”) (quoting Anderson v. Gen. Dynamics Convair Aerospace Div. , 589 F.2d 397, 406-07 (9th Cir. 1978)); EEOC v. Alamo Rent-A-Car, LLC , 432 F. Supp. 2d at 1016 (“‘hypothetical hardships’” based on assumptions or “pure speculation” about accommodations which have never been put into practice are insufficient to show undue hardship”). [149] Id. Compare EEOC and Research, Electrolux Reach Voluntary Resolution in Class Religious Accommodation Case (press release available at https://www.eeoc.gov/press/9-24-03.html, Sept. 24, 2003) (settlement whereby employer agreed to accommodate the religious request of 165 Somali workers who, pursuant to the tenets of the Islamic faith, must offer at with least five daily prayers, two of Research paper payment which must be observed within a restricted time period of Custom essay writing between one and two hours) with Farah v. Whirlpool Corp ., 3:02cv424 (M.D.

Tenn. Oct. Research Payment? 16, 2004) (jury verdict entered in favor of employer, which argued that allowing 40 Muslim factory workers to take a break from the line for Writing essays, their sunset prayers at the same time would result in an undue hardship because as a result of their absence, the line would have to Research, be shut down). [150] Commission Guidelines , 29 C.F.R. § 1605.2(e)(1). Under Title VII, for example, in Hardison , the payment of essay writing cheap overtime (or premium pay) to another employee so that plaintiff could be off for weekly religious observance was an undue hardship. Id . By contrast, infrequent pay of premium wages for an occasional religious observance is Research paper payment, not “more than de minimis .” See, e.g., EEOC v. Southwestern Bell Tel. LP , 2007 WL 2891379 (E.D. Ark. Internet? Oct. 3, 2007) (summary judgment for paper payment, employer denied on Dissertation consulting service claim by two employees that they were improperly denied leave for an annual religious observance that would have required company to pay two other workers overtime wages of Research paper approximately $220 each to fill in, where the facility routinely paid technicians overtime, the employer failed to contact the union about possible accommodation, the policy providing for only one technician on Dissertation consulting leave per day was not always observed, and Research paper, there was no evidence that customer service needs actually went unmet on the day at issue) (jury verdict for plaintiffs subsequently entered), appeal docketed , Case No.

08-1096 (8th Cir. filed Jan. 10, 2008); Brown v. Gen. Motors Corp. , 601 F.2d at for ap 959-60 (no more than de minimis cost imposed by allowing employee to leave work at Sundown on Friday where he did not receive any pay for the time missed, a replacement worker was readily available to fill in for him on the shift during the hours he missed because the company maintained “extra board men” who were at all times available to replace unscheduled absences of payment regular employees); Burns v. Pay For? S. Pac. Research Payment? Transp. Pdf? Co. , 589 F.2d 403, 407 (9th Cir. 1978) (excusing employee from paying his monthly $19 union dues due to religious objection did not pose an undue hardship, where one union officer testified that the loss “wouldn’t affect us at all”; the loss was also de minimis because “even if so necessary to Research payment, its fiscal well?being that its equivalent would be collected from the essay writing Local’s 300 members at a rate of Research payment 2 cents each per month; an accommodation that would only result in an increase of other union members dues in amount of 24 cents per year was de minimis ; unions asserted fear that many more religious objectors would request similar accommodation, resulting in greater cost, was based on mere speculation); EEOC v. IBP, Inc. , 824 F. Supp. 147 (C.D. Writing Reviews? Ill. 1993) (adopting EEOC’s interpretation in the Commission Guidelines that undue hardship means, with respect to costs for a substitute, “costs similar to the regular payment of premium wages,” and holding that “[i]nfrequent payment of premium wages made on a temporary basis and Research, administrative costs associated with implementing an accommodation are considered de minimis , although the ultimate determination is made with ‘due regard given to the identifiable cost in relation to the size and operating cost of the employer.’ 29 C.F.R. § 1605.2(e)(1)).” [151] Commission Guidelines , 29 C.F.R. § 1605.2(e)(1); Redmond , 574 F.2d at 904 (employer could not demonstrate that paying replacement worker premium wages would cause undue hardship because plaintiff would have been paid premium wages for the hours at issue). [152] Protos , 797 F.2d at 134-35; Brown v. Polk County , 61 F.3d at 655 (allowing employee to assign secretary to type his Bible study notes posed more than de minimis cost because secretary would otherwise have been performing employer’s work during that time). [153] “[A]n employer need not accommodate an employee’s religious beliefs if doing so would result in discrimination against with english writing message his co-workers or deprive them of contractual or other statutory rights.” Peterson v. Hewlett-Packard Co. , 358 F.3d 599 (9th Cir.

2004) (also holding that employee’s proposed accommodation of either allowing him to Research paper, post religiously motivated messages intended to demean and harass co-workers, or the company deleting sexual orientation from its voluntarily adopted diversity and non-discrimination policy, would have posed an undue hardship on the employer); EEOC v. BJ Servs. Custom Essay Reviews? Co. , 921 F. Supp. Research? 1509 (N.D. Tex. 1995) (employer was unable to accommodate employee’s religious request for with message, certain day off because no other employees were available to payment, work, there were safety concerns regarding untrained substitute personnel, there were significant costs in short, bringing employees from other locations, and this accommodation would deny other employees their day off); Virts v. Consol. Freightways Corp. of Delaware , 285 F.3d 508 (6th Cir. 2002) (trucking firm had no obligation under Title VII to accommodate a driver’s religious request for only male driving partners, where making assignments in this manner would have violated collective bargaining agreement). [154] BJ Servs. Co., 921 F. Supp. at paper 1509; Balint v. Carson City, Nevada , 180 F.3d 1047, 1054 (9th Cir. 1999) (citing Bhatia v. Chevron U.S.A., Inc. , 734 F.2d 1382, 1384 (9th Cir.1984) (cost of plaintiff’s requested accommodation was more than de minimis when it required co-workers to assume plaintiff’s share of the Pay for anlaysis paper use hazardous work)); Bruff 244 F.3d at Research paper payment 501 (requiring co-workers of plaintiff mental health counselor to assume disproportionate workload to accommodate plaintiff’s request not to counsel certain clients on religious grounds would constitute undue hardship). [155] See, e.g., Sutton v. Essay Writing? Providence St.

Joseph Med. Ctr. , 192 F.3d 826 (9th Cir. 1999) (employer not required to accommodate job applicant’s religiously based refusal to Research paper, provide his social security number where employer sought it to Writing, comply with Internal Revenue Service and paper payment, Immigration and Naturalization Service requirements). However, an with english message employer should not assume that it would pose an undue hardship to accommodate a religious practice that appears to conflict with a generally applicable safety requirement, but rather should assess whether an undue hardship is paper payment, actually posed. For example, there are existing religious exemptions to the government enforcement procedures of some safety requirements.

See, e.g. , U.S. Department of Labor, Occupational Safety and Health Administration STD 1-6.5 (“Exemption for Religious Reason from consulting editing Wearing Hard Hats”) (June 20, 1994) (exempting employers from citations for certain violations based on religious objection of employee, but providing for various reporting requirements). [156] See EEOC v. Oak-Rite Mfg. Paper? Corp. , 2001 WL 1168156 (S.D. Ind. Aug. 21, 2001) (manufacturing employee’s proposed accommodation of write essay for scholarship letter wearing close-fitting denim or canvas dress or skirt that extends to within two or three inches above the ankle would impose an undue hardship on employer by requiring it to experiment with employee safety, given the absence of evidence demonstrating safety of paper proposed accommodation in a comparable work setting); EEOC v. Brink’s Inc., No. 1:02-CV-0111 (C.D. Ill.) (consent decree filed Dec. 27, 2002) (settlement of How to write hardship case alleging that employee was denied reasonable accommodation when she sought to Research paper, wear culottes made out of Custom cheap messenger uniform material, rather than the Research paper payment required trousers, because her Pentecostal Christian beliefs precluded her from wearing pants); c f. Webb v. City of Philadelphia, 2007 WL 1866763 (E.D.

Pa. June 27, 2007) (undue hardship to accommodate the wearing of a traditional religious headpiece called a khimar by a Muslim police officer while in uniform, where evidence showed dress code in para-military organization promotes cooperation, fosters esprit de corps, emphasizes the hierarchical nature of the police force, and portrays a sense of Help with english authority as well as public and religious neutrality to the public). [157] Hardison, 432 U.S. at Research paper 80; Stolley v. Lockheed Martin Aeronautics Co. Message? , 2007 WL 1010418 (5th Cir. March 28, 2007) (unpublished) (affirming summary judgment in favor of the employer, the court ruled that a newly-hired aircraft assembly line worker was not entitled to have the employer reassign him to a different shift as an accommodation for his Sabbath observance, because the employer’s union contract dictated that shift swapping and Research paper, transfers would be based on seniority and the union was unwilling to english, waive the contract in this case); see also Balint , 180 F.3d at 1054. [158] Balint, 180 F.3d at 1054; Killebrew v. Paper? Local Union 1683 of Help writing message Am. Fed’n of State, County, Mun. Employees, AFL-CIO, 651 F. Supp. 95 (W.D. Ky. 1986) (union not required to negotiate a change in the CBA to paper, allow an employee to short for scholarship letter, bump another employee to obtain an accommodation because bumping would have been detrimental to those bumped); see also Virts v. Consol. Freightways Corp. of Research paper payment Delaware , 285 F.3d 508 (6th Cir.

2002) (trucking firm had no obligation under Title VII to accommodate a driver’s religious request for only male driving partners, where making assignments in this manner would have violated CBA); Weber v. Roadway Express, Inc. , 199 F.3d 270 (5th Cir. Anlaysis? 2000) (same); Thomas , 225 F.3d 1149 (because seniority system in CBA gave more senior employees first choice for job assignments, it would be an undue hardship for employer to grant employee’s accommodation request not to be scheduled to work on paper payment Saturdays); Mann v. Frank , 7 F.3d 1365 (8th Cir.1993) (no violation of the duty to accommodate where the union refused the Postal Service’s request to assign another worker to take plaintiff’s Saturday shift, which would have violated CBA’s provisions governing overtime). [159] Commission Guidelines , 29 C.F.R. Dissertation Consulting? § 1605.2(e)(2); Stolley , 2007 WL 1010418. [160] Lee v. ABF Freight Sys., Inc., 22 F.3d 1019 (10th Cir. 1994) (employer satisfied Title VII obligation when it suggested method by which driver would usually be able to work the number of trips each week required under the union contract prior to the Sabbath, and could use vacation time on other occasions; employer was not required to grant driver’s request to skip assignments, which would then have to be worked by other drivers, or his request to work less than other full-time drivers and paper payment, reimburse employer for additional costs; or his request to transfer with no loss of seniority, which would violate its CBA, where the employer had sought but could not obtain a waiver from the union). [162] See Wilson v. U.S. West Communications, 58 F.3d 1337 (8th Cir. 1995) (employer reasonably accommodated an writing internet pdf employee by asking her when she was outside her cubicle to paper, cover up an Custom essay reviews anti-abortion button she wore containing a graphic photograph of a fetus because the button so distracted other employees that it had caused a 40% reduction in Research paper, productivity and some employees threatened to walk off their jobs). [163] Opuku-Boateng , 95 F.3d at 1473 (mere complaints by other employees did not constitute undue hardship; employer failed to establish undue hardship in accommodating employee’s religious holidays because it did not show hardship on plaintiff’s co-workers or that accommodation required more than de minimis cost).

[164] Burns, 589 F.2d at 407 (“Undue hardship requires more than proof of some fellow-workers’ grumbling or unhappiness with a particular accommodation to a religious belief. Pay For Paper Use? An employer or union would have to Research paper payment, show . Essay Reviews Cheap? . . actual imposition on co-workers or disruption of the work routine.”); accord Brown v. Polk County , 61 F.3d at 655; Peterson v. Hewlett-Packard Co. Payment? , 358 F.3d 599 (9th Cir. 2004) (it would have posed an undue hardship for employer to accommodate employee’s religiously motivated posting of large signs in his cubicle which he “intended to be hurtful” and to demean and harass his co-workers; it also would have posed an undue hardship for employer to eliminate a portion of its diversity program to which plaintiff had religious objections). [165] See nn.182-184, infra. However, a different result may obtain depending on the setting and Writing essays english, the religious garb at issue. See United States v. New York State Dep’t of Corr. Servs. , Civil Action No. Payment? 07-2243 (S.D.N.Y. settlement approved Jan. 18, 2008) (providing for essays, individualized review of correctional officers’ accommodation requests with respect to uniform and grooming requirements, and allowing employees to wear religious skullcaps such as kufis or yarmulkes if close fitting and Research, solid dark blue or black in color, provided no undue hardship was posed).

[166] For example, Title 18 U.S.C. With English Writing? Section 930 generally prohibits the possession of knives, including kirpans, with blades longer than 2.5 inches, in federal facilities, unless otherwise authorized. [167] The Commission’s regulations, Commission Guidelines , 29 C.F.R. § 1605.2(d), set forth suggested methods of paper payment accommodating scheduling conflicts, but those methods are not intended to comprise an exhaustive list. Different factual circumstances will require different solutions. State wage and hour laws may provide certain limitations that impact an anlaysis employer’s potential flexibility. [168] See “Electronics Manufacturer and Islamic Group Settle Muslim Prayer Issue in Georgia Factory,” Daily Labor Report (BNA), No. 230 (Dec. 1, 1999) (ISSN 1522-5968); see also supra n.149; George v. Home Depot , 2002 WL 31319124 (5th Cir. Sept. 22, 2002) (unpublished) (excusing employee who served as department “greeter” from working any Sundays would have posed an undue hardship, because she was the only greeter in the department; the paper payment store would have had to do without a Sunday greeter or hire another employee in order to grant the accommodation, both of which would have posed an undue hardship based on the evidence the employer provided regarding the need for the position); Brener , 671 F.2d 141 (requiring hospital to hire a substitute pharmacist for days employee sought not to work due to Essay writing pdf, religious observance involved more than a de minimis cost, and operating without him or having the pharmacy director substitute for him would have had an unacceptable adverse impact on functions of the pharmacy). [169] See U.S. Research? v. Los Angeles County Metropolitan Transit Authority , Case No.

CV 04-07699 JFW (JTLx) (C.D. Write Short Essay? Cal. Paper? consent decree filed Oct. Write Short Essay For Scholarship? 2005) (lawsuit filed by Civil Rights Division of the U.S. Department of Research Justice and resolved by Essay writing pdf consent decree prior to Research paper payment, ruling by court on merits; the write for scholarship hardship letter settlement provided that the employer would accept the applications of Sabbath-observant applicants; provide applicants with information about their accommodation rights; permit drivers to swap assignments with other drivers, and when no acceptable assignment is possible either through use of seniority rights or swaps, permit drivers to paper payment, take temporary leaves of absence; and provide information about religious accommodation in marketing literature and in its training programs for supervisors). [170] EEOC v. Robert Bosch Corp. , 2006 WL 406296 (6th Cir.

Feb. 21, 2006) (unpublished) (in case involving request for Pay for literary use, shift swap and relief from mandatory overtime to accommodate Sabbath observance, summary judgment for employer reversed where reasonable factfinder could conclude that employer failed to provide reasonable accommodation based on evidence that plaintiff was told a shift swap would not be permitted and the employer’s policy was only designed to identify employees willing to work additional shifts, not to swap shifts); Beadle v. Hillsborough County Sheriff’s Dep’t , 29 F.3d 589 (11th Cir. Paper? 1994) (employer satisfied its accommodation obligation by Custom writing reviews allowing employee to make announcement on bulletin board and at employee meeting to seek out co-workers willing to swap); McGuire v. Gen. Motors Corp ., 956 F.2d 607 (6th Cir. 1992) (summary judgment for employer reversed where genuine issue of material fact existed regarding whether employer’s accommodation of allowing voluntary shift swaps was a reasonable accommodation where there was evidence employer may have intentionally or unintentionally inhibited volunteers from swapping shifts by Research issuing a survey to employees regarding whether they would be willing to swap shifts in order to accommodate plaintiff); see also Beadle v. Tampa, 42 F.3d at literary anlaysis paper use 636-37 (excusing police recruit from rotating training schedule would have posed undue hardship because it would undermine intended educational benefit of working with different training officers); Morrissette-Brown v. Paper Payment? Mobile Infirmary Med. Ctr. Pay For Paper? , 2006 WL 1999133 (S.D. Ala. July 14, 2006) (in case brought by Research paper Seventh-day Adventist who requested not to work on writing reviews her Sabbath, employer satisfied its accommodation obligation by maintaining a neutral shift rotation schedule, allowing plaintiff to arrange a shift swap with co-workers, and making available the Research paper payment schedules of literary other employees). [171] See, e.g., Pyro Mining Co. , 827 F.2d at Research paper 1088-89 (it would be a reasonable accommodation for employer simply to be amenable to with english writing message, a shift swap; employer not required itself actively to solicit other employees to make such a swap unless plaintiff had religious constraints against arranging his own schedule swap with other employees; a CBA’s provision permitting religious observers to trade days off with other employees did not provide reasonable accommodation in the case of an employee who had a religious objection to paper, seeking such a trade); EEOC v. Essays For Ap English? Texas Hydraulics, Inc. Research Paper? , Case No. 2:06-cv-161 (E.D. Tenn.

April 16, 2008) (employer's proposal that employee find another qualified candidate to Dissertation consulting, take his Saturday shift was not a reasonable accommodation because the payment employer was on notice that the How to short hardship employee considers it a sin for anyone to Research paper, work on Saturday, not just himself); EEOC v. Aldi , 2008 WL 859249 (W.D. Pay For Literary Anlaysis? Pa. March 28, 2008) (where an employee sincerely believes that working on [his Sabbath] is morally wrong and that it is a sin to try to induce another to work in his stead, then an employer's attempt at accommodation that requires the Research employee to seek his own replacement is not reasonable ”) (emphasis in original) (citing Pyro Mining Co. , 827 F.2d at 1088). [172] Commission Guidelines , 29 C.F.R. § 1605.2(e)(1); Redmond. , 574 F.2d at 904 (employer could not demonstrate that paying replacement worker premium wages would cause undue hardship because plaintiff would have been paid premium wages for pdf, the hours at issue); EEOC v. Southwestern Bell Tel. LP, 2007 WL 2891379 (E.D. Ark. Research Paper Payment? Oct. 3, 2007) (payment of premium wages for one day to allow two employees to attend a yearly Jehovah’s Witness convention as part of their religious practice, at an alleged cost of $220.72 per short essay for scholarship hardship letter person in paper payment, a facility that routinely paid overtime was not an undue hardship as a matter of law, where there was no evidence that customer service needs actually went unmet on the day at issue), appeal docketed , Case No.

08-1096 (8th Cir. filed Jan. 10, 2008). [173] U.S.F. Logistics (IMC), Inc. , 274 F.3d at How to write essay hardship letter 477 (“[i]n many cases, a company must modify its stated policies in practice to reasonably accommodate a religious practice”) (citing Minkus v. Metro. Research Paper Payment? Sanitary Dist. , 600 F.2d 80 (7th Cir.1979) (municipal employer failed to accommodate a Jewish applicant when it followed its stated policy and scheduled civil service examinations only on Saturdays). [174] EEOC v. Razzoo’s , Civil Action No. 3:06-CV-1781-L (N.D. Tex. consent decree filed June 18, 2007) (settlement of case alleging that restaurant unlawfully failed to accommodate server’s religious beliefs by excusing her from participating in singing “Happy Birthday” to celebrating customers). [175] Noesen v. Med. Staffing Network, Inc. , 2007 WL 1302118 (7th Cir. May 2, 2007) (unpublished) (pharmacy reasonably accommodated employee by allowing him to transfer to Pay for literary anlaysis use, co-worker any customer service involving contraceptives; employee’s proposed further accommodation of assigning responsibility for Research paper payment, all initial customer contact to lower-paid technicians, even if it could be done, would impose an undue hardship because it would divert technicians from Writing essays for ap english their assigned data input and insurance verification duties, resulting in uncompleted data work).

The reasonable accommodation that the employer was able to provide in Research paper payment, Noesen might pose an Custom essay reviews cheap undue hardship in a different case where there was no qualified co-worker on duty to Research paper, whom such customer service duties could be transferred, or where it would otherwise pose more than a de minimis burden on the operation of the employer’s business. [177] Draper , 527 F.2d at 519-20 (transfer that involved substantial reduction in consulting service, pay and would have “wasted [plaintiff’s] skills” would not be reasonable accommodation where plaintiff could have been accommodated in his original position without undue hardship). [178] Commission Guidelines , 29 C.F.R. § 1605.2(d)(iii) (“When an employee cannot be accommodated either as to his or her entire job or an assignment within the job, employers and labor organizations should consider whether or not it is possible to change the payment job assignment or give the employee a lateral transfer.”); Rivera v. Pay For Literary Anlaysis Use? Choice Courier , 2004 WL 1444852 (S.D.N.Y. June 25, 2004) (employer’s failure to consider transferring employee to Research, position with less stringent dress code so that he could continue his religious practice of proselytizing by wearing patch stating “Jesus is Lord” may have violated Title VII). [179] See supra n.138; Rodriguez , 156 F.3d at 775-77 (permitting employee to exercise transfer rights under CBA to obtain equivalent position that eliminated religious conflict with duty assignment was a reasonable accommodation); see also Cook v. Lindsay Olive Growers , 911 F.2d 233, 241 (9th Cir. 1990) (under state law parallel to Title VII, transfer of Writing for ap english employee to a lower-level position was reasonable where no equivalent position was available); Bruff , 244 F.3d at 501 (accommodation by transfer to lower-paying non-counselor job could satisfy Title VII if plaintiff could not be accommodated in her current position or an equivalent position). [180] Shelton , 223 F.3d at 227 (offering transfer to nurse who had religious objection to abortion procedure sometimes performed in her department was a reasonable accommodation); EEOC v. Dresser-Rand Co. , 2006 WL 1994792 (W.D.N.Y. July 14, 2006) (summary judgment for employer denied in paper, case on behalf of a Jehovah’s Witness who allegedly was denied transfer to different assignment as an accommodation of his religious objection to working on military projects). But cf. supra n.138 (discussing when a lateral transfer might be an english writing message adverse employment action). Research Paper? At least one court has ruled that it is Custom writing, unreasonable for public protectors such as police officers or fire fighters to seek to be relieved from certain assignments as a religious accommodation.

See Endres v. Indiana State Police , 349 F.3d 922, 927 (7th Cir. 2003) (state police officer’s religious accommodation request not to be assigned to full-time, permanent work at a casino was unreasonable; police and fire departments “need the cooperation of all members” and need them to perform their duties “without favoritism”), cert. denied , 541 U.S. 989 (2004). Because public protectors, such as police officers and firefighters, are obliged to serve and protect all under their care, and their public responsibilities must take precedence over their religious and other personal scruples, in some cases conflicts between the requirements of their job and their religious beliefs may not be able to be resolved. However, it is not per se unreasonable for public protectors to obtain changes in job assignments, schedule changes, or transfers in situations where a conflict between their job duties and their religious beliefs could be eliminated or reduced.

Therefore, the better approach is to Research payment, determine on a case-by-case basis whether granting the request would pose an paper undue hardship. [181] See, e.g., EEOC v. United Parcel Serv. , 94 F.3d 314 (7th Cir. 1996) (genuine issue of material fact regarding whether the employer reasonably accommodated the employee’s religious practice of wearing a beard precluded summary judgment for Research paper, the employer); EEOC v. Comair, Inc. , Civil Action No. 1:05-cv-0601 (W.D. Mich. consent decree filed Nov. 22, 2006) (settlement prior to ruling on merits of for scholarship hardship case on behalf of Rastafarian airline applicant alleging he was not hired because he refused to Research paper, cut his hair to conform with the company’s grooming standards); EEOC v. Pilot Travel Ctrs .LLC , Civil Action No. 2:03-0106 (M.D. Tenn. consent decree filed April 9, 2004) (settlement prior to ruling on merits of claim on behalf of Messianic Christian maintenance worker, who wore beard as part of his religious practice, and was terminated for refusing to shave in compliance with employer’s no-beard policy). [182] United Parcel Serv ., 94 F.3d at 318-20; c ompare Daniels , 246 F.3d 500 (police department may be able to demonstrate that allowing an Custom writing reviews cheap officer to wear a cross on his uniform would give the appearance of public agency endorsement of the officer’s religious views, in violation of the department’s constitutional obligations, and payment, therefore would pose an undue hardship under Title VII), cert. denied , 534 U.S. 951 (2001), with Draper v. How To Write Short Essay For Scholarship Hardship? Logan County Pub.

Library , 403 F. Supp. 2d 608 (W.D. Ky. 2005) (public library employee’s First Amendment free speech and free exercise rights were violated when she was prohibited from Research wearing a necklace with a cross ornament). [183] See, e.g., Cloutier v. Costco Wholesale Corp. , 390 F.3d 126 (1st Cir.

2004) (holding that it would pose “an undue hardship to Help with message, require Costco to grant an exemption because it would adversely affect the employer’s public image,” given Costco’s determination that facial piercings detract from the “neat, clean and professional image” that it aims to cultivate). [184] Denying the employer’s motion for summary judgment in EEOC v. Red Robin Gourmet Burgers, Inc. Paper? , 2005 WL 2090677 (W.D. Wash. Aug. Consulting Editing? 29, 2005), the court ruled that notwithstanding the paper payment employer’s purported reliance on a company profile and customer study suggesting that it seeks to present a family-oriented and kid-friendly image, the Writing english company failed to demonstrate that allowing an Research paper employee to Dissertation consulting service, have visible religious tattoos was inconsistent with these goals. “Hypothetical hardships based on unproven assumptions typically fail to constitute undue hardship . . . . Red Robin must provide evidence of ‘actual imposition on co-workers or disruption of the work routine’ to demonstrate undue hardship.” S ee also Brown v. Research Paper? F.L. Roberts , 419 F. Supp. 2d 7, 17 (D. Mass. 2006) (district court held no Title VII violation occurred when employer transferred lube technician whose Rastafarian religious beliefs prohibited him from literary paper shaving or cutting his hair to a location with limited customer contact because he could not comply with a new grooming policy; stating it was bound to follow Cloutier as the law of the circuit, the court nevertheless observed in dicta: “If Cloutier’s language approving employer prerogatives regarding ‘public image’ is read broadly, the Research paper payment implications for persons asserting claims for religious discrimination in the workplace may be grave. One has to wonder how often an employer will be inclined to cite this expansive language to terminate or restrict from customer contact, on image grounds, an editing employee wearing a yarmulke, a veil, or the mark on the forehead that denotes Ash Wednesday for many Catholics. Paper Payment? More likely, and more ominously, considerations of ‘public image’ might persuade an employer to tolerate the religious practices of predominant groups, while arguing ‘undue hardship’ and ‘image’ in forbidding practices that are less widespread or well known.”); EEOC v. Chriskoll, Inc. , d/b/a Brookhaven Burger King, Civil Action No.

06-cv-1197 (E.D. Pa. consent decree filed December 3, 2007) (settlement of anlaysis paper claim on behalf of paper Muslim employee who was terminated pursuant to restaurant appearance code requiring male employees to be clean-shaven notwithstanding that employer’s written policy had exception permitting beards required for religious reasons). [185] See generally EEOC v. American Airlines , Civil Action No. 02-C-6172 (N.D. Ill.) (Order of Resolution filed September 3, 2002) (resolving claim on behalf of employee who was not hired as passenger service agent because she wore a hijab for religious reasons in essay, violation of the airline’s since-changed uniform policy; the Research payment airline’s current uniform policy specifically contemplates exceptions for religious accommodation of employees). [186] Webb v. Pay For Literary Anlaysis Use? City of Research Philadelphia, 2007 WL 1866763 (E.D.

Pa. June 27, 2007) (granting summary judgment to the employer, the court ruled that the City of Philadelphia established as a matter of law that it would pose an writing undue hardship to accommodate the Research paper payment wearing of a traditional religious headpiece called a khimar by a Muslim police officer while in Pay for anlaysis, uniform, in contravention of the department’s dress code directive). [187] See U.S. v. New York State Dep’t of Research Corr. Write Essay For Scholarship Hardship Letter? Servs. , Civil Action No. 07-2243 (S.D.N.Y. settlement approved Jan. 18, 2008) (settlement of case brought on behalf of Muslim correctional officers by U.S. Department of Justice providing that employee requests for paper, religious exemptions from uniform and grooming requirements of state prison system would be determined on essay letter a case-by-case basis, and paper payment, allowing employees to Custom, wear religious skullcaps such as kufis or yarmulkes if close fitting and solid dark blue or black in color, provided no undue hardship was posed). [188] See also Federal Workplace Guidelines , supra n.11, at § 1.c (“Accommodation of Religious Exercise”), example (d) (under the First Amendment, government workplaces that allow employees to use facilities for Research payment, non-work related secular activities generally are required to allow the privilege on equal terms for employee religious activities). [189] See, e.g., Minkus , 600 F.2d 80; Cary , 908 F. Supp. at 1343-44 (employee failed to give employer proper notice so that it could attempt an accommodation of his religious objection to signing consent form for a drug test). [190] Minkus , 600 F.2d 80 (employer must demonstrate it would pose undue hardship to allow applicant to take exam at different time than others as a religious accommodation). [191] Sutton v. Providence St.

Joseph Med. Ctr. , 192 F.3d 826 (9th Cir. 1999) (hospital not liable for refusing to hire applicant who declined to provide social security number on How to short essay religious grounds; because federal tax law required the hospital to obtain all employees’ social security numbers, accommodation of applicant’s religious belief would pose undue hardship); Hover v. Florida Power Light Co., 1995 WL 91531 (S.D. Fla. Feb.

6, 1995) (employee’s proposed accommodation that employer “make up” a social security number rather than obtain employee’s actual social security number posed an undue hardship), aff’d , 101 F.3d 708 (11th Cir. 1996) (Table) (unpublished). [192] Commission Guidelines , 29 C.F.R. § 1605.2(d)(2); Tooley , 648 F.2d at 1242-44 (union cannot force an Research paper employer, under a contractual union security clause, to terminate three Seventh-day Adventists who offered to pay an amount equivalent to dues to How to short essay for scholarship, a nonreligious charity because the union failed to show that such an accommodation would deprive it of funds needed for Research paper, its maintenance and operation); EEOC v. Univ. of Detroit , 904 F.2d 331 (6th Cir. Writing? 1990) (because employee’s religious objection was to union itself, reasonable accommodation required allowing him to make charitable donation equivalent to amount of union dues instead of paying dues); Int’l Assoc. of Machinists v. Boeing , 833 F.2d 165, 169 (9th Cir. 1987) (an employer may be required to accommodate an employee who has a sincerely held religious opposition to unionism by allowing an equivalent contribution to a mutually agreeable charity in lieu of dues payment); Burns , 589 F.2d at Research paper 406-07 (allowing equivalent charitable contribution in lieu of dues did not constitute undue hardship notwithstanding administrative cost to union and “grumblings” by other employees); Cooper v. General Dynamics, 533 F.2d 163 (5th Cir. 1976) (religious belief that supporting labor union violated precept of “love thy neighbor,” i.e., including employers, was subject to Custom reviews cheap, reasonable accommodation absent undue hardship); Reed v. Payment? UAW , 523 F. Supp. 2d 592 (E.D. Consulting Service Editing? Mich.

Oct. 19, 2007) (union was not liable for paper, denial of consulting service reasonable accommodation to employee who objected to paying union dues for religious reasons, because union satisfied its accommodation obligation under Title VII by requiring the employee to pay to a charity of his choice an Research paper amount equal to write short for scholarship hardship, full union dues). [193] See McDaniel v. Essex Int’l, Inc. , 696 F.2d 34 (6th Cir. 1982) (finding employee’s proposal to donate amount equivalent to dues to a “mutually agreeable” charity was a reasonable accommodation that would not have posed an undue hardship) and EEOC v. Am. Fed’n of State, County Mun. Employees , 937 F. Supp. 166, 168 (N.D.N.Y.

1996) (referring to “mutually agreeable” charity as reasonable accommodation). Some CBAs have charities listed in them, pursuant to the requirements of section 19 of the Research National Labor Relations Act. Writing? See 20 U.S.C. § 169. [194] Commission Guidelines, 29 C.F.R. § 1605.2(e); Nottelson v. Smith Steel Workers D.A.L.U. 19806 , 643 F.2d 445 (7th Cir. 1981) (charity-substitute religious accommodation for union dues did not pose undue hardship to union where loss of plaintiff’s dues represented only .02% of paper payment union’s annual budget, and writing reviews, the union presented no evidence that the paper loss of receipts from plaintiff would necessitate an increase in the dues of his co?workers); see also Burns , 589 F.2d at 407 (excusing employee from paying his monthly $19 union dues did not pose an undue hardship, where one union officer testified that the loss “wouldn’t affect us at all” and essays english, union’s asserted fear of many religious objectors was based on mere speculation; the payment court noted, however, that if “in the essay future, the payment expressed fear of widespread refusal to pay union dues on religious grounds should become a reality, undue hardship could be proved”). One court has held that it may be inappropriate to require the religious objector to pay the full amount of the union dues to Essay writing internet, a charitable organization, however, if non-religious objectors are permitted to pay a reduced amount. Research Payment? See O’Brien v. Springfield Educ. Ass’n , 319 F. Supp. For Scholarship? 2d 90 (D. Mass.

2003) (not a reasonable accommodation to require religious objector to pay full union dues where state statute permitted non-union members to pay a lower amount in form of agency fee). Cf. Madsen v. Associated Chino Teachers, 317 F. Supp. 2d 1175, 1179 (C.D. Research? Cal. 2004) (holding that it was not disparate treatment under Title VII to require religious objectors to pay full amount of Custom reviews cheap dues to charity where non-religious objectors were only paying agency fee to union). [195] See EEOC v. Univ. of Detroit , 904 F.2d at 335; see also U.S. v. Paper? Ohio and EEOC v. Write Essay For Scholarship Hardship Letter? Ohio Civil Service Employees Association , Case No. 2:05-CV-799 (S.D.

Ohio consent decree filed Sept. 2006) (lawsuits filed by paper payment Civil Rights Division of U.S. Department of Help writing message Justice and EEOC against Research paper payment Ohio state agencies and their employee union, respectively, over essay writing reviews cheap, their refusal to accommodate state employees’ religious objections to payment of payment union dues unless the employees were members of churches that have “historically held conscientious objections to joining or financially supporting” unions; pursuant to settlement reached prior to ruling by court on merits, the consent decree provides that a state employee is essays english, permitted to pay an amount equal to the union service fee to paper payment, a mutually agreeable charity if he has sincerely held religious objections to writing, supporting the union, even if he does not belong to such a church); Int’l Assoc. of Machinists , 833 F.2d 165, 169 (9th Cir. 1987) (explaining that because “Title VII defines religion as ‘all aspects of paper religious observance and practice, as well as belief,’” a union may be required to accommodate an write essay employee who has a sincerely held religious opposition to unionism by allowing equivalent contribution to Research paper payment, mutually agreeable charity in lieu of dues payment, even if he “is not a member of an organized religious group that opposes unions”). [196] Wilson, 58 F.3d at 1341-42 (given disruption among co-workers actually caused in Custom writing, workplace, employee’s request to wear at all times a button containing a graphic photograph of a fetus with anti-abortion message posed undue hardship; employer reasonably accommodated employee by offering her several alternatives, including to take the button off or cover up the Research paper payment photograph portion when she left her work cubicle); cf . Red Robin Gourmet Burgers , 2005 WL 2090677 (denying employer’s motion for summary judgment because issue of whether employee’s Kemetic religious wrist tattoos would disrupt work or otherwise pose an undue hardship raised a disputed factual question to be decided by jury). [197] Wilson, 58 F.3d at 1341-42 (employer denied certain accommodation options because of demonstrated disruption to co-workers); Brown v. Polk County , 61 F.3d at 656-57 (there was insufficient evidence to establish that supervisor’s occasional prayers in writing, meetings posed an undue hardship because, although the employer asserted that the supervisor’s conduct had polarized employees along religious lines, it adduced no supporting evidence).

[198] EEOC Enforcement Guidance: Vicarious Employer Liability for Unlawful Harassment by Supervisors (1999), https://www.eeoc.gov/policy/docs/harassment.html. [199] U.S.F. Logistics (IMC) , 274 F.3d at 476 (employer reasonably accommodated plaintiff’s religious practice of sporadically using the phrase “Have a Blessed Day” when it permitted her to use the phrase with co-workers and supervisors who did not object, but prohibited her from paper payment using the phrase with customers where at least one regular client objected; allowing her to use the writing internet pdf phrase with customers who objected would have posed an undue hardship); Banks v. Serv. Am. Corp. , 952 F. Supp. 703 (D. Kan. 1996) (plaintiff food service employees at company cafeteria, who were terminated when they refused to stop greeting customers with phrases such as “God Bless You” and “Praise the Research paper payment Lord,” presented a triable issue of fact regarding whether they could have been accommodated without undue hardship; in the absence of employer proof that permitting the statements was disruptive or that it had any legitimate reason to fear losing business, a reasonable jury could conclude that no undue hardship was posed; the employer received only 20 to 25 complaints while serving approximately 130,000 to 195,000 customers, which is a complaint rate of between .01025 and .01923%; and writing, the employer produced no evidence of decreased use of the cafeteria or religious polarization among customers).

[200] See infra nn.201-203; see also Johnson v. Halls Merch. Paper Payment? , 1989 WL 23201 (W.D. Essay Pdf? Mo. Jan. 17, 1989) (court found it would have posed undue hardship on employer to paper, permit retail employee’s regular statement to customers “in the name of service editing Jesus Christ of Research paper Nazareth,” because it offended the beliefs of some customers and therefore cost the Writing essays for ap company business). [201] See Knight , 275 F.3d at 164-65 (allowing employee to evangelize clients would cause undue hardship). Paper Payment? Compare Baz v. Literary Anlaysis Paper? Walters , 782 F.2d 701 (7th Cir. 1986) (government hospital did not violate employee chaplain’s Title VII religious accommodation or First Amendment Free Exercise rights by terminating him for evangelizing patients; it would have posed an undue hardship under Title VII, and would have violated the Research paper First Amendment Establishment Clause, to permit chaplain to remain employed given his intention to minister to patients), with Rivera v. Help With? Choice Courier Sys., Inc., 2004 WL 1444852 (S.D.N.Y. June 25, 2004) (genuine issue of paper payment material fact existed as to whether courier was denied reasonable accommodation where employer could have accommodated courier’s need to evangelize by write hardship letter transferring him to a position with a less stringent dress code that would have allowed employee to payment, continue wearing a patch stating “Jesus is Lord”). [202] Moreover, a private employer’s own rights under the First Amendment Free Speech Clause may provide a defense to a Title VII accommodation claim, if the Help with writing message proposed accommodation would require the private employer involuntarily to display a religious message that could be construed as its own.

See also infra § IV-C-7. Similarly, if XYZ were a government employer, the First Amendment Establishment Clause would likely justify its refusal to display a religious message. However, Susan’s display probably would not violate the Establishment Clause, or pose an undue hardship for Title VII purposes, because it has a minimal effect on any co-workers who saw it, whereas Roger’s display might be perceived to constitute government endorsement of a particular religion and pose an Establishment Clause violation. See Berry v. Dep’t of Social Servs. , 447 F.3d 642 (9th Cir. Research Payment? 2006) (accommodating social worker’s request to display religious items in essay writing, his cubicle and to discuss religion with clients would have posed an undue hardship under Title VII on county social services department since the accommodations sought would create a danger of the employer violating the payment Establishment Clause); cf. Peloza v. Capistrano Unified Sch. Dist. , 37 F.3d 517 (9th Cir.

1994) (school district’s restriction on teacher’s First Amendment right of free speech in Help writing message, prohibiting teacher from talking with students about religion during school day was justified by school district’s interest in Research paper, avoiding Establishment Clause violation); Draper v. Logan County Pub. Library , 403 F. Supp. 2d 608 (W.D. Ky. 2005) (public library’s decision to bar employee from wearing necklace with cross was not justified by library’s purported interest in avoiding Establishment Clause violation; “[a] different conclusion might be justified, if for example, the library allowed employees to internet, actively proselytize or if it permitted religious banners or slogans to be hung from the Research paper payment rafters”). [203] Knight , 275 F.3d 156; Grant v. Fairview Hosp. Healthcare Serv., 2004 WL 326694 (D. Essays For Ap English? Minn. 2004) (ultrasound technician was offered a reasonable accommodation of his religious beliefs when hospital excused him from performing ultrasounds on women contemplating abortions; hospital did not have to allow technician to Research payment, provide pastoral counseling, as that accommodation would have posed an undue hardship); see also Grossman v. Writing Essays For Ap English? South Shore Pub.

Sch. Research Paper Payment? Dist. Writing English? , 507 F.3d 1097 (7th Cir. 2007) (affirming summary judgment for paper, school district on terminated guidance counselor’s First Amendment free exercise and Title VII claims, the court ruled that the Help school district was permitted to terminate counselor for paper payment, her conduct, even if her actions of praying with students who approached her for guidance and throwing away school contraceptive education materials were motivated by her religious beliefs; there was insufficient evidence that her termination was based on her religious views alone as opposed to Custom cheap, these actions, which the school district was entitled to prohibit). [204] See Townley, 859 F.2d at 619-21 (private employer has First Amendment free exercise right to express its religion in the workplace). [205] Young , 509 F.2d 140; see, e.g., EEOC v. Native Angels Homecare Agency , Civil Action No. 7:06-cv-83 (E.D.N.C. consent decree filed March 22, 2007) (settlement prior to Research payment, decision by court on the merits of Help with message claim alleging that a registered nurse was required to attend a “prayer circle” at Research paper payment work and was then terminated because she objected and refused to Custom writing, attend). [206] Townley, 859 F.2d at 620-21 (employer must accommodate an employee’s atheism; no undue hardship because excusing employee from Research payment services would not have cost anything nor caused a disruption; employer’s free exercise rights may be overridden where necessary to avoid religious discrimination in violation of Title VII). [207] Young , 509 F.2d 140 (employee was constructively discharged based on her religion in violation of Title VII where her superior advised her that she had obligation to consulting, attend monthly staff meetings in their entirety and advised her that she could simply “close her ears” during religious exercises with which meetings began). [208] Although it is beyond the scope of Title VII enforcement, we note for the sake of completeness that the U.S. Supreme Court has held that wreaths and Christmas trees are “secular” symbols, akin to items such as lights, Santa Claus, and reindeer, and thus that government display of these items does not violate the establishment clause of the First Amendment. See County of Allegheny v. ACLU , 492 U.S.

573 (1989) (stand-alone crèche on county courthouse steps violated establishment clause, but display elsewhere of Christmas tree next to Research paper payment, a menorah and Custom, a sign proclaiming “liberty” did not); Lynch v. Donnelly , 465 U.S. 668 (1984) (holding that government-sponsored display of crèche did not violate establishment clause because it was surrounded by various secularizing symbols, thus precluding a perception of government endorsement of religion); Federal Workplace Guidelines , supra n.11 at Section D (example (b)). For a discussion of both Title VII and establishment clause claims arising from holiday decorations in federal government employment context, see, e.g., Spohn v. Research Payment? West , 2000 WL 1459981 (S.D.N.Y. Oct. 2, 2000). In the private sector, establishment clause constraints would not apply. As a best practice, however, all employers may find that sensitivity to the diversity of their workplace promotes positive employee relations. [209] An employer may accommodate the employee’s religious belief by substituting an alternative technique or method that does not conflict with the Help with english writing message employee’s religious belief or by excusing the payment employee from that part of the training program that poses a conflict, if doing so would not pose an essays english undue hardship.

[210] Many employers have policies that require employees to treat each other with “courtesy, dignity and respect.” This terminology fits within the ambit of “professionally” as used in Research paper payment, the example. See also Peterson v. Hewlett-Packard Co. , 358 F.3d 599 (9th Cir. 2004) (it would have constituted undue hardship for employer to accommodate employee by eliminating portions of its diversity program to with english writing message, which employee raised religious objections; to do so would have “infringed upon the company’s right to promote diversity and encourage tolerance and good will among its workforce”). If training conflicts with an paper payment employee’s religious beliefs, the Writing english content of the training materials may be determinative in deciding whether it would pose an undue hardship to Research paper, accommodate an employee by excusing him from the training or a portion thereof. If the training required or encouraged employees to essay writing, value certain lifestyles or dimensions of diversity, it might be more difficult for an employer to establish that it would pose an undue hardship to accommodate an employee who objects to participating on religious grounds. Buonanno v. ATT Broadband, LLC, 313 F. Research? Supp.

2d 1069 (D. Colo. 2004) (company can require and instruct employees to treat co-workers with respect in writing internet pdf, accordance with corporate diversity policy, but violation of Title VII occurred where company did not accommodate employee’s refusal on religious grounds to sign diversity policy asking him to “value” homosexual co-workers, which he reasonably believed required him to subscribe to a certain belief system rather than simply agree to treat his co-workers appropriately). [211] Commission Guidelines , 29 C.F.R. Research Paper? § 1605.2. [212] EEOC v. WCM Enter., Inc. , 496 F.3d 393 (5th Cir.

2007) (evidence was sufficient for employee to proceed to trial on claim that he was subjected to Dissertation editing, hostile work environment harassment based on both religion and national origin where harassment motivated both by Research his being a practicing Muslim and by having been born in India); Vitug v. Multistate Tax Comm’n , 88 F.3d 506, 515 (7th Cir. 1996) (Catholic Filipino employee made out literary anlaysis use a prima facie case of national origin and payment, religious discrimination, although he did not prevail on the merits).