Sikiru Adeyeye v. Heartland Sweeteners, LLC

721 F.3d 444, 2013 WL 3928168, 2013 U.S. App. LEXIS 15610, 97 Empl. Prac. Dec. (CCH) 44,874, 119 Fair Empl. Prac. Cas. (BNA) 680
CourtCourt of Appeals for the Seventh Circuit
DecidedJuly 31, 2013
Docket12-3820
StatusPublished
Cited by118 cases

This text of 721 F.3d 444 (Sikiru Adeyeye v. Heartland Sweeteners, LLC) is published on Counsel Stack Legal Research, covering Court of Appeals for the Seventh Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

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Sikiru Adeyeye v. Heartland Sweeteners, LLC, 721 F.3d 444, 2013 WL 3928168, 2013 U.S. App. LEXIS 15610, 97 Empl. Prac. Dec. (CCH) 44,874, 119 Fair Empl. Prac. Cas. (BNA) 680 (7th Cir. 2013).

Opinion

HAMILTON, Circuit Judge.

Title VII of the Civil Rights Act of 1964 prohibits discrimination in employment on the basis of religion. Among other consequences, the law requires a covered employer to provide a reasonable accommodation for an employee’s request te participate in a religious observance or practice if an accommodation would not cause the employer undue hardship. Plaintiff Sikiru Adeyeye made such a request to his former employer, defendant Heartland Sweeteners, LLC, after his father’s death. Adeyeye is a native of Nigeria who moved to the United States in 2008. He requested several weeks of unpaid leave so he could travel to Nigeria to lead his father’s burial rites. He explained to Heartland that his participation in the funeral ceremonies was “compulsory” and that if he failed to lead the burial rites, he and his family members would suffer at least spiritual death. Heartland denied Adeyeye’s request, but he traveled to Nigeria for the ceremonies anyway. He was fired when he returned and reported to work.

Adeyeye filed this suit under Title VII for failure to accommodate his religion. The district court granted summary judgment for Heartland, finding that Adeyeye’s two written requests did not present evidence sufficient for a reasonable jury to find that he had provided Heartland notice of the religious character of his request for unpaid leave. We disagree. Whether or not Adeyeye’s letters might have justified holding as a matter of law that they provided sufficient notice of the religious nature of his request (a question we do not decide), they certainly are sufficient to present a genuine issue of material fact regarding whether Heartland had notice of the religious nature of the request. We also find that genuine issues of material fact prevent us from affirming summary judgment on any of the other grounds argued by Heartland. We reverse the district court’s judgment and remand for fur *448 ther proceedings consistent with this opinion.

I. Religious Accommodation Claims Under Title VII

Title VII prohibits employers from discriminating against employees and job applicants based on their religion. 42 U.S.C. § 2000e-2(a). The statutory definition of “religion” in Title VII is drafted as an unusual blend. It combines a broad substantive definition of religion with an implied duty to accommodate employees’ religions and an explicit affirmative defense for failure-to-accommodate claims if the accommodation would impose an undue hardship on the employer. The statutory definition reads: “The term ‘religion’ includes all aspects of religious observance and practice, as well as belief, unless an employer demonstrates that he is unable to reasonably accommodate to [sic] an employee’s or prospective employee’s religious observance or practice without undue hardship on the conduct of the employer’s business.” 42 U.S.C. § 2000e(j).

United States v. Seeger provides a helpful definition of religion: The test “is whether a given belief that is sincere and meaningful occupies a place in the life of its possessor parallel to that filled by the orthodox belief in God.” 380 U.S. 163, 165-66, 85 S.Ct. 850, 13 L.Ed.2d 733 (1965). In interpreting what qualifies as religion under the broad statutory definition of Title VII, we have endorsed this standard that was used in Seeger to interpret the federal statute exempting conscientious religious objectors from military conscription, finding that the definition serves equally well for the purposes of Title VII. See Redmond v. GAF Corp., 574 F.2d 897, 901 n. 12 (7th Cir.1978) (explaining that a religious belief is a belief that is considered religious “in [the] person’s own scheme of things” and is “sincerely held”). The broad definition applies to all religious beliefs that are sincerely held: “In such an intensely personal area, of course, the claim of the registrant that his belief is an essential part of a religious faith must be given great weight.... The validity of what he believes cannot be questioned. Some theologians, and indeed some examiners, might be tempted to question the existence of the registrant’s ‘Supreme Being’ or the truth of his concepts. But these inquiries are foreclosed to Government.” Seeger, 380 U.S. at 184, 85 S.Ct. 850 (reviewing criminal convictions for men claiming conscientious objections to military conscription).

Thus, a genuinely held belief that involves matters of the afterlife, spirituality, or the soul, among other possibilities, qualifies as religion under Title VII. See Kaufman v. McCaughtry, 419 F.3d 678, 681 (7th Cir.2005) (“[W]hen a person sincerely holds beliefs dealing with issues of ultimate concern that for her occupy a place parallel to that filled by God in traditionally religious persons, those beliefs represent her religion.”) (internal quotations and ellipses omitted). 1 There are three factors to consider when determining whether a belief is in fact religious for purposes of Title VII: (1) the belief necessitating the accommodation must actually be religious, (2) that religious belief must be sincerely held, and (3) accommodation of the employee’s sincerely held religious beliefs must not impose an undue hardship on the employer. Redmond, 574 F.2d at 901 n. 12.

*449 To prove a Title VII claim for failure to accommodate religion, an employee must prove three things: (1) “the observance or practice conflicting with an employment requirement is religious in nature;” (2) the employee “called the religious observance or practice to [the] employer’s attention;” and (3) “the religious observance or practice was the basis for [the employee’s] discharge or other discriminatory treatment.” Porter v. City of Chicago, 700 F.3d 944, 951 (7th Cir.2012) (internal quotations omitted). If the employee shows these elements, the burden then shifts to the employer to show that it could not accommodate the employee’s religious belief or practice without causing the employer undue hardship. Baz v. Walters, 782 F.2d 701, 706 (7th Cir.1986). With these background principles in mind, we turn to the evidence Adeyeye presented to support his claim of religious discrimination based on the failure to accommodate his need to participate in burial rites for his father.

II. The Summary Judgment Issues

We review a district court’s grant of a summary judgment motion de novo. Porter, 700 F.3d at 950. The non-moving party is entitled to the benefit of conflicts in the evidence and all reasonable inferences that could be drawn in his favor.

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721 F.3d 444, 2013 WL 3928168, 2013 U.S. App. LEXIS 15610, 97 Empl. Prac. Dec. (CCH) 44,874, 119 Fair Empl. Prac. Cas. (BNA) 680, Counsel Stack Legal Research, https://law.counselstack.com/opinion/sikiru-adeyeye-v-heartland-sweeteners-llc-ca7-2013.