Edwards v. School Bd. of City of Norton, Va.

483 F. Supp. 620, 21 Fair Empl. Prac. Cas. (BNA) 1375, 1980 U.S. Dist. LEXIS 10406
CourtDistrict Court, W.D. Virginia
DecidedJanuary 18, 1980
Docket77-0057-B
StatusPublished
Cited by13 cases

This text of 483 F. Supp. 620 (Edwards v. School Bd. of City of Norton, Va.) is published on Counsel Stack Legal Research, covering District Court, W.D. Virginia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Edwards v. School Bd. of City of Norton, Va., 483 F. Supp. 620, 21 Fair Empl. Prac. Cas. (BNA) 1375, 1980 U.S. Dist. LEXIS 10406 (W.D. Va. 1980).

Opinion

MEMORANDUM OPINION

GLEN M. WILLIAMS, District Judge.

This action is brought by plaintiff to enforce the provisions of Title VII of the Civil Rights Act of 1964 as amended, 42 U.S.C. § 2000e et seq. Specifically, plaintiff contends that her employer, the defendant, *623 failed to accommodate her religious practices and, thereby, unlawfully discriminated against her under 42 U.S.C. § 2000e-2(a)(l). This court has jurisdiction over the dispute pursuant to 42 U.S.C. § 2000e-5(f)(3). A summary of the facts in this case is stated below:

I.

In September of 1967, plaintiff, Ruby Edwards, was first employed by defendant, the School Board of the City of Norton, Virginia, as a teacher’s aide in the Norton Elementary School. Sometime in 1968 plaintiff became a member of the Worldwide Church of God and this association became known to defendant.

As a member of this church, plaintiff felt church doctrine required her to abstain from secular work on seven annual holy days. 1 These holy days drew their basis from the Bible and were fixed in accordance with the Jewish calendar. Six of the seven holy days occurred during the school year and, thereby, required plaintiff to be absent from her job if the days did not fall on weekends. 2 However, plaintiff believed that the Feast of Tabernacles required her to attend an eight-day regional religious convocation during which she must abstain from secular work. Since this feast contained only two of the holy days, during any given school year plaintiff would be absent from her job from five to ten days for religious purposes. 3

During the 1968-69, 1969 — 70, and 1970-71 school terms, plaintiff requested and obtained permission to be absent from work to observe these holy days. In the fall of 1971 plaintiff was told by defendant that her absences for the holy days would no longer be allowed. It was explained to plaintiff that due to her changing responsibilities as a teacher’s aide, she would have to fulfill her 180-day contract. However, her yearly contract was renewed and she was allowed to take leave for the holy days.

Then, before signing her contract for the 1972-73 school term, plaintiff was made aware that the contract required 180 days of work and that defendant expected her to fulfill the obligation. However, after the school year started, plaintiff requested leave from work to attend the Feast of Tabernacles during September, 1972. The defendant denied plaintiff’s request and advised her that if she did take leave during this period that she would be dismissed. Plaintiff ignored defendant’s warning and missed six school days while attending the feast. Upon her return from the religious convocation, plaintiff was informed of her dismissal.

Plaintiff’s responsibilities as a teacher’s aide changed composition from 1968 to 1972. Initially, the job required plaintiff to collect lunch money, grade papers, supervise playgrounds, and work in the cafeteria. But, by 1972, the major thrust of the job required plaintiff to provide individual math and reading instruction to the students, especially the educable mentally retarded and slow learners.

Specifically, plaintiff was one of two teacher’s aides in an “open concept” educational unit consisting of a four-teacher team. The teacher-aide positions were created from federal funds that were designated to provide individual instruction to educationally deprived students. While subject *624 to the direction of the four teachers, the aides were to engage in no more than one hour of non-instructional activity per day. These teacher-aide jobs did not provide for vacation time, nor were substitutes available in the event that an aide was absent. It was while employed in this capacity that plaintiff was dismissed.

Based upon the above facts, plaintiff contends that defendant violated Title VII by failing to accommodate her religious practices. Defendant has countered plaintiff’s assertion by questioning whether her religious beliefs are cognizable under Title VII and, in the alternative, by arguing that because of the undue hardship that resulted from plaintiff’s religious practices, defendant was not required to make any accommodations to plaintiff.

II.

Under 42 U.S.C. § 2000e-2(a)(l), it is considered an unlawful employment practice for an employer to discharge any employee on the grounds of that individual’s religion. 4 In order to establish a prima facie case under this provision, plaintiff must prove three factors: (1) that she held a bona fide religious belief or engaged in a bona fide religious practice; (2) that defendant-employer had notice of plaintiff’s religious beliefs; and, (3) that plaintiff was discharged for refusing to comply with an employment requirement because it was contrary to her religious beliefs. See Brown v. General Motors Corp., 601 F.2d 956 (8th Cir. 1979); Burns v. Southern Pacific Transportation Co., 589 F.2d 403 (9th Cir. 1978); Anderson v. General Dynamics Convair Aerospace Division, 589 F.2d 397 (9th Cir. 1978); Redmond v. GAF Corp., 574 F.2d 897 (7th Cir. 1978). While there is no dispute that plaintiff satisfied the notice and basis of discharge requirements, defendant contends that it is not a bona fide religious practice to refrain from secular work on holy days.

Specifically, defendant argues that the church’s “Fundamentals of Belief” does not require a member to refrain from secular work on holy days. But, assuming that church “custom” requires a refrain from secular work on holy days, defendant also contends that only the first and last days of the Feast of Tabernacles are considered holy and, therefore, nothing forbids work during the intervening period. Hence, it is argued that plaintiff’s eight-day attendance at the Feast of Tabernacles was not a bona fide religious practice.

The Code broadly defines religion as “includpng] all aspects of religious observance and practice, as well as belief.” 42 U.S.C. § 2000e(j).

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Bluebook (online)
483 F. Supp. 620, 21 Fair Empl. Prac. Cas. (BNA) 1375, 1980 U.S. Dist. LEXIS 10406, Counsel Stack Legal Research, https://law.counselstack.com/opinion/edwards-v-school-bd-of-city-of-norton-va-vawd-1980.