Seventh Circuit Emphasizes Importance of Employers Grasping Religious Nature of Time-Off Requests and Properly Communicating With Employees in Order to Accommodate Appropriately

The Seventh Circuit Court of Appeal’s decision in Adeyeye v. Heartland Sweeteners, Inc.,1 reminds employers that a very broad definition of “religion” applies in Title VII religious discrimination cases. Given this broad definition, employers must be sufficiently alert to perceive, or at least to inquire about, the possible religious nature of employees’ accommodation requests – even when those requests do not contain the word religion. The Adeyeye decision also cautions employers to make careful, case-by-case determinations as to whether granting a religious accommodation would impose an undue hardship. The decision also makes it clear that an employer will not be reasonably accommodating an employee if all the employer offers is the opportunity to resign, fulfill a religious obligation, and then reapply if there happens to be an open position available.