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How to and Dark Sides Eyre Essay Give Constructive Criticism: 6 Helpful Tips. “People seldom refuse help, if one offers it in the right way.” – A. Orestes? C. Benson. Have you ever given suggestions that were subsequently ignored? Have you ever given critiques that were not well received? Have you ever wanted to give constructive criticism on something, but held back from doing so because you did not know how to convey your intentions across? How to Give Constructive Criticism in 6 Steps.

Today’s guide is on Light and Dark Eyre, how to give constructive criticism to someone. Whether at work or in relationships, sharing and receiving feedback is part and parcel of improvement. Structures Essay? If you have ideas on how someone can improve, don’t hold your ideas back — rather, share your criticism constructively. Of course, to be sensitive to others’ emotions at the same time and only offer feedback when you feel the other person is Light and Dark of Jane Eyre ready to take it — otherwise, you may come across as imposing your opinions on Business Structures Defined Essay, others, especially if you repeatedly tell others what to do without them asking you for and Dark Sides Essay example your thoughts. 1. Use the Feedback Sandwich method. The feedback sandwich method is a popular method of the courtship lyon, giving constructive criticism. Example? It is gestational diabetes often used in Toastmasters and in the corporate environment.

I refer to the feedback sandwich as PIP, which stands for of Jane Eyre Essay Positive-Improvement-Positive. Frustration And Aggression: Strive Essay? I know there are people who use PIP to represent Praise-Improve-Praise which is different from my version of Light and Dark Sides Essay, PIP. Read on. With Positive-Improve-Positive , your feedback is broken down into 3 segments: You start off by focusing on the strengths — what you like about the troy (2004), item in question. Then, you provide the criticism — things you don’t like, the areas of improvement. Lastly, you round off the Light Sides example, feedback with (a) a reiteration of the positive comments you gave at the start and (b) the positive results that can be expected if the criticism is acted upon. It’s called the “feedback sandwich” because you wedge your criticism between an opening and Frustration and Aggression: Strive for Satisfaction Essay, an ending — like a patty wedged between two buns.

Here’s an example: you want to critique someone on their website. Here’s how PIP can be used: First layer, “P” for Light of Jane example Positive, where you talk about gestational what you like: “Great website! I love the overall layout and how user-friendly it is. The overall design is nice and pleasing to the eye, and consistent with your brand. The menu is very accessible and makes it easy to access your site sections. I found the intro video helpful in Light Eyre, giving me an overview of what you do.” Second layer, “I” for Improve, where you talk about the areas of improvement: “However, I thought that there are two things that can be better. Firstly, there is a lot of content in uk, the sidebar that clutters up the usage experience. Perhaps if the sidebar content can be narrowed down to the key things, it would make it easier to navigate. Secondly, the font size is and Dark Sides of Jane Eyre Essay example too small for solomonic me. I found it hard to read as I had to keep squinting.” Last layer, “P” for Positive, where you reiterate the Sides Eyre Essay example, positive points and the positive results to Business Structures Defined be expected when the improvement areas are worked on: “Overall, great work.

I love what you’ve done with the design, layout, and Light and Dark of Jane Eyre Essay example, intro video. I think if the sidebar clutter can be removed and the font size can be increased, it’d really create a fantastic usage experience for gestational diabetes uk any visitor.” The feedback sandwich is Light Sides Eyre example a good framework for providing constructive criticism because by starting off with the of mr lyon quotes, positive comments (the first “P”), you let the receiver know that you are on his/her side and you are not there to attack him/her . You are also recognizing things that the receiver is doing right, rather than only talking about the issue areas which can come across as being rude — especially if both of you don’t really know each other to begin with. The receiver then becomes more receptive to your critique (the “I” in PIP). After sharing the things you don’t like or feel can be improved, round off the criticism with more positive points (the last “P”).

This helps your critique end off on Light Sides example, a high note, rather than leaving the recipient with a sour taste in his/her mouth. It also reminds him/her what he/she is doing right and the courtship lyon, reinforces the benefits of acting on your critique. The feedback sandwich method is and Dark Sides of Jane example most appropriate when you are giving criticism to the courtship lyon people you don’t know or don’t know well. Otherwise you may come across as very aggressive and rude if you just jump right into the critique. This is especially true in the Asian culture. Light And Dark Of Jane Example? Over time though, you can go right into the critique if you have established a rapport with the recipient and he/she is familiar with the way you think. Some people may dislike using the feedback sandwich as they think it’s silly to praise for the sake of it.

But the point of the feedback sandwich isn’t to give false praise or to butter people up. People are often quick to criticize, judge, or even shame, and it downplays what others are doing well and the effort they have put into their work. I see the feedback sandwich as a great way to (a) practice emotional generosity, because we sure can work on being more generous in orestes, supporting people’s hard work, (b) help the person learn what he/she is doing well, and (c) use this as the foundation to Light and Dark share what can be improved on. 2. Focus on solomonic, the situation, not the person. Constructive criticism focuses on the situation, not the person. Example #1 : Giving feedback on a person’s presentation style. Bad example : “You’re really boring. You kept going on and on about a certain point even though we were running behind time; it made me want to fall asleep!” — While perhaps said with good intentions to help the person improve (though overly critical here, ouch ), this is Light and Dark of Jane example not exactly constructive criticism.

It makes a personal attack and makes it seem like he/she is the problem. Good example : [Apply the feedback sandwich first where you insert context and talk about the good points. Then, move on to the critique.] “… however, I thought some of the points could be delivered in a more concise manner. For example, the presentation allotted time is solomonic definition 30 minutes but we went over time by about 10 minutes, which is one-third of the intended time. Since there were 5 points, perhaps we could allocate 5 minutes per point, which would take up 25 minutes for and Dark 5 points, and then have 5 minutes left for closing? This would create a presentation that’s more well-paced.” — The situation is detached from the the courtship of mr lyon, person.

Critique is given on the situation itself. Example #2 : Giving feedback on Light and Dark Sides of Jane Essay example, a person’s character trait. Bad example : “You’re always so negative. Business Structures? It’s so draining to be around you.” — Like Example #1, this feedback makes a personal attack at and Dark of Jane Eyre, the person. It also does not tell the Business Structures Essay, person what he/she can do, which makes it unconstructive.

Good feedback : [Insert context first before going into critique.] “… there are times when I was hurt by the comments you made as they were somewhat demeaning. For example, the last time I had a haircut, one of the first things you said was how ugly I looked. That took me by Light Sides of Jane Eyre Essay example surprise and I felt quite down.” — While it’s tricky to Business Structures Essay give constructive criticism when it comes to someone’s personality, here it is successfully accomplished by separating the Light and Dark of Jane Essay, person’s actions from him/herself. This makes it easy to Strive Essay critique the Light Sides, behavior without offending the person in question. Some simple steps to apply this tip: Firstly, detach the situation from the the courtship, person . This distinction is crucial. Take the person out of the and Dark Eyre example, equation and focus on Business Structures, the behavior / action / situation / issue at and Dark Eyre, hand. Comment on Frustration for Satisfaction Essay, the issue, not the person . For example, “The clothes are dirty” and not “You are dirty.” “The report is late” and Light and Dark Essay example, not “You are late.” “The food is oily” and definition, not “You are a bad cook.” Don’t make personal attacks . Comments like “I’m so sick and and Dark Sides of Jane Essay, tired of…” or “You’re so stupid / negative / lazy / unorganized / ” come across as accusatory. Stay away from orestes attacks.

Don’t use active voice; use passive voice . Example of active voice vs. passive voice: “You gave a bad presentation.” vs. “The presentation you gave was bad.” Notice that the passive voice shifts the Light and Dark Sides example, attention away from the person and brings it to the subject matter. Strive For Satisfaction? Share how it affects you. And Dark Of Jane Essay Example? Rather than go on and on about how bad the thing is, share how it affects you. This shifts the focus away from the the courtship of mr lyon quotes, person and onto yourself, which lets the person take a step back to evaluate the situation. It also gives him/her insight to where you are coming from. The third tip to providing constructive criticism is to be specific. I receive a lot of feedback in running PE. The more specific someone is Sides of Jane Essay when giving the feedback, the more actionable it is for me.

Here is an example of a vague vs. specific feedback: Vague : “Hey Celes, I’d love it if you can write some articles on Business Essay, communication.” Specific : “Hey Celes, don’t know if you’re taking suggestions but if you do, I’d love some advice on public speaking.” The first feedback is and Dark Sides of Jane Eyre Essay very broad — “communication” is a very general topic. To attempt to write an article on “communication” will result in solomonic definition, a generic article which wouldn’t really help anyone. And Dark Example? While I can pinpoint some subtopics under communication like “networking,” “body language,” “small talk,” and “public speaking,” the subtopics I choose may not be what the and pylades, reader really wants, which then makes it a wasted effort.

With the second feedback, it is more actionable because it is Light and Dark Eyre example so specific. It tells me right away that “Hey, there’s a request for public speaking articles,” after which I can then plan for an article or series on public speaking. There is Business Structures Essay no confusion. That’s not to say that vague feedback is stupid or bad. It’s just that specific feedback helps me understand the user’s needs more easily, which makes it easy for me to serve his/her request. Likewise, it’s the same for you — if you want very actionable outcomes, if you want people to help you in a more targeted way, give specific vs. vague feedback.

Specific feedback that doesn’t target the person as I shared in tip #2. Here is another example of vague vs. Of Jane Essay? specific feedback. Say you’re giving feedback on a report: Vague : “Good effort on the report but I don’t like it. I think there is Frustration Strive room to be better.” — This feedback is hardly constructive. What do you mean by and Dark example “don’t like it”? “Like” and “dislike” are subjective words. Unless objective criteria is used, it’s hard for the person to decipher what is the Business Structures Defined Essay, problem. Specific : “Good effort but there are some things which can be improved – namely, (a) the formatting and (b) the final recommendations. The formatting is not standardized – there are some parts that uses Arial and other parts that use Times New Roman. Light And Dark Of Jane Example? In a formal report, it is best to orestes standardize the Light of Jane Eyre Essay, font.

For the Frustration Strive for Satisfaction, final recommendations, the ideas are good but they are too brief, especially ideas #1 and #3. The management would need more data to make their assessment.” — Great feedback that is specific. It tells the receiver the key problem areas, why they are problem areas, and specific incidences where they appear. Here’s how to make your feedback specific and hence actionable: Focus more on objective points than subjective opinions.

Just saying “I don’t like it” is not helpful. And Dark Of Jane Eyre? On the other hand, stating the specific things you do not like, is helpful. Troy (2004)? Break your feedback down into key points . Don’t give your feedback as one big lump. Of Jane Eyre Essay Example? Break it down into various key points, then give your feedback point by point. Give specific examples of orestes and pylades, each point . What are the exact situations or examples where the person exhibits the behaviors you highlighted in #2? Point them out. There is no need to Light of Jane Eyre highlight every single example – just pointing out 1-2 key examples per point will be sufficient. The intention here is to solomonic definition (a) bring the person’s awareness to things which he/she may be oblivious about and (b) illustrate what you mean. 4. Comment on things that can be actioned upon. The whole point of giving feedback is to help the person improve. Hence talk about things which the and Dark Sides of Jane Eyre example, person can do something about, rather than things that are out of his/her control.

Critiquing the orestes, former makes your criticism constructive; critiquing the latter just makes the person feel bad because he/she can’t do anything about it, even if he/she wants to. While you can make points on of Jane Essay example, latter especially if they are very crucial, balance things out by talking about Defined Essay things he/she can control. Let’s illustrate this with an example. Say your friend is in a singing competition and she has entered the finals. She asks you to critique her performance. Here, actionable critique would be comments regarding her overall performance, her pitch, her intonation, her gestures while singing, and perhaps even her song choice. On the Light and Dark Sides of Jane Eyre Essay, other hand, talking about how her voice is too husky/low probably isn’t too helpful because it’s not something she can change; if she can get into the finals, it probably isn’t a real “issue” to orestes and pylades begin with. Not only Light and Dark Eyre example, that, such a feedback is highly subjective. Gestational Diabetes Uk? There are people who like husky voices just as there are others who prefer other kinds of voices. While you can point out things you don’t like (say if you find her voice too husky), making it the center of your critique probably isn’t going to be very helpful for of Jane Eyre example your friend’s preparation.

In another example, say your friend just set up a new restaurant. He signs a lease for 12 months, and the location happens to have average human traffic. Definition? He then approaches you for advice to market his restaurant. Saying things like “change the location of your restaurant” really isn’t helpful at all, because the lease has already been signed. You can point out that location is critical and you’d recommend that he consider places with high human traffic for his next branch or if he’s open to Light Sides Eyre Essay changing his restaurant location before the lease ends, but focusing all your time to bash his “poor” location choice isn’t really going to help. Other unactionable critique includes saying that he should change his restaurant name or the decor especially if they have already been finalized and your critique is only based on the courtship of mr quotes, subjective thoughts vs. hard data. On the other hand, actionable critique would be to “invite food bloggers for Essay food tasting,” “do a media launch,” “give time-sensitive promotional discounts,” and “place advertisements in orestes, lifestyle magazines.” Knowing what’s actionable and unactionable requires you to be empathetic. Understand the person’s situation and his/her objectives, then provide your critique based on that.

5. Give recommendations on how to Sides of Jane Eyre Essay example improve. When all is said and done, give recommendations on what the person can do to improve. Firstly, your recommendations will tie up your critique in a nice bow. Everyone has varying perspectives, which means every critique can be interpreted in different ways. Giving recommendations will give the person a clear idea of what you have in mind. Structures Defined Essay? Secondly, recommendations provide a strong call-to-action. You want the person to act on what you have shared, not procrastinate. With your recommendations, I recommend to (a) be specific with your suggestions and (b) briefly explain the Light and Dark Sides Essay example, rationale behind the recommendation.

Example : Giving feedback on a presentation. Weak recommendation : “The presentation is too long. Make it shorter.” — Not very helpful. Reducing the presentation time can be done via many ways — cutting down the points, removing examples, talking faster, and so on. What exactly do you mean? Part of giving constructive criticism includes being specific (see Tip #3). Structures Defined? Good recommendation : “Instead of 2-3 examples per point which detracts from the Light Sides of Jane Eyre, main message, limit 1 example to orestes each point.

This way, the presentation is more succinct and impactful. Doing this, the presentation length will easily be reduced from 30 minutes to 20 minutes.” — Great recommendation that is specific. Of Jane Eyre Example? Rationale is also provided which explains your point of Frustration and Aggression: Strive Essay, view to the person. My final tip for Light Sides of Jane Eyre giving constructive criticism is not to make assumptions. When providing criticism, do so within what you know as fact about the the courtship of mr, person and the subject. Light Sides Of Jane Example? There’s no need to make any assumptions. Not only does it make the person look bad, it also makes you look bad — especially when your assumption is Business Structures Essay wrong. Here are 3 examples to highlight the difference between an Light Sides Eyre, assumption and a critique/comment:

Example #1 on public speaking: “The speech was mediocre. The speaker appeared nervous and was not able to lead the audience.” (Criticism) “The speaker never had any public speaking experience.” (This is an assumption and is not necessarily true. Seasoned public speakers can be nervous when giving speeches, especially in an new environment. To assume that someone doesn’t have any public speaking experience just because he/she appears nervous is quite pompous.) “This person speaks with an accent I’m not familiar with.” (Comment/Observation) “This person is not a native English speaker.” (Not necessary true. Just because you don’t recognize the accent or you can’t understand it as well doesn’t mean that English isn’t the person’s native language — it just means that you aren’t familiar with the accent. I find that people who are less traveled tend to troy (2004) think that anyone who doesn’t speak with an American accent is not a native English speaker, when there are many developed countries where English is their first language and the citizens are simply bilingual or trilingual.) “The new colleague seems to be anxious when around male co-workers. She keeps fidgeting and Light Sides Eyre example, she’s not able to troy (2004) articulate herself well.” (Comment/Observation) “The person was brought up in an all-girls environment.” (Assumption.

This is example not necessarily true. Anxiety around the opposite gender can happen to anyone.) As they say, when you assume, you make an “ASS out of U and ME.” I have people made assumptions about me before while giving feedback, and it creates an embarrassing situation when the assumptions turn out to Structures Essay be wrong, especially when they were bad assumptions. Not having a presumptuous attitude will go a long way in any communication, not just in Light of Jane, giving criticism. Check out the following related content: Hi!

I'm Celes. I write about personal development, relationships, productivity, career and more. Gestational? If you found this article helpful, join my free newsletter where I update you on my latest content and Light and Dark Sides of Jane Eyre Essay example, share messages that I don't post here. :)

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Nov 16, 2017 Light and Dark Sides of Jane Eyre Essay example,

Order Essay Writing from Our Custom Essay Writing Service - Chapter 16 - Cliffs Notes

42 Amazing Resume Tips That You Can Use in Light and Dark Sides Eyre, 30 Minutes [Examples] Maybe you’ve finished writing your resume, maybe you’re just starting. Either way, you could probably use some quick resume tips. What are the best tips for the courtship of mr lyon quotes writing a resume? It’s easy to overlook things when you’re worried about finding a job. Light Eyre Example. The best tips help you remember the of mr quotes, smallest details of resume writing. So, here are 42 of the best resume tips we could find for every step of the resume writing process. For your convenience, we’ve divided the tips into two , five , and thirty-minute tips . Next to each tip you will also see a star rating that ranks the tips in importance on a scale from one to five. Our five-star tips are those that we highly recommend every job seeker use especially if you don’t have time for Sides Eyre Essay anything else. These Resume Tips Will Take Two Minutes Tops.

1. Create a professional email address. Out of all of the resume tips listed, this may seem too obvious. But it’s worth mentioning because the troy (2004), use of an unprofessional email address will get you rejected 76% of the time. Light And Dark Of Jane Eyre Example. So, if you haven’t already done so, ditch that email address you’ve been using since high school. Choose a professional email provider like Gmail or Outlook. The Courtship. Use your name. 2. Update your contact information. After you change your email address, make sure the rest of your contact information is up to date. You don’t want to Light and Dark of Jane Essay example, miss an interview because you put the wrong phone number on diabetes, your resume. Also, exclude information like your birth date or marital status.

You do not have to respond to questions about and Dark Sides of Jane, religion, race, or gender on an application. Gestational Diabetes Uk. US employers cannot take these aspects into consideration when accessing you. If you’re applying for a job out of state or country, also consider omitting your current address. That way a hiring manager won’t think you’re confused about the location of the job. 3. Set your font size to 10-12 points. Light Of Jane. While choosing a font is important, making sure that it is the right size is paramount.

Keep your font size between 10-12 points so that a hiring manager can easily read it without squinting. For your education section, put your highest degree first. For your experience section, put your current job first. 5. Align your content to the left to make it skimmable. The first thing a hiring manager is going to do is diabetes skim your resume for relevant keywords from the job description. Aligning your text to and Dark Sides of Jane example, the left makes this easier for them to Essay, do. 6. Make strategic use of bold, caps, and italics. Be consistent with your choices.

If you’ve made one of your subheadings bold - make them all bold. Try not to overuse anything. The point is to make important information easier to find. Light And Dark Example. 7. Choose an attractive and readable font. You may think fonts are trivial in the larger scheme of things, but the right font is going to do a lot for your resume.

Stick to fonts that sound like the names of hipster children: If you choose a font that is hard to read or childish, a hiring manager might toss your resume in the trash. 8. Only add jobs you’ve had in the past 10-15 years. You do not need to list every job you’ve ever had on the courtship lyon quotes, your resume. Make sure that every job you have added was a job you held in the last 10 or 15 years. 9. Give your sections simple subheadings.

Regardless of Light and Dark Sides of Jane Essay, what layout you choose, make sure your sections are visible and orestes easy to find. Light And Dark Essay Example. You can do that by giving them simple subheadings. You’ll want to write simple subheadings for all sections. That way Applicant Tracking System (ATS) software can find them. Pro Tip: Deciding what skills to put on your resume is one of the biggest tasks that lie ahead of new resume writers. Make sure that they are easy to find and easy to troy (2004), skim as well.

10. Include URLs to social media profiles, personal websites, and and Dark Eyre Essay example your blog. If you have a professional website or blog, take a moment to include the URL in Business, your contact section. Light And Dark Sides Of Jane Eyre Essay Example. Add any relevant social media handles as well. For most professionals, that will include your LinkedIn URL and orestes your Twitter handle. Creative professionals could also consider adding relevant links to Instagram, Youtube, or Pinterest profiles. Take an extra couple of minutes to make sure that your URLs are live and to Sides Eyre example, hyperlink them in the text so they are accessible.

11. Choose a resume format that works for you. Troy (2004). What are the best formats for a resume? Well, that depends. There are three types of resume formats: Reverse-chronological Combination Functional or Skills-based. Most of you will opt for and Dark Sides of Jane Eyre the reverse-chronological format . It’s the Business Structures Essay, most common and you can play with the layout. In almost every situation, the functional resume format is not a good choice because it kills your experience section. And even if you don’t have experience, that’s not the Light Sides Essay example, best way to handle it. Solomonic Definition. Pro Tip: Consider a format that gets your strongest information closest to Light and Dark Essay example, the top of your resume where hiring managers will be sure to see it right away. 12.

Consider using a professionally designed template. Templates can save you a lot of time and effort. Imagine not having to the courtship of mr, fool around with margins in Word. Pick one out, and you’re ready to go. 13. Consider putting your education section first. Once you’ve chosen a format, it’s a good idea to make a quick decision about the layout. How do you build a strong resume? After your contact information , start your resume with either a resume summary or a resume objective . More on Light and Dark Eyre Essay, that later. And Pylades. But what should come next?

Your education or your experience section? If you’re a professional with tons of experience , your experience should come first. But let’s say you’re a student and your educational background is your strongest selling point. In that case, consider putting your education section first. 14. Lose the phrase “References Available Upon Request.” It is no longer necessary to place this phrase at the bottom of and Dark Essay example, your resume, as hiring managers know that they can request your references. Adding it only takes up valuable space that you could use for and pylades something else. Only Have Five Minutes? Here are the of Jane Eyre, Best Resume Tips. 15. Read the job description and then read it again.

Okay, reading the job description may sound like one of the most obvious resume tips ever. Of course, you’ve read the job description. Right? In fact, most people spend an average of 76 seconds reading a job description. And that’s why hiring managers find that 50% of troy (2004), applicants are unqualified for the job.

You’ve got to make sure you have the skills necessary for the job in the first place. Light And Dark Essay Example. Read the and Aggression:, job description. Make sure you’re qualified. Read it again. Mine it for keywords. Put it through a cloud generator. Take it on a date. And Dark. Buy it Tiffany’s. Get married to it.

Because that job description is your best friend when it comes to building a great resume. Seeing a job title that sounds right, sending your resume immediately. Reading a job description is as close as you’re going to get to reading the recruiter’s mind. 16. Make sure you’ve created margins. Margins are important. That’s because resumes with text crammed edge to edge look messy and unprofessional. Do you know where messy resumes go?

You know. If you do need a little more space, it’s okay to drop your bottom and top margins to 0.5” and your side margins to 0.75”. Anymore and solomonic definition you’re resume will suffer. 17. Balance your text and white space. Balancing your text and white space is the Light Eyre Essay example, same thing as adding margins. It makes your resume aesthetically pleasing and easy to read. Do not sacrifice white space in the name of fitting everything onto troy (2004) one page. There are other ways.

18. Consider adding a coursework description. Light And Dark Of Jane Eyre Essay Example. This is one of the orestes and pylades, best resume tips for students. If you’re learning how to make a student resume , adding a coursework description is and Dark of Jane Essay example a good start. Your education is still your strongest asset. Essay. Listing or describing courses can show recruiters that you have skills related to the job. Coursework descriptions can also benefit professionals who are making a career change. It shows that you’ve got relevant knowledge that goes beyond your past work experience. It is important to name your files properly. And Dark Sides Of Jane Eyre Example. Your resume could end up in an inbox with hundreds of the courtship of mr quotes, other resumes. And if they’re all named “ resume ,” then the chance of your resume standing out is slim to none.

20. Match your cover letter to your resume. The two best cover letter tips are: Write a cover letter. Match the content of Sides of Jane Eyre Essay, your cover letter to your resume. Yes, you still need to write cover letters . And yes, they need to and pylades, match your resume so that you’re telling the Light Sides Essay example, hiring manager one cohesive story. Definition. If there was something you feel needs an explanation, write about it in Light and Dark Sides of Jane example, your cover letter. 21. Draw attention to your promotions. Orestes And Pylades. Make sure you’ve mentioned any promotions you’ve received. You don’t have to list the name of the company more than once in the case of internal promotions.

Write the name of the company once. Then list your various titles with their accompanying responsibilities. Light And Dark Sides Of Jane Eyre Essay. 22. Cut the fluff in definition, your experience section. Light And Dark Sides Of Jane Eyre Essay. Is your resume is a bit longer than the recommended length for resumes (one to troy (2004), two pages)? Then an easy way to cut fluff is to start by deleting bullet points in your experience section.

Limit yourself to around six bullet points. List responsibilities that demonstrate the skills and experience you’ll need for your new job. Also, consider listing responsibilities that you can illustrate with achievements. And Dark Sides Eyre Example. Don’t list every responsibility you had at previous jobs. 23. Write explanations for large gaps in your career history. Diabetes. Address significant gaps in your career history by and Dark example writing brief explanations next to the jobs where the gaps occur.

Gaps can happen for all sorts of reasons. Orestes. A brief explanation will reassure recruiters that it was unintentional or beneficial for Light and Dark of Jane Eyre Essay you. As in the case of a layoff or a break to have a child or go back to school. Orestes And Pylades. 24. Insert action verbs wherever possible. Take a quick glance at your resume. How many times have you used the phrase “ responsible for and Dark Sides of Jane Essay ?” A million? It’s not uncommon. The good news is that it only takes five minutes to solomonic, replace that sad phrase with action-packed verbs . Using action verbs as often as possible is one of the best resume tips out there. Remember, not all verbs are action verbs. Try to avoid weak verbs like “ managed ” or “ communicated. ” Here are some alternatives: The person interviewing you may not be familiar with the technical jargon that goes with your territory.

Especially if you are in a jargon-heavy industry such as engineering, law, or medicine. Try to Light and Dark of Jane Eyre Essay, use layman’s terms or simplified equivalents wherever possible. Wrong: Dramatically cloudify viral innovation. Right: Create digital backups for popular campaigns. 26. Run your job description and resume through a cloud generator. Troy (2004). Before you start writing, run your job description through a cloud generator. Light And Dark Of Jane Essay. Which words are the most prominent? You can use the words that appear as a content guide while writing your resume.

When you’re finished writing, send your resume through the cloud generator. Do the same words appear? A cloud generator is a quick way to check that you’ve tailored your resume to meet the needs of the hiring manager. Frustration And Aggression: Strive For Satisfaction Essay. 27. Consider saving a copy of your resume as a PDF. Saving your resume as a PDF is one of those resume tips that might not work for everyone. The benefit of saving your resume as a PDF is that the formatting will not change when it’s opened. Light And Dark Sides Of Jane Essay. The downside is that if a company is troy (2004) using ATS, a PDF might not be the best format for Light and Dark Sides Essay example your resume. Diabetes. Pro Tip: It’s often best to save your resume in a couple of Light and Dark Sides of Jane, file formats so you can send whatever is more suitable.

It’s up to you to decide. And Aggression: Strive. These Resume Tips Take 30 Minutes, But They’re So Worth It. And Dark. 28. Tailor your resume to the job description. You do that by identifying keyword skills in the courtship quotes, the offer and then add these skills throughout your resume. It sounds like a lot of work, but these keywords are what you should put on your resume above all else. That’s because keywords are what hiring managers are looking for when they scan your resume. 29. Add achievements to your experience section. If tailoring your resume to the job description is the king, adding achievements is the queen of resume tips. Illustrating a skill or responsibility with an achievement puts you five steps ahead of candidates with the same skill set.

That’s because you’re showing what it looks like when you put your skills to work. Light And Dark Of Jane Essay. To generate user engagement , I performed multiple A/B tests , resulting in a 20% decrease in bounce rates and a 15% increase in sales conversions . Troy (2004). I won an employee of the year award. 30. Add numbers and details where possible. Light Eyre. Adding numbers and details to emphasize skills is by far one of the troy (2004), best resume tips you can follow. Anytime you can illustrate an and Dark Sides of Jane Essay achievement or skill with numbers or details - do it. Responsible for troy (2004) sales.

Numbers draw the eye of the recruiter and details give them a tangible sense of what it looks like when you use a skill. Maybe you increased sales, efficiency, or user engagement. Maybe you slashed costs. Whatever it is and Dark of Jane example that you’ve achieved try to make it quantifiable. 31. Make good use of the troy (2004), top third of your resume. Think of the top third of your resume and Light of Jane Eyre Essay example “the penthouse.” It’s here that you want your best skills, experience, and achievements to appear. Try to troy (2004), put the best stuff at the top.

Because when a recruiter scans your resume, they will focus on the top third of the document. And Dark Sides Of Jane Eyre Example. If they don’t find what they’re looking for in a few seconds of scanning, they will reject your resume as irrelevant. 32. Include a resume summary or objective. So, how do you get your best information in the top third of your resume? Include a resume summary or a resume objective.

It’s three sentences of who you are, where you’re going, and why you’ll bring value to Defined Essay, the company. Dedicated Sales Manager seeking fulfilling work in children’s retail sector. Dedicated Sales Manager with 5+ years of experience in the retail industry. Wishing to decrease returns for PeaPod Babywear by 15%. 33. Use a proofreading tool like Grammarly. Light And Dark Sides Of Jane Eyre Essay Example. You cannot afford to Business Structures Defined Essay, have typos or grammar errors in your resume. The majority (61%) of recruiters will throw out a resume immediately if they see typos. Microsoft Word or Google Docs will do a good job of detecting spelling errors, but the Grammarly app or Language Tool will catch grammar mistakes and Light and Dark Eyre Essay example typos. You need to proofread your resume before sending your resume, and definition an app will help you catch things you can’t see.

34. Have a human proofread your resume. Apps are great for catching mistakes, but another human being is priceless. Grab whoever you can find with the Light and Dark Sides of Jane Essay example, patience to read through your resume. They can also give you feedback about your tone and how you’re selling yourself. It’s not always enough to write a great resume and ace an interview.

The show isn’t over until you’ve also written a thoughtful thank-you email. When you’re just learning how to of mr, create a resume , you may forget that hiring managers also search for you online. Light. Make sure that you’ve cleaned up “public” information on your Facebook and Structures Essay Twitter accounts. Of Jane Eyre Example. Change your Facebook privacy settings to “Friends” to keep future posts from becoming public. And do a quick sweep to troy (2004), make sure nothing else unsavory is lurking out Light and Dark Sides of Jane Essay there on uk, the Internet. Enter your name into Google and see what turns up in the results. 37.

Create a professional persona for Light of Jane Essay yourself. A professional persona is Defined Essay a two or three-word description of Light Sides of Jane Eyre Essay, yourself that should stick in the head of the recruiter when your name doesn’t. It’s like when you try to describe someone from Business Defined Essay, last night’s party. Eyre. Remember the girl who graduated from Harvard and talked about goat cheese for an hour? It’s like that except less goat cheese.

38. Reinforce your professional titles by showing career progression. Putting a bunch of flashy titles on your resume isn’t the most impressive thing you can do believe it or not. What is impressive is the orestes, telling the story of your career progression . And Dark Eyre Essay Example. See, you can be a social media manager for Frustration Strive for Satisfaction Essay your cousin’s pizza place without any prior experience. But when you can show that you progressed to that position through hard work, that’s impressive. The trick is trying to Light of Jane Eyre Essay example, make each past role reinforce your place in and pylades, the next one. Planned and implemented promotional campaigns. Cooperated with interactive agencies. Conducted market research. Assisted during promotional campaigns . 39. Consider adding a Hobbies and Interest section to your resume.

That’s because companies are beginning to emphasize work culture . Which makes finding a candidate with a fitting personality increasingly important. Just be sure to and Dark Sides example, research your company. Choosing hobbies and interests that match the company’s culture is a good strategy. Work Culture: Corporation participates in charity marathons. Hobbies and Interests: Volunteer Work and Athletics. Religious, political, or sexual hobbies.

If the person reading your resume has an opposite the courtship lyon quotes opinion, it could hurt your chances of Light of Jane Eyre Essay example, getting an interview. 40. The Courtship Of Mr. Trim any unnecessary fat from your resume. Having problems keeping the length of your resume in check? You will want to trim the fat: Make sure every word you’ve used is necessary. Keep your bullet points to six at most. Trim your resume summary or your skills section without killing the value. And kill any extra sections that aren’t mandatory. 41. Try to Light and Dark Essay example, find the personal email address of the hiring manager. You can always attach your resume to a generic email and send it to a generic inbox.

Or you can attach your resume to a personalized email and gestational diabetes uk send it to your hiring manager. Some hiring managers may not appreciate receiving unsolicited resumes. Of Jane Eyre Example. At the gestational uk, same time, if you know how to send an email to a hiring manager you know that you aren’t sending it unannounced. You establish contact via a referral or LinkedIn before sending your resume. Sending a cold-call email to an unknown hiring manager. Instead of waiting around for a phone call, track your email so that you know the Light and Dark Sides of Jane example, moment a hiring manager opens it. You can use a free tool like Mixmax to see if a hiring manager has read your resume.

That give you a better idea of gestational uk, when to send follow-up or thank you emails. It can be easy to forget small details when you’re trying to figure out how to write a great resume. But if you follow these resume tips and tricks you can rest assured that you’re on the right track. Always take the time to check your resume. Can you think of any more quick resume writing tips that we forgot? What are some little-known resume tips you can share?

Let us know in the comments. Natalie is a writer at Uptowork. She loves writing about and Dark Sides of Jane Eyre Essay example, resumes and eating tacos more than life itself. She spends her free time reading complicated novels and binge watching TV series.

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compliance resume SUBJECT: EEOC COMPLIANCE MANUAL. PURPOSE: This transmittal covers the and Dark Sides example issuance of orestes and pylades Section 12 of the new Compliance Manual on “Religious Discrimination.” The section provides guidance and instructions for investigating and Light and Dark Sides of Jane Eyre example, analyzing charges alleging discrimination based on 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 Structures Essay Goldman v. Light Sides Of Jane Essay! Weinberger (Accommodation of the Wearing of Religious Dress) . The Commission’s Guidelines on gestational Discrimination Because of Essay example 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 religious discrimination under Title VII of the Structures Essay 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. Solely with respect to example religion, Title VII also requires reasonable accommodation of of mr lyon quotes 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 employers to 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 and Dark of Jane example discrimination and the requirement of reasonable accommodation apply whether the religious views in question are mainstream or non-traditional, and even if not recognized by any organized religion. These protections also extend to those who profess no religious beliefs. [6] Questions about religion in the workplace have increased as religious pluralism has increased.

In a 2001 survey of human resource professionals conducted by lyon quotes 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 Light Sides, 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 such charges remains relatively small compared to troy (2004) charges filed on Light and Dark Sides of Jane Essay 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 orestes Compliance Manual is designed to be a practical resource for employers, employees, practitioners, and EEOC enforcement staff on Light of Jane Eyre Title VII’s prohibition against of mr quotes, religious discrimination. Of Jane Example! The Section defines religious discrimination, discusses typical scenarios in which religious discrimination may arise, and troy (2004), provides guidance to employers on how to balance the needs of individuals in a diverse religious climate. [10] The Section is organized by legal topic, as follows: I - Coverage issues , including the definition of “religion” and “sincerely held,” the and Dark Sides of Jane Eyre religious organization exception, and the ministerial exception. II - Disparate treatment analysis of gestational employment decisions based on religion, including recruitment, hiring, promotion, discipline, and compensation, as well as differential treatment with respect to religious expression; customer preference; security requirements; and Light and Dark Sides example, bona fide occupational qualifications. III - Harassment analysis , including religious belief or practice as a condition of orestes employment or advancement, hostile work environment, and employer liability issues.

IV - Reasonable accommodation analysis , including notice of the Light of Jane Eyre Essay example conflict between religion and work, scope of the the courtship accommodation requirement and undue hardship defense, and common methods of accommodation. V - Related forms of Light and Dark Sides Eyre Essay example 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 Business Structures Essay 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 Light and Dark Sides Essay Free Exercise or Free Speech Clauses would be violated if it is compelled by the courtship lyon quotes Title VII to grant a particular accommodation. [13] In addition, government employees often raise claims under the Light Eyre Essay example First Amendment parallel to quotes their Title VII accommodation claims. [14] Defining the 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. Sides Eyre Essay! [15] Title VII prohibits covered employers, employment agencies, and unions [16] from: (1) treating applicants or employees differently (disparate treatment) based on their religious beliefs or practices or lack thereof in any aspect of employment, including recruitment, hiring, assignments, discipline, promotion, and orestes, benefits; (2) subjecting employees to harassment because of their religious beliefs or practices or lack thereof or because of the religious practices or beliefs of and Dark Sides of Jane Essay example 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 the courtship of mr, accommodation will not impose an undue hardship on the conduct of the business; [17] and, (4) retaliating against an applicant or employee who has engaged in protected activity, including participation ( e.g. , 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 Light Sides of Jane Essay 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 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 definition, analyzed under all four theories of Light Eyre Essay example liability to the extent applicable, even if the charging party only Frustration and Aggression: Essay, 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 Sides a few or even one individual; however, mere personal preferences are not religious beliefs. Title VII requires employers to troy (2004) accommodate religious beliefs, practices, and observances if the beliefs are “sincerely held” and the reasonable accommodation poses no undue hardship on Light and Dark of Jane Essay 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 subscribed to by a small number of people, or that seem illogical or unreasonable to others. [20] Further, a person’s religious beliefs “need not be confined in either source or content to traditional or parochial concepts of religion.” [21] A belief is troy (2004), “religious” for 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 Light of Jane that filled by God.” [23] An employee’s belief or practice can be “religious” under Title VII even if the employee is solomonic, 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 Light and Dark Sides of Jane example what is right and wrong which are sincerely held with the strength of traditional religious views.” [25] Although courts generally resolve doubts about solomonic 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 and Dark Sides Eyre example “life, purpose, and death.” [27] Social, political, or economic philosophies, as well as mere personal preferences, are not “religious” beliefs protected by gestational diabetes Title VII. [28] Religious observances or practices include, for example, attending worship services, praying, wearing religious garb or symbols, displaying religious objects, adhering to Light Eyre Essay example certain dietary rules, proselytizing or other forms of religious expression, or refraining from certain activities. Troy (2004)! Determining whether a practice is religious turns not on the nature of the activity, but on and Dark Sides Essay the employee’s motivation. The same practice might be engaged in by one person for religious reasons and by 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 of mr quotes, secular ( e.g. , health or environmental) reasons. [30] In that instance, the same practice might in one case be subject to reasonable accommodation under Title VII because an employee engages in the practice for religious reasons, and in Light and Dark Eyre Essay example, 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 a self-described evangelical Christian. A qualified non-Jewish employee is denied promotion because the supervisor wishes to give a preference based on troy (2004) religion to a fellow Jewish employee. An employer terminates an employee based on his disclosure to Light and Dark Eyre example 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 troy (2004) applicant or employee, and therefore is based on “religion” within the meaning of 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 Light Eyre Essay example life thereof, which is the blood thereof, shall ye not eat,” (Genesis 9:4). Her vegetarianism is solomonic, a religious practice, even though not all Seventh-day Adventists share this belief or follow this practice, and 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. 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 Sides Essay, exception allowing her to solomonic wear her bindi (religious forehead marking). An atheist asks to be excused from the religious invocation offered at Sides of Jane, the beginning of staff meetings. An adherent to Native American spiritual beliefs seeks unpaid leave to attend a ritual ceremony. An employee who identifies as Christian but is 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 orestes meaning of Title VII. Light And Dark Sides Eyre Essay! By contrast, a request for a schedule change to help set up decorations or prepare food for a church event, for solomonic definition, instance, typically does not involve a “religious” belief or practice within the and Dark example meaning of Title VII. [31] Supervisor Considers Belief Illogical. Morgana asks for time off on October 31 to solomonic definition attend the “Samhain Sabbat,” the and Dark Eyre New Year observance of Wicca, her religion. Her supervisor refuses, saying that Wicca is not a “real” religion but an “illogical conglomeration” of “various aspects of the and Aggression: 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 affiliates himself with a tribe numbering fewer than ten members.He states that he believes in Light and Dark of Jane Eyre, various deities, and follows the faith’s concept of troy (2004) Ma’at, a guiding principle regarding truth and order that represents physical and and Dark Sides, 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 the courtship quotes Egyptian god of the and Dark Sides Eyre example sun. When his employer asks him to cover the tattoos, he explains that it is a sin to cover them intentionally because doing so would signify a rejection of gestational Ra. These can be religious beliefs and practices even if no one else or few other people subscribe to them. [33] Personal Preference That is Light and Dark Sides of Jane Eyre, 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. And Pylades! Sylvia says that her tattoos and piercings are religious because they reflect her belief in body art as self-expression and should be accommodated.

However, the Light and Dark Sides of Jane Eyre example 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 troy (2004), wrong, and Sides of Jane Essay, they are not part of a moral or ethical belief system. Quotes! Therefore, her belief is a personal preference that is not religious in Light Sides of Jane Eyre, nature. Of Mr Quotes! [34] Title VII requires employers to 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 Light Eyre Essay example, only relevant to religious accommodation, not to Frustration claims of and Dark of Jane Essay disparate treatment or harassment because of 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. Frustration! A detailed discussion of reasonable accommodation of sincerely held religious beliefs appears in Eyre Essay example, § IV, but the meaning of “sincerely held” is addressed here. Like the and pylades “religious” nature of a belief or practice, the Sides of Jane “sincerity” of an employee’s stated religious belief is usually not in dispute. Nevertheless, there are some circumstances in troy (2004), which an Light and Dark Sides, employer may assert as a defense that it was not required to solomonic definition 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 religious belief at issue include: whether the employee has behaved in a manner markedly inconsistent with the and Dark of Jane Eyre professed belief; [36] whether the accommodation sought is a particularly desirable benefit that is Frustration Essay, likely to Light and Dark Sides Eyre be sought for secular reasons; whether the timing of the request renders it suspect ( e.g. , it follows an earlier request by the employee for diabetes, the same benefit for secular reasons); and whether the employer otherwise has reason to believe the accommodation is Light of Jane Eyre, not sought for religious reasons. The Courtship Of Mr! However, none of Light and Dark of Jane Eyre Essay these factors is dispositive. For example, although prior inconsistent conduct is relevant to the question of sincerity, an of mr quotes, individual’s beliefs or degree of adherence may change over time, and therefore an Light and Dark Sides Eyre Essay, employee’s newly adopted or inconsistently observed religious practice may nevertheless be sincerely held. [37] An employer also should not assume that an employee is insincere simply because some of Structures Defined Essay his or her practices deviate from the Sides of Jane example commonly followed tenets of his or her religion. [38] 3. Business Structures Essay! Employer Inquiries into Religious Nature or Sincerity of Light Eyre Essay example Belief. Because the definition of troy (2004) religion is and Dark Sides of Jane example, broad and protects beliefs and practices with which the quotes 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 employee requests religious accommodation, and an employer has an objective basis for questioning either the religious nature or the sincerity of a particular belief or practice, the employer would be justified in seeking additional supporting information. 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. And Dark Sides Eyre Essay Example! What religious belief or practice does the CP claim to 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 of mr lyon quotes investigator may need to ask follow-up questions about the nature and of Jane Essay, 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 solomonic an individual, evidence from others is not always necessary. And Dark Sides! However, if the 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 alleged religious practice or belief is at issue, a case-by-case analysis is required. Investigators should not make assumptions about a religious practice or belief. In some cases, to definition determine whether CP’s asserted practice or belief is “religious” as defined under Title VII, the Light of Jane Eyre investigator’s general knowledge will be insufficient, and additional objective information will have to be obtained, while nevertheless recognizing the intensely personal characteristics of and Aggression: for Satisfaction Essay adherence to a religious belief. If the Respondent disputes that CP’s belief is “sincerely held,” the following evidence may be relevant:

Oral statements, an and Dark of Jane Eyre example, 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 and pylades the belief or practice; and/or, Oral statements, affidavits, or other documents from and Dark example, potential witnesses identified by CP or R as having knowledge of whether CP adheres or does not adhere to definition 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 Eyre Essay all religious discrimination claims under the statute. However, specially-defined “religious organizations” and “religious educational institutions” are exempt from certain religious discrimination provisions, and a “ministerial exception” bars Title VII claims by employees who serve in clergy roles. Title VII’s prohibitions apply to lyon quotes 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 provide reasonable accommodation unless doing so would impose an and Dark Eyre, undue hardship. [40] Unions also can be liable if they knowingly acquiesce in Frustration and Aggression: Strive Essay, employment discrimination against their members, join or tolerate employers’ discriminatory practices, or discriminatorily refuse to represent employees’ interests. Light Sides Of Jane Essay! [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 Strive, dispositive, significant factors to Light and Dark Eyre Essay example 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 orestes a church or other religious organization? [45] This exception is not limited to Eyre 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 discriminate in employment on 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 of mr quotes, racially discriminatory hiring by asserting that a tenet of and Dark Sides Eyre Essay its religious beliefs is not associating with people of gestational other races. Light Sides Eyre Essay Example! Similarly, a religious organization is not permitted to deny fringe benefits to married women but not to married men by 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. Tots is orestes, 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 the primary providers for their families. Believing that men shoulder a greater financial responsibility than women, the and Dark Eyre Essay example organization pays female teachers less than male teachers. Uk! The organization’s practice of unequal pay based on and Dark of Jane Essay example sex constitutes unlawful discrimination. [49] Courts have held, based on First Amendment constitutional considerations, that clergy members cannot bring claims under the Frustration for Satisfaction Essay federal employment discrimination laws, including Title VII, the Age Discrimination in Employment Act, the Equal Pay Act, and the Americans with Disabilities Act, because “[t]he relationship between an organized church and Sides Essay, 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 gestational uk free exercise of religion and constitutes impermissible government entanglement with church authority. [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. Of Jane! [52] The ministerial exception applies only to troy (2004) those employees who perform essentially religious functions, namely those whose primary duties consist of engaging in Light Eyre example, church governance, supervising a religious order, or conducting religious ritual, worship, or instruction. [53] The exception is lyon, 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. However, the Light and Dark of Jane example exception does not necessarily apply to solomonic everyone with a title typically conferred upon Light of Jane Eyre Essay, clergy ( e.g. , minister). The Courtship Of Mr Lyon! [55] In short, in each case it is necessary to make a factual determination of whether the Light Sides of Jane Eyre example function of the position is one to 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 his religious beliefs, practices, or observances or lack thereof. Thus, for example, except to the extent permitted by the religious organization and ministerial exceptions, an employer may not refuse to recruit, hire, or promote individuals of a certain religion, may not impose stricter promotion requirements for solomonic definition, persons of a certain religion, and Light Sides of Jane Eyre, may not impose more or different work requirements on an employee because of that employee’s religious beliefs or practices. Uk! [56] The following sub-sections address work scenarios that may lead to claims of religious discrimination. 1. And Dark Sides Of Jane! Recruitment, Hiring, and Promotion. Employers that are not religious organizations may neither recruit individuals of solomonic definition a particular religion nor adopt recruitment practices, such as word-of-mouth recruitment, that have the and Dark example purpose or effect of discriminating based on religion. Title VII permits employers that are not religious organizations to hire and employ employees on the basis of 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 hire an applicant simply because he does not share the Frustration and Aggression: Strive for Satisfaction employer’s religious beliefs, and conversely may not select one applicant over of Jane Essay example, another based on quotes a preference for employees of a particular religion. [58] Similarly, employment agencies may not comply with requests from employers to engage in and Dark Sides of Jane example, discriminatory recruitment or referral practices, for example by screening out applicants who have names often associated with a particular religion ( e.g., Mohammed). Moreover, an employer may not exclude an applicant from hire merely because he or she may need a reasonable accommodation that could be provided absent undue hardship. Definition! [59] Charles, the Essay example president of a company that owns several gas stations, needs managers for the new convenience stores he has decided to add to orestes and pylades the stations. He posts a job announcement at Light Sides Eyre Essay example, the Hindu Temple he attends and asks other members of the temple to refer only Hindu friends or family members who may be interested in the position. He does no other recruitment. By limiting his recruitment to the courtship lyon Hindus, Charles is engaging in Light Eyre Essay example, unlawful discrimination. Mary is a human resources officer who is filling a vacant administrative position at her company. During the application process, she performs an Internet search on the candidates and learns that one applicant, Jonathan, has written an the courtship, article for of Jane Eyre, the local chapter of the Ethical Society setting forth his view that religion has been historically divisive and explaining why he subscribes to troy (2004) no religious beliefs or practices.

Although Mary believes he is the 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 his lack of religious identification, the and Dark Essay company violated Title VII. Darpak, who practices Buddhism, holds a Ph.D. degree in engineering and applied for a managerial position at the research firm where he has worked for ten years. He was rejected in Business Defined, favor of a non-Buddhist candidate who was less qualified. Light And Dark Sides Of Jane Essay! The company vice president who made the promotion decision advised Darpak that he was not selected because “we decided to go in a different direction.” However, the vice president confided to co-workers at 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 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 their religion. [61] Joanne, a retail store clerk, is frequently 10-15 minutes late for her shift on several days per 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 lyon 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 Light Sides of Jane Essay disciplining only troy (2004), Yusef and not Joanne absent a legitimate nondiscriminatory reason for treating them differently. A charge alleging the above facts might also present a claim for denial of and Dark Sides of Jane Eyre Essay reasonable accommodation. Diabetes! While the of Jane Essay example employer may require employees to be punctual, it may have to accommodate an employee who seeks leave or a schedule change to resolve the the courtship lyon quotes conflict between religious services and a work schedule, unless the Light and Dark Sides of Jane Essay example accommodation would pose an undue hardship. [62] 3. Compensation and Other Terms, Conditions, or Privileges of Employment. Title VII prohibits discrimination on a protected basis “with respect to . . . compensation, terms, conditions, or privileges of employment,” for example, setting or adjusting wages, granting benefits, and/or providing leave in a discriminatory fashion. [63] Wages and Benefits. Janet, who practices Native American spirituality, is a newly hired social worker for an agency. Gestational Uk! As a benefit to its employees, the agency provides tuition reimbursement for professional continuing education courses offered by selected providers. Janet applied for tuition reimbursement for of Jane Eyre Essay example, an approved course that was within permitted cost limit. Troy (2004)! Janet’s supervisor denied her request for tuition reimbursement, stating that since Janet believes in and Dark Sides of Jane Essay example, “voodoo” she “won’t make a very good caseworker.” By refusing, because of Janet’s religious beliefs, to provide the tuition reimbursement to which Janet was otherwise entitled as a benefit of solomonic definition 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 Light and Dark Sides Eyre example disparate treatment of religious expression in the workplace. [64]

Eve is a secretary who displays a Bible on the courtship quotes her desk at Light and Dark of Jane Eyre Essay, work. Xavier, a secretary in the same workplace, begins displaying a Quran on his desk at work. Troy (2004)! Their supervisor allows Eve to retain the 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 Sides of Jane Eyre example the display of of mr lyon a religious item at work constitutes disparate treatment based on religion in violation of Title VII. [65] Charges involving religious expression may present claims not only Light Sides of Jane Essay example, of disparate treatment, but also of harassment and/or denial of Structures reasonable accommodation. Investigation of claims of harassment and denial of reasonable accommodation are addressed respectively in §§ III and Light of Jane Essay, IV of this document. The Courtship Lyon Quotes! 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 constitute harassment or otherwise poses an Light Eyre Essay, 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 orestes and pylades perceive the materials to express the employer’s own message, or where the item or message in Light and Dark Sides of Jane Eyre, question is harassing or otherwise disruptive. [66] For further discussion of how to the courtship quotes analyze when accommodation of religious expression would pose an Light Sides Eyre, undue hardship, refer to the sections on Harassment at § III-C and Accommodation at § IV-C-6. If an of mr, employer takes an action based on the discriminatory preferences of others, including co-workers or clients, the employer is and Dark Sides example, unlawfully discriminating. Employment Decision Based on 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 manager notices that the orestes and pylades work crew from the Light and Dark of Jane Essay example construction site near the gestational 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 September 11 th attacks. The manager tells Harinder that he has to Sides of Jane Eyre Essay example let him go because the customers’ discomfort is understandable. The manager has subjected Harinder to unlawful religious discrimination by taking an adverse action based on customers’ preference not to have a cashier of Harinder’s perceived religion. Orestes And Pylades! Harinder’s termination based on 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. For example, an Light and Dark Sides Eyre Essay, employer may not require Muslim applicants to undergo a background investigation or more extensive security procedures because of troy (2004) 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 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 Sides of Jane Essay the normal operation of that particular business or enterprise.” [68] Religious organizations do not typically need to rely on Frustration Strive for Satisfaction Essay this BFOQ defense, however, because the “religious organization” exception in and Dark Sides of Jane Eyre, Title VII permits them to prefer their co-religionists. See supra § I-C. It is and Aggression:, well settled that for Light and Dark Sides of Jane Eyre, employers that are not religious organizations and therefore seek to rely on the BFOQ defense to justify a religious preference, the definition defense is a narrow one and can rarely be successfully invoked. [69] Employers can reduce the Light and Dark Sides Essay risk of discriminatory employment decisions by establishing written objective criteria for evaluating candidates for hire or promotion and applying those criteria consistently to of mr all candidates. And Dark Sides! In conducting job interviews, employers can ensure nondiscriminatory treatment by asking the and Aggression: for Satisfaction Essay same questions of Light Sides of Jane Eyre example all applicants for a particular job or category of job and Frustration for Satisfaction Essay, inquiring about matters directly related to the position in question. Sides Essay Example! Employers can reduce the risk of troy (2004) 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 Sides Eyre Essay subjective judgment, employers can reduce the risk of discriminatory decisions by providing training to inexperienced managers and gestational uk, 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 and Dark Eyre Essay example being served by an employee due to religious garb, the employer should consider engaging with and educating the diabetes customers regarding any misperceptions they may have and/or the equal employment opportunity laws. Overview: Religious harassment is analyzed and proved in the same manner as harassment on other Title VII bases, e.g., race, color, sex, or national origin. And Dark Sides Of Jane Essay Example! [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 solomonic definition, employer to and Dark Sides of Jane example reconcile its dual obligations to take prompt remedial action in 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 and Aggression: Strive employment (this type of Light of Jane Essay “quid pro quo” harassment may also give rise to definition a disparate treatment or denial of accommodation claim in some circumstances), [71] or (2) subjected to unwelcome statements or conduct that is based on religion and is so severe or pervasive that the individual being harassed reasonably finds the Light Eyre example work environment to orestes be hostile or abusive, and there is 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 Eyre example receiving a job benefit or avoiding an adverse action. Troy (2004)! [73] Religious Conformance Required for Promotion. Wamiq was raised as a Muslim but no longer practices Islam. Example! His supervisor, Arif, is a very devout Muslim who tries to orestes and pylades persuade Wamiq not to abandon Islam and and Dark Sides Essay, advises him to follow the teachings of the Quran. Gestational Uk! Arif also says that if Wamiq expects to advance in Essay, 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 Frustration and Aggression: for Satisfaction 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 Light and Dark of Jane 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 troy (2004) his adherence to Arif’s views of appropriate religious practice. [74] This would also be actionable as disparate treatment based on and Dark Sides Essay religion. Definition! In addition, if the prayer sessions were made mandatory and and Dark Sides of Jane example, Wamiq had asked to be excused on religious grounds, Arif would have been required to orestes excuse him from the prayer sessions as a reasonable accommodation. A claim of harassment based on Light and Dark Eyre example 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 Frustration and Aggression: for Satisfaction, 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 accommodate the employee’s request to be excused. However, the same fact pattern may give rise to claims of and Dark Sides Eyre disparate treatment, harassment, and/or denial of accommodation. For example, terminating rather than accommodating an employee may give rise to of mr lyon quotes both denial of Light and Dark Sides Essay example accommodation and discriminatory discharge claims. [75] For discussion of the accommodation issue, see § IV, infra .[76] Title VII’s prohibition against religious discrimination can also be violated if the employee is subjected to a hostile work environment because of religion. [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 an employee. A hostile work environment is created when the solomonic definition “workplace is permeated with discriminatory intimidation, ridicule, and of Jane Eyre example, insult that is sufficiently severe or pervasive to alter the conditions of the victim’s employment and create an abusive working environment.” [78] To establish a case of religious harassment, an employee must show that the harassment was: (1) based on his religion; (2) unwelcome; (3) sufficiently severe or pervasive to alter the for Satisfaction conditions of employment by creating an intimidating, hostile, or offensive work environment; and, (4) that there is Sides Essay, a basis for employer liability. [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 either the harasser or the of mr lyon quotes targeted employee.

Moreover, while verbally harassing conduct clearly is Eyre Essay example, based on Strive for Satisfaction Essay 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 work day and observes Muslim dietary restrictions, his co-workers are aware of his religious beliefs. Upset about the 9/11 terrorist attacks, his co-workers and managers began making mocking comments about Light and Dark Sides Essay example his religious dietary restrictions and need to pray during the workday. They repeatedly referred to Structures him as “Taliban” or “Arab” and asked him “why don’t you just go back where you came from 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 way things work over and Dark Sides Eyre Essay example, here. This is not the Structures Islamic country where you come from.” After this confrontation, the Light and Dark Eyre Essay 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 and pylades, national origin. [82] Harassing Conduct Based on Light Sides Eyre 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 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 orestes, client meetings on Friday afternoons, and often marked Shoshanna AWOL when she was not scheduled to Eyre Essay work.

In addition, Nicholas treated her differently than her colleagues by, for example, denying her training opportunities and loudly berating her with little or no provocation. Gestational! Although Nicholas did not mention Shoshanna’s religion, the Light of Jane example evidence shows that his conduct was because of Shoshanna’s need for religious accommodation, and diabetes uk, therefore was “based on” religion. [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 Light and Dark Eyre Essay evaluate all of the surrounding circumstances to determine whether or not particular conduct or remarks are unwelcome. [85] For example, where an employee is orestes and pylades, upset by repeated mocking use of derogatory terms or comments [86] about 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 Light Sides of Jane Essay same two employees were engaged in a consensual conversation that involves a spirited debate of religious views, and and Aggression: Strive Essay, neither employee indicates that he was upset by it. The distinction between welcome and Sides Essay, unwelcome conduct is especially important in the religious context in troy (2004), 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 Sides Eyre Essay correctness of his belief, or vice versa, the conduct may or may not be welcome. When an Essay, employee objects to particular religious expression, unwelcomeness is Sides Essay example, 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. When he persisted even after she told him that he had “crossed the 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 be abusive” and the conduct is “severe or pervasive enough to create an objectively hostile or abusive work environment -- an definition, environment that a reasonable person would find hostile or abusive.” [90] Whether a reasonable person would perceive the conduct as abusive turns on common sense and context, looking at the totality of the Light and Dark Sides Eyre circumstances. [91] Relevant factors include whether the conduct was abusive, derogatory, or offensive; [92] whether the conduct was frequent; [93] and whether the conduct was humiliating or physically threatening. Troy (2004)! [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 be a religiously hostile work environment. [95] To “alter the Sides of Jane Eyre Essay conditions of employment,” conduct need not cause economic or psychological harm. [96] It need not impair work performance, discourage employees from remaining on the job, or impede their advancement. Frustration And Aggression: Strive! [97] The presence of Light and Dark Eyre one or more of Strive those factors would buttress the and Dark Sides of Jane Eyre Essay example claim, but is not required. [98] However, Title VII is troy (2004), not a general civility code, and does not render all insensitive or offensive comments, petty slights, and annoyances illegal. Light And Dark Of Jane Eyre! [99] Offhand or isolated incidents (unless extremely serious) will not rise to the level of Business Defined illegality. [100] Insensitive Comments Not Enough To Constitute Hostile Environment. Marvin is an Orthodox Jew who was hired as a radio show host. Light And Dark Sides Of Jane Eyre Essay! 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 yarmulke, such as: “Nice hat. Is that a beanie?” and “Do they come in different colors?” Although the definition co-worker’s comments about his yarmulke were insensitive, they were not sufficiently severe or pervasive to create a hostile work environment for Marvin. [101] Isolated Comments Not Enough to Constitute Hostile Environment.

Bob, a supervisor, occasionally allowed spontaneous and voluntary prayers by employees during office meetings. During one meeting, he referenced Bible passages related to “slothfulness” and “work ethics.” Amy complained that Bob’s comments and the few instances of allowing voluntary prayers during office meetings created a hostile environment. The comments do not create an actionable harassment claim. Sides Of Jane Eyre! 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 and pylades 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 Light Sides Essay example, unusually severe, particularly if it involves physical threat. Orestes! [104] One Instance of and Dark Essay Physically Threatening Conduct Is Enough to definition Constitute Hostile Environment. Ihsaan is a Muslim.

Shortly after the terrorist attacks on September 11, 2001, Ihsaan came to work and Light and Dark Sides Essay, found the words “You terrorists go back where you came from! We will avenge the solomonic victims!! Your life is next!” scrawled in red marker on his office door. Because of the timing of the statement and the direct physical threat, this incident, alone, is and Dark Sides Essay example, sufficiently severe to constitute hostile environment harassment based on religion and national origin. [105] Persistent Offensive Remarks Constitute Hostile Environment. Betty is a Mormon. Business Structures! 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 “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 be transferred, or she can “just pray about it.” Over the next six months, Julian regularly makes similar negative references to 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 be insulting or abusive. And Dark Sides Of Jane Eyre Essay Example! Thus, for example, persistently reiterating atheist views to a religious employee who has asked that it stop can create a hostile environment. Solomonic! However, the and Dark of Jane Eyre Essay example extent to which the expression is troy (2004), directed at Sides of Jane Eyre, a particular employee is Business Structures Essay, 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 Light and Dark Sides Essay example, conceivable that one employee may allege that he is offended by a colleague’s wearing of religious garb, expressing one’s religion by gestational diabetes uk 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 Light and Dark of Jane Eyre Essay example, 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 troy (2004), the company cafeteria, Clarence often overhears conversations between his co-workers Dharma and Light and Dark of Jane, Khema. Dharma, a Buddhist, is discussing meditation techniques with Khema, who is interested in Buddhism. Clarence strongly believes that meditation is an the courtship lyon quotes, occult practice that leads to devil worship and complains to their supervisor that Dharma and Light and Dark of Jane Essay, 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 they were not directed at him. Overview: An employer is always liable for a supervisor’s harassment if it results in a tangible employment action. However, if it does not, the employer may be able to avoid liability or limit damages by uk establishing an 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 Light and Dark Sides of Jane Eyre example take advantage of any preventive or corrective opportunities provided by the courtship quotes the employer or to avoid harm otherwise. In cases of harassment by a co-worker or a third party over and Dark Sides Essay example, whom the employer had some control, an Business Essay, employer is liable if it knew or should have known about the Light and Dark Sides Eyre Essay harassment and failed to take immediate and appropriate corrective action. 1. Harassment by of mr lyon quotes Supervisors or Managers. Employers are automatically liable for of Jane Eyre example, supervisory harassment that results in a tangible employment action such as a denial of promotion, demotion, discharge, or constructive discharge. Frustration Strive For Satisfaction Essay! If the harassment does not result in 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 Light and Dark Sides, (2) the employee unreasonably failed to take advantage of any preventive or corrective opportunities provided by the employer or to otherwise avoid harm. [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 deeply religious is a zealot with his own agenda and cannot be trusted to act in the best interests of the orestes public.

George particularly ridicules Debra, a devoutly observant Jehovah’s Witness, and consistently withholds the most desirable assignments from her. He denies her request for of Jane example, a promotion to Frustration Strive 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 Light and Dark of Jane Essay, 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 troy (2004) employer is liable for the harassment even if it has an effective anti-harassment policy, and even if Debra never complained. Additionally, the denial of 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 regularly publicized it. Despite his knowledge of the Sides of Jane Eyre Essay example 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. Jennifer never reported the problem. When one of Jennifer’s co-workers eventually reported the solomonic supervisor’s harassing conduct, the employer promptly investigated, and acted effectively to stop the Light and Dark example supervisor’s conduct. Orestes! 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 Light and Dark Essay example, 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 reasonable corrective measures once it did learn of the harassment. An employer is liable for harassment by co-workers where it: knew or should have known about the the courtship of mr lyon harassment, and failed to take prompt and appropriate corrective action. [108] Harassment by Co-Workers.

John, who is Sides, a Christian Scientist, shares an and Aggression: Strive for Satisfaction, office with Rick, a Mormon. Light And Dark Of Jane Eyre Essay! 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 him about religion. After vainly asking Rick to the courtship of mr lyon quotes 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 Eyre example, just being helpful. Lyon Quotes! If the harassment continues, the employer is liable because it knew, through the supervisor, about Rick’s harassing conduct but failed to take immediate and appropriate corrective action. [109] An employer is liable for harassment by non-employees where it: knew or should have known about the Light and Dark Eyre harassment, could control the harasser’s conduct or otherwise protect the employee, and failed to take prompt and appropriate corrective action. [110] Harassment by a Contractor. Tristan works for XYZ, a contractor that manages Crossroads Corporation’s mail room. When Tristan delivers the mail to Julia, the of mr lyon quotes Crossroads receptionist, he gives her religious tracts, attempts to convert her to his religion, and persists even after she tells him to stop. And Dark Sides Essay Example! Julia reports Tristan’s conduct to her supervisor, who tells her that he cannot do anything because Tristan does not work for Crossroads. Frustration Essay! If the and Dark Sides of Jane example harassment continues, the orestes supervisor’s failure to act will subject Crossroads to liability because Tristan’s conduct is pervasive and Crossroads refused to take preventive action within its control.

Options available to Julia’s supervisor or the appropriate individual in 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 Light of Jane Eyre Essay, Employers When Balancing Anti-Harassment and and Aggression: Strive Essay, Accommodation Obligations With Respect to Religious Expression. While some employees believe that religion is intensely personal and private, others are open about their religion. Of Jane Eyre Essay Example! [111] There are employees who may believe that they have a religious obligation to share their views and to try to persuade co-workers of the truth of their religious beliefs, i.e. , to proselytize. Some employers, too, may wish to orestes and pylades express their religious views and 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. This mix of divergent beliefs and practices can give rise to conflicts requiring employers to balance the rights of employees who wish to express their religious beliefs with the rights of Sides of Jane Eyre Essay example other employees to be free from religious harassment under the foregoing Title VII harassment standards. [113] As discussed in more detail in § IV-C-6 of this document, an employer never has to accommodate expression of a religious belief in the workplace where such an accommodation could potentially constitute harassment of and Aggression: Strive for Satisfaction Essay co-workers, because that would pose an of Jane example, undue hardship for 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 Essay, employer does not have to allow such expression if it imposes an and Dark of Jane Eyre Essay, undue hardship on orestes and pylades the operation of the business. For example, it would be an undue hardship for an employer to accommodate proselytizing by Light of Jane Eyre example an employee if it constituted potentially unlawful religious harassment of a co-worker who found it unwelcome, or if it otherwise interfered with the operation of the business. [114] Because employers are responsible for maintaining a nondiscriminatory work environment, they are liable for troy (2004), perpetrating or tolerating religious harassment of Light and Dark Sides Eyre example their employees. Solomonic! An employer can reduce the Eyre Essay example chance that employees will engage in conduct that rises to the level of unlawful harassment by implementing an and Aggression: Essay, anti-harassment policy and an effective procedure for reporting, investigating, and and Dark Sides Eyre example, correcting harassing conduct. [115] Even if the policy does not prevent all such conduct, it will likely limit the employer’s liability where the affected employee allows the Structures conduct to Light and Dark Eyre Essay rise to the level of illegality by Business Structures Essay failing to Light and Dark Sides of Jane Eyre Essay report it. However, Title VII violations may result if an and Aggression: Strive for Satisfaction Essay, employer tries to avoid potential co-worker objections to employee religious expression by preemptively banning all religious communications in the workplace, since Title VII requires that employees’ sincerely held religious practices and Light and Dark Sides Eyre Essay, beliefs be accommodated as long as no undue hardship is posed.

Employers should have a well-publicized and consistently applied anti-harassment policy that: (1) covers religious harassment; (2) clearly explains what is gestational uk, prohibited; (3) describes procedures for bringing harassment to management’s attention; and, (4) contains an assurance that complainants will be protected against retaliation. The procedures should include a complaint mechanism that includes multiple avenues for complaint; prompt, thorough, and impartial investigations; and prompt and appropriate corrective action. Employers should allow religious expression among employees to the same extent that they allow other types of personal expression that are not harassing or disruptive. Once an employer is on notice that an employee objects to 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 Light of Jane Essay affect the conditions of employment if allowed to persist in the face of the employee’s objection. Gestational Diabetes Uk! 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 and Dark Eyre Essay example, escalating to the level of quotes a Title VII violation, employers should immediately intervene when they become aware of Light of Jane Essay example objectively abusive or insulting conduct, even absent a complaint. Frustration Strive For Satisfaction Essay! Employers should encourage managers to intervene proactively and discuss with subordinates whether particular religious expression is Light and Dark Eyre Essay, welcome if the orestes manager believes the expression might be construed as harassing to a reasonable person. While supervisors are permitted to engage in 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 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 personally confront an individual who is directing unwelcome religious or anti-religious conduct towards them should report the conduct to their supervisor or other appropriate company official in accordance with the company’s anti-harassment policy. Overview: Title VII requires an and Dark of Jane Eyre, employer, once on notice, to orestes reasonably accommodate an Light and Dark Essay, employee whose sincerely held religious belief, practice, or observance conflicts with a work requirement, unless providing the accommodation would create an undue hardship. Structures Defined! [116] However, the Title VII “undue hardship” defense is and Dark Sides Essay example, 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 providing religious accommodation requires a showing that the proposed accommodation in a particular case poses a “more than de minimis” cost or burden, which is troy (2004), a far lower standard for an employer to meet than undue hardship under the ADA, which is Light Eyre Essay, defined in that statute as “significant difficulty or expense.” [117] A religious accommodation claim is distinct from a disparate treatment claim, in which the troy (2004) question is whether employees are treated equally. An individual alleging denial of religious accommodation is seeking an adjustment to a neutral work rule that infringes on the employee’s ability to practice his religion. The accommodation requirement is “plainly intended to Light Sides of Jane Eyre relieve individuals of the burden of choosing between their jobs and their religious convictions, where such relief will not unduly burden others.” [118]

A reasonable religious accommodation is any adjustment to the work environment that will allow the employee to comply with his or her religious beliefs. However, it is subject to the limit of more than de minimis cost or burden. Uk! 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 and Dark Sides of Jane Eyre Essay employee or applicant will be able to of mr practice his or her religion. Light Eyre Example! Accommodation requests often relate to work schedules, dress and grooming, or religious expression or practice while at 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 solomonic, accommodation and that it is being requested due to Eyre example a conflict between religion and work. Troy (2004)! The employee is obligated to explain the Light Sides of Jane Eyre Essay example religious nature of the troy (2004) belief or practice at issue, and cannot assume that the employer will already know or understand it. [119] Similarly, the employer should not assume that a request is and Dark Eyre example, invalid simply because it is Frustration and Aggression: Strive Essay, 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 the way in which it conflicts with a work requirement. No “magic words” are required to place an employer on notice of an applicant’s or employee’s conflict between religious needs and a work requirement. 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 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 Light and Dark Sides of Jane Eyre Essay employer failed to accommodate his religious objection to swearing an oath. Until it received notice of the charge, the employer did not know that Jim’s refusal to solomonic sign the form was based on his religious beliefs. Because the employer was not notified of the conflict at Light Sides Eyre Essay, the time Jim refused to diabetes sign the form, or at any time prior to Jim’s termination, it did not have an opportunity to offer to accommodate him. Sides Of Jane Example! The employer has not violated Title VII. [121] While an employer is and Aggression: Strive, not required by Title VII to conduct a discussion with an employee before denying the employee’s accommodation request, as a practical matter it can be important to and Dark of Jane Eyre example do so. Both the lyon quotes employer and the employee have roles to and Dark of Jane example play in gestational uk, resolving an and Dark of Jane Eyre Essay example, accommodation request. In addition to diabetes uk placing the employer on notice of the need for accommodation, the employee should cooperate with the employer’s efforts to example 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 needed to determine whether an accommodation is available that would eliminate the religious conflict without posing an orestes, undue hardship on the operation of the employer’s business. Light Eyre Example! [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 lyon quotes, a reasonable accommodation. If the accommodation solution is not immediately apparent, the Sides Eyre example employer should discuss the Frustration and Aggression: request with the Light and Dark Essay employee to determine what accommodations might be effective. If the employer requests additional information reasonably needed to evaluate the request, the employee should provide it. Failure to confer with the Defined Essay employee is not an independent violation of Title VII but, as a practical matter, such failure can have adverse legal consequences for both an employee and an employer. For example, in some cases where an and Dark Sides, 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 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 orestes, reasonable information when, as a result, the employer was deprived of the information necessary to resolve the accommodation request. For example, if an employee requested a schedule change to accommodate daily prayers, the employer might need to Eyre Essay example ask for information about the the courtship of mr quotes religious observance, such as time and 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. Light Essay Example! [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 troy (2004) meet his religious needs through the employer’s proposed accommodation if possible. [125] Where the Light and Dark Sides Eyre example accommodation request itself does not provide enough information to enable the employer to make a determination, and and Aggression: Strive Essay, the employer has a bona fide doubt as to the basis for the accommodation request, it is entitled to Light Sides Eyre make a limited inquiry into the facts and circumstances of the employee’s claim that the Business Structures belief or practice at issue is religious and sincerely held, and Light and Dark Eyre example, that the solomonic definition belief or practice gives rise to the need for Sides example, the accommodation. See “Sincerely Held” and “Employer Inquiries into Religious Nature or Sincerity of Belief,” supra §§ I-A-2 and Structures Defined, I-A-3. Light Sides Of Jane Essay Example! [126] Whether an employer has a reasonable basis for seeking to verify the diabetes uk employee’s stated beliefs will depend on Light example the facts of a particular case.

Sincerity of orestes and pylades Religious Belief Questioned. Bob, who had been a dues-paying member of the 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 Light, that he could no longer pay union dues. The union doubted whether Bob’s request was based on a sincerely held religious belief, given that it appeared to and pylades be precipitated by an unrelated dispute with the union, and he had not sought this accommodation in and Dark of Jane Eyre, his prior fourteen years of Essay 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 belonging to or financially supporting a union. [127] When an employer requests additional information, employees should provide information that addresses the 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 Sides of Jane Eyre example employer’s doubts about the sincerity or religious nature of the employee’s professed belief such that third-party verification is unnecessary. Further, since idiosyncratic beliefs can be sincerely held and religious, even when third-party verification is needed, it does not have to the courtship come from a church official or member, but rather could be provided by of Jane Essay others who are aware of the employee’s religious practice or belief. [128] An employee who fails to and pylades cooperate with an and Dark Sides of Jane Essay example, employer’s reasonable request for verification of the troy (2004) sincerity or religious nature of a professed belief risks losing any subsequent claim that the employer improperly denied an Light of Jane Eyre Essay example, accommodation. 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 a pattern of harassment.

It also is important to troy (2004) remember that even if an employer concludes that an Sides Eyre example, individual’s professed belief is sincerely held and religious, it is only required to 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 Frustration and Aggression: Strive Essay, requesting or whether the change is sought due to a religious belief or practice. While Diane’s request lacked sufficient detail for the employer to make a final decision, it was sufficient to constitute a religious accommodation request. Rather than denying the request outright, the employer should have obtained the information from Light example, Diane that it needed to make a decision. Troy (2004)! 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 provide sufficient information to permit her employer to make a reasonable assessment of whether her request was based on a sincerely held religious belief, the Sides example precise conflict that existed between her work schedule and the courtship, church schedule, and whether granting the accommodation would pose more than a de minimis burden on Sides of Jane Essay example the employer’s business. 3. What is a “Reasonable” Accommodation?

Although an employer never has to troy (2004) provide an Sides of Jane Essay, accommodation that would pose an undue hardship, see infra § IV-B, the accommodation that is solomonic definition, 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 undue hardship. Of Jane Eyre Example! [129] Eliminating the conflict between a work rule and an employee’s religious belief, practice, or observance means accommodating the employee without unnecessarily disadvantaging the employee’s terms, conditions, or privileges of employment. Business Defined Essay! [130] Where there is more than one reasonable accommodation that would not pose an undue hardship, the employer is not obliged to provide the Light Sides Eyre Essay example accommodation preferred by the employee. [131] However, an employer’s proposed accommodation will not be “reasonable” if a more favorable accommodation is provided to Business Defined Essay other employees for of Jane Eyre Essay, non-religious purposes, [132] or, for example, if it requires the employee to accept a reduction in pay rate or some other loss of a benefit or privilege of employment and there is an alternative accommodation that does not do so. [133] Ultimately, reasonableness is a fact-specific determination. “The reasonableness of an troy (2004), employer’s attempt at accommodation cannot be determined in a vacuum. Instead, it must be determined on Sides of Jane a case?by?case basis; what may be a reasonable accommodation for one employee may not be reasonable for another . Frustration And Aggression: Strive! . . Light And Dark Of Jane Eyre Essay Example! . ‘The term ‘reasonable accommodation’ is a relative term and cannot be given a hard and fast meaning; each case . . Troy (2004)! . Sides Of Jane! necessarily depends upon its own facts and circumstances, and comes down to 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 a sports arena, asked not to be scheduled for any Friday night or Saturday shifts, to 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 Structures Defined, not reasonable because it does not fully eliminate the Light and Dark example religious conflict. Gestational Diabetes! The arena may deny the accommodation request only if giving Rachel every Saturday off poses an 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 Light and Dark of Jane Eyre, that she should refrain from diabetes uk, work on Sunday as part of her Sabbath observance, asked her supervisor never to Light and Dark Eyre schedule her to Defined work on Light and Dark Sides Eyre Essay Sundays. Tina specifically asked to 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 not required to grant Tina’s preferred accommodation. And Aggression: Strive For Satisfaction Essay! [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 hospital to accommodate her religious beliefs by allowing her to trade assignments with other nurses in the Labor and Delivery Unit as needed. The hospital concluded that it could not accommodate Yvonne within the Light and Dark Sides Eyre Essay Labor and solomonic definition, Delivery Unit because there were not enough staff members able and willing to trade with her. The hospital instead offered to permit Yvonne to transfer, without a reduction in pay or benefits, to a vacant nursing position in the Newborn Intensive Care Unit, which did not perform any such procedures. The hospital’s solution complies with Title VII. Light And Dark Sides Of Jane Essay! The hospital is Structures Defined, 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 undue hardship to accommodate her in the Labor and Delivery Unit. Title VII is violated by an employer’s failure to accommodate even if to avoid adverse consequences an employee continues to 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 Light and Dark Sides of Jane example the employment policy.” [138] Thus, the fact that an employee acquiesces to the employer’s work rule, continuing to work without an accommodation after the orestes employer has denied the request, should not defeat the employee’s legal claim. [139] In addition, the obligation to provide reasonable accommodation absent undue hardship is a continuing obligation. Employers should be aware that an employee’s religious beliefs and practices may evolve over Sides of Jane Eyre Essay, time, and that this may result in requests for the courtship quotes, 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 provide a reasonable accommodation if it would pose an example, undue hardship. Undue hardship may be shown if the accommodation would impose “more than de minimis cost” on the operation of the solomonic definition employer’s business. [141] The concept of Light Sides of Jane Eyre “more than de minimis cost” is discussed below in sub-section 2. Although the employer’s showing of undue hardship under Title VII is easier than under the solomonic definition ADA, the burden of persuasion is and Dark Sides of Jane Essay example, still on the employer. Of Mr Lyon Quotes! [142] If an Light and Dark Sides of Jane, employee’s proposed accommodation would pose an undue hardship, the 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 orestes type of workplace, the nature of the employee’s duties, the identifiable cost of the accommodation in relation to the size and operating costs of the employer, and of Jane Eyre Essay example, the number of solomonic employees who will in Essay example, fact need a particular accommodation. [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 employer will need to 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. Frustration And Aggression: For Satisfaction! [146] A mere assumption that many more people with the same religious practices as the individual being accommodated may also seek accommodation is Light and Dark Sides Eyre Essay, not evidence of undue hardship. The determination of whether a proposed accommodation would pose an lyon quotes, 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. And Dark Of Jane Eyre Essay Example! [148] Factors to be considered are “the identifiable cost in relation to the size and operating costs of the employer, and the number of individuals who will in Frustration and Aggression: Strive for Satisfaction Essay, fact need a particular accommodation.” [149] Generally, the payment of Light Sides of Jane Essay 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 diabetes uk regular payment of Sides Eyre Essay 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 solomonic, being sought are costs which an employer can be required to bear as a means of providing reasonable accommodation.” [151] Costs to and Dark of Jane example be considered include not only direct monetary costs but also the burden on the conduct of the employer’s business. 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 the courtship quotes accommodated employee’s share of 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 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 and Dark Sides of Jane Essay example cut his hair, David explains that he keeps his hair long based on his religious beliefs, and troy (2004), offers to wear it in a pony tail or held up with a clip. Light And Dark Of Jane Essay Example! The manager refuses this accommodation, and denies David the position based on his long hair. Since the lyon quotes 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 her job as a steel mill laborer because of her religion (Pentecostal) after she notified her supervisor that her faith prohibits her from Light and Dark of Jane Eyre, wearing pants, as required by the mill’s dress code, and requested as an troy (2004), accommodation to be permitted to wear a skirt. Management contends that the dress code is essential to of Jane Eyre example the safe and efficient operation of the 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 undue hardship. Troy (2004)! [156]

3. Seniority Systems and Collectively Bargained Rights. A proposed religious accommodation poses an undue hardship if it would deprive another employee of Light Sides of Jane example a job preference or other benefit guaranteed by a bona fide seniority system or collective bargaining agreement (CBA). Gestational Uk! [157] Of course, the mere existence of 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 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 QRS Corp., asks not to work on 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 of Jane example swap shifts to accommodate her sincerely held religious beliefs, the employer could be found liable for denial of reasonable accommodation if it refuses to troy (2004) permit the swap to occur. The existence of the collectively bargained system for determining weekend shifts should not result in the denial of Light and Dark Sides Essay accommodation if a voluntary swap can be arranged by for Satisfaction the employee without violating the system or otherwise posing an and Dark Sides example, undue hardship.

The result would be the same if QRS had a unilaterally imposed seniority system (rather than a CBA) pursuant to uk 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 Light example, question, or the employer would be subject to other operational costs that were more than de minimis by orestes and pylades allowing Susan to and Dark of Jane Eyre example swap shifts, then the employer can demonstrate undue hardship. Orestes And Pylades! [160] Although infringing on co-workers’ ability to 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. Of Jane Eyre! [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 diabetes uk accommodation would actually infringe on 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 Light Sides example, 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 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 gestational diabetes uk, employed as a correctional officer at a state prison, and his brother William is employed as a grocery store manager. Both Patrick and William seek permission from 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 head covering. The prison’s policy is based on 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 Light Sides example a stated desire that all employees wear uniform clothing so that they can be readily identified by for Satisfaction customers. 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 be worn. Light Of Jane Eyre Essay Example! William will likely prevail because there is no indication it would pose an undue hardship for the grocery store to troy (2004) 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 Light Eyre 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 hospital policy against weapons in Structures, the workplace. Harvinder explained to Light and Dark Eyre Essay example Bill that her faith requires her to wear a kirpan in order to comply with the Sikh Code of Conduct, and gave him literature explaining that the kirpan is a religious artifact, not a weapon. She also showed him the kirpan, allowing him to see that it was no sharper than butter knives found in Structures Essay, the hospital cafeteria. 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 Light Sides of Jane Essay, the factual circumstances of this case, the hospital is liable for denial of orestes and pylades accommodation. And Dark Sides Of Jane Example! [166] C. Lyon! Common Methods of Accommodation in the Workplace. Under Title VII, an employer or other covered entity may use a variety of methods to provide reasonable accommodations to its employees.

The most common methods are: (1) flexible scheduling; (2) voluntary substitutes or swaps of shifts and assignments; (3) lateral transfer and/or change of and Dark Sides Eyre Essay example job assignment; and, (4) modifying workplace practices, policies, and/or procedures. An employer may be able to reasonably accommodate an employee by allowing flexible arrival and Structures Defined Essay, departure times, floating or optional holidays, flexible work breaks, use of lunch time in Sides Eyre example, exchange for early departure, staggered work hours, and other means to enable an employee to make up time lost due to Business the observance of religious practices. And Dark Sides Eyre Essay! [167] However, EEOC’s position is that it will be insufficient merely to eliminate part of the conflict, unless eliminating the orestes conflict in its entirety will pose an and Dark of Jane Eyre Essay example, undue hardship by gestational diabetes 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 Light of Jane example pray at several prescribed times during the and pylades workday in order to adhere to his religious practice of praying at Light and Dark Sides Essay, five specified times each day, for Frustration and Aggression: Essay, several minutes, with hand washing beforehand. Eyre Essay! 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 30 minutes of total break time otherwise allotted, nor will it affect his ability to perform his duties or otherwise cause an definition, undue hardship for and Dark Sides example, his employer. Lyon! 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 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 of Jane example the extent that it discriminates against applicants who refrain from work on certain days for religious reasons, by failing to of mr quotes allow for the provision of Light and Dark Sides of Jane Eyre Essay 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 the courtship lyon quotes reasonable accommodation requirement can often be satisfied without undue hardship where a volunteer with substantially similar qualifications is Light Essay, available, either for a single absence or an extended period of troy (2004) time. The employer’s obligation is to make a good faith effort to allow voluntary substitutions and shift swaps, under circumstances which do not discourage employees from and Dark of Jane Essay example, substituting for Business Structures Defined Essay, one another or trading shifts to Light and Dark example 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 Business Structures do so, reasonable accommodation requires more than merely permitting the employee to swap. [171] Nevertheless, an employer does not have to Sides of Jane permit a substitute or swap if it would pose more than de minimis cost or burden to business operations. As noted above, if a swap or substitution would result in the employer having to pay premium wages (such as overtime pay), the definition frequency of the and Dark of Jane Eyre example arrangement will be relevant to determining if it poses an troy (2004), undue hardship; “the 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 Light and Dark Sides Eyre Essay, employer can be required to bear as a means of providing reasonable accommodation.” [172] An employer may have to make an exception to its scheduling policies, procedures, or practices in order to grant religious accommodation. Orestes And Pylades! [173] For example, if it does not pose an undue hardship, an employer must make an exception to its policy of requiring all employees, regardless of seniority, to work an “equal number of weekend, holiday, and night shifts,” and 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 Light Sides the Sabbath. 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 Essay, undue hardship, the accommodation does not have to be granted.

3. Change of Sides Essay example Job Tasks and Lateral Transfer. When an uk, employee’s religious belief or practice conflicts with a particular task, appropriate accommodations may include relieving the employee of the task or transferring the Light and Dark Essay employee to Frustration and Aggression: Strive for Satisfaction a different position or location that eliminates the conflict with the employee’s religion. Light Of Jane Eyre Example! Whether or not such accommodations pose an undue hardship will depend on factors such as the nature or importance of the duty at orestes, issue, the availability of others to perform the function, the availability of other positions, and Light and Dark Sides Essay, the applicability of Frustration for Satisfaction Essay a CBA or seniority system. Restaurant Server Excused from Singing Happy Birthday. Kim, a server at Light Sides of Jane Essay, a restaurant, informed her manager that she would not be able to join other waitresses in singing “Happy Birthday” to the courtship customers because she is a Jehovah’s Witness whose religious beliefs do not allow her to celebrate holidays, including birthdays. There were enough servers on duty at and Dark Essay, any given time to perform this singing without affecting service.

The manager refused any accommodation. 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 solomonic a large corporation that operates numerous large pharmacies at which more than one pharmacist is on Light of Jane example duty during all hours of operation. Neil informed his employer that he refused on religious grounds to gestational participate in distributing contraceptives or answering any customer inquiries about contraceptives. The employer reasonably accommodated Neil by offering to allow Neil to signal to of Jane 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 Turn Away Customers.

In the above example, assume that instead of facilitating the assistance of gestational diabetes uk such customers by Light Sides of Jane Essay a co-worker, Neil leaves on hold indefinitely those who call on the phone about 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 not required to Frustration for Satisfaction 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 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 Light and Dark Sides example 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 gestational uk pharmacist to signal a co-worker to assist customers with such prescriptions, the employer cannot choose instead to Sides Essay accommodate by transferring the pharmacist to a different position. Moreover, if the Structures Defined Essay pharmacist cannot be accommodated within his position, the employer cannot transfer the pharmacist to a position that entails less pay, responsibility, or opportunity for advancement unless a lateral transfer is and Dark Sides Eyre example, 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 his Sabbath observance, but because the nature of his position requires being available to handle emergency problems at any time, there is no accommodation that would permit the lineman to remain in his position without posing an undue hardship. The employer can accommodate the lineman by offering a lateral transfer to another assignment at the same pay, if available. If, however, no job at the courtship quotes, the same pay is readily available, then the Light of Jane example employer could satisfy its obligation to of mr quotes reasonably accommodate the lineman by offering to transfer him to a different job, even at lower pay, if one is available. [180]

4. Of Jane Essay Example! Modifying Workplace Practices, Policies and Procedures. When an troy (2004), employer has a dress or grooming policy that conflicts with an employee’s religious beliefs or practices, the employee may ask for an exception to the policy as a reasonable accommodation. [181] Religious grooming practices may relate, for and Dark, 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 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 division responsible for sterilizing the 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 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 diabetes uk, files a Title VII charge. CutX will prevail because it offered a reasonable accommodation that would eliminate Prakash’s religious conflict with the hygiene rule. Some courts have concluded that it would pose an undue hardship if an employer was required to accommodate a religious dress or grooming practice that conflicts with the public image the employer wishes to convey to Light Sides of Jane Essay customers. [183] While there may be circumstances in Frustration and Aggression:, which allowing a particular exception to an employer’s dress and Light and Dark Sides of Jane example, grooming policy would pose an troy (2004), undue hardship, an employer’s reliance on the broad rubric of “image” to deny a requested religious accommodation may in a given case be tantamount to reliance on customer religious bias (so-called “customer preference”) in violation of Title VII. [184]

Nasreen, a Muslim ticket agent for a commercial airline, wears a head scarf, or hijab, to work at and Dark of Jane, the airport ticket counter. After September 11, 2001, her manager objected, telling Nasreen that the and Aggression: customers might think she was sympathetic to and Dark Eyre Essay example terrorist hijackers. The Courtship Quotes! Nasreen explains to her manager that wearing the hijab is her religious practice and continues to wear it. She is Light Essay example, terminated for wearing it over her manager’s objection. Customer fears or prejudices do not amount to solomonic undue hardship, and the refusal to accommodate her and the termination, therefore, violate Title VII.

In addition, denying Nasreen the position due to perceptions of customer preferences about Light of Jane Eyre Essay religious attire would be disparate treatment based on troy (2004) religion in violation of Title VII, because it would be the Light and Dark Sides of Jane same as refusing to solomonic hire Nasreen because she is a Muslim. 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 undue hardship. [186] However, even in these situations, a case-by-case determination is Light and Dark of Jane example, advisable. [187] If any employee needs to use a workplace facility as a reasonable accommodation, for example use of a quiet area for gestational diabetes uk, prayer during break time, the Sides of Jane example 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 uk, issue for Light and Dark Eyre Essay, 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 orestes, religious activities is Light Sides of Jane Eyre Essay, not a reasonable accommodation or poses an undue hardship. [188]

Use of Employer Facilities. An employee whose assigned work area is Defined, 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 only conference room is used for Essay example, work meetings at that time. However, the supervisor is not required to provide the employee with his choice of the available locations, and 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 unoccupied area of the work space rather than the conference room. c. Tests and Other Selection Procedures. An employer has an obligation to accommodate an employee or prospective employee when scheduling a test or administering other selection procedures, where the diabetes uk applicant has informed the employer of a sincerely held religious belief that conflicts with a pre-employment testing requirement, unless undue hardship would result. Light Eyre Essay Example! [189] An employer may not permit an applicant’s need for a religious accommodation to affect its decision whether or not to hire the applicant unless the employer can demonstrate that it cannot reasonably accommodate the applicant’s religious practice without undue hardship. And Aggression: Strive For Satisfaction Essay! [190] d. Providing Social Security Numbers. It will typically pose an undue hardship for an employer to Light and Dark Sides of Jane Eyre accommodate an orestes and pylades, applicant or employee’s asserted religious belief against providing or using a social security number. [191] 5. Sides Of Jane Example! Excusing Union Dues or Agency Fees. Absent undue hardship, Title VII requires employers and unions to accommodate an employee who holds religious objections to joining or financially supporting a union. [192] Such an employee can be accommodated by allowing the Structures Defined equivalent of Light and Dark Eyre her union dues (payments by union members) or agency fees (payments often required from non-union members in a unionized workplace) to be paid to a charity agreeable to the employee, the definition union, and the employer. [193] Whether a charity-substitute accommodation for payment of and Dark of Jane Eyre Essay example 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 the courtship lyon quotes, not to joining or financially supporting the Sides of Jane Essay example union, but rather to definition the union’s support of certain political or social causes, the Light and Dark Essay example employee may be accommodated if it would not pose an undue hardship by, for example, reducing the amount owed and/or by allowing the employee to Essay donate to a charitable organization the full amount the employee owes or that portion that is Light Sides Essay, attributable to solomonic definition the union’s support of the cause to which the employee has a religious objection, or by 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 Light and Dark Sides of Jane Eyre example cause to which the employee has a religious objection. [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. Others may seek to proselytize by engaging in solomonic, one-on-one discussions regarding religious beliefs, distributing literature, or using a particular religious phrase when greeting others. Still others may seek to Light and Dark Essay example engage in prayer at their work stations or to troy (2004) use other areas of the workplace for 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 situation or be called upon to consider any action unless it receives complaints about the religious expression from either other employees or customers. 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 Sides of Jane Eyre example issue of 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 other forms of 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 orestes have, if permitted to continue, on co-workers, customers, or business operations. a. And Dark Of Jane Eyre Essay Example! Effect on Workplace Rights of Co-Workers. Expression can create undue hardship if it disrupts the troy (2004) work of Light and Dark Sides Essay example other employees or constitutes or threatens to constitute unlawful harassment. Since an lyon, employer has a duty under Title VII to protect employees from Light Sides example, religious harassment, it would be an undue hardship to accommodate such expression.

As explained in diabetes uk, § III-A-2-b of this document, religious expression directed toward co-workers might constitute harassment in Light and Dark Eyre, some situations, for example where it is facially abusive ( i.e. , demeans people of other religions), or where, even if not abusive, it persists even though the co-workers to 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. Uk! [197] As with harassment on Light and Dark Sides of Jane Essay any basis, it is permitted and advisable for employers to 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. And Aggression: Strive For Satisfaction Essay! [198] The determination of and Dark Sides of Jane Eyre whether it is an undue hardship to allow employees to engage in religiously oriented expression toward customers is a fact-specific inquiry and will depend on the nature of the expression, the nature of the employer’s business, and the extent of the impact on customer relations. And Pylades! 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 the context of brief anonymous interactions and Light Sides Eyre Essay, had little demonstrable adverse impact on customers or the business. [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 uk client objects, this may be an undue hardship for an employer where the Light Sides of Jane Eyre expression could be mistaken as the employer’s message. Troy (2004)! Where the religiously oriented expression is not limited to use of a phrase or greeting, but rather is in the manner of individualized, specific proselytizing, an employer is far more likely to be able to demonstrate that it would constitute an undue hardship to accommodate an employee’s religious expression, regardless of the Light of Jane length or nature of the business interaction. [201] Display of Religious Objects By an diabetes, Employee. Susan and Roger are members of the same church and are both employed at Light and Dark Essay, 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. 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 Susan and Roger’s church, the Strive for Satisfaction 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 poster on the wall above their respective work stations. XYZ orders both to remove the Light and Dark of Jane poster despite the fact that both explained that they felt a religious obligation to display it, and despite the fact that there have been no complaints from co-workers or clients. Susan and Roger file charges alleging denial of religious accommodation. The employer will probably be unable to show that allowing Susan to display a religious message in orestes and pylades, her personal workspace posed an undue hardship, because there was no evidence of any disruption to the business or the workplace which resulted. By contrast, because Roger sits at the lobby desk and 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 pose an undue hardship. [202] Undue Hardship to Light of Jane Eyre Allow Employee to Discuss Religion with Clients. Helen, an employee in a mental health facility that served a religiously and solomonic definition, ethnically diverse clientele, frequently spoke with clients about religious issues and shared religious tracts with them as a way to help solve their problems, despite being instructed not to do so. After clients complained, Helen’s employer issued her a letter of of Jane Eyre reprimand stating that she should not promote her religious beliefs to the courtship quotes clients and that she would be terminated if she persisted. Helen’s belief in the need to 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 of Jane Eyre Essay example, 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 solomonic, the workplace, and they are entitled to do so. [204] However, if an Essay example, employer holds religious services or programs or includes prayer in business meetings, Title VII requires that the employer accommodate an orestes and pylades, employee who asks to be excused for religious reasons, absent a showing of undue hardship. [205] Excusing an employee from Sides Eyre, 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 troy (2004), 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. And Dark Eyre Essay! He asks his supervisor to allow him to arrive at the meeting after the prayer. Defined Essay! 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 the staff meeting prayer, even if other employees of Light and Dark Eyre Michael’s religion do not object to being present for the prayer. [207] Employer Holiday Decorations.

Each December, the president of XYZ corporation directs that several wreaths be placed around the office building and orestes, 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 wreaths and 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 of Jane Eyre Essay example, employee from gestational, compulsory personal or professional development training where it conflicts with the employee’s sincerely held religious beliefs or practices. [209] There may be cases, however, where an and Dark example, employer can show that it would pose an undue hardship to provide an alternative training or to excuse an employee from 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 job, on how to comply with equal employment opportunity obligations, or on other workplace policies, procedures, or applicable legal requirements). Religious Objection to Frustration and Aggression: Essay Training Program Employee Must Be Excused. As part of its effort to Light Essay 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 orestes and pylades 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 Light and Dark Eyre example excusing her from the weekly meditation classes, even if the 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 employees on a variety of personnel matters, including compliance with EEO laws and also XYZ’s own internal anti-discrimination policy, which includes a prohibition on sexual orientation discrimination. Lucille asks to be excused from the 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 sinful based on her religion. The training does not tell employees to orestes value different sexual orientations but simply discusses and reinforces the employer’s conduct rule requiring employees not to discriminate against or harass other employees and to treat one another professionally. Light Sides Eyre! Because an employer needs to make sure that its employees know about and comply with such employer workplace rules, it would be an Frustration and Aggression: Essay, undue hardship for XYZ to excuse Lucille from the Light and Dark example training.[210] While not all of the following issues will be in dispute in troy (2004), every charge alleging denial of religious accommodation, if CP alleges that R failed to accommodate CP’s religious beliefs or practices, the investigator should generally follow this line of Light and Dark Sides Eyre Essay inquiry, considering these steps: Ascertain the nature of the belief or practice that CP claims R has failed to accommodate ( e.g. , dress, grooming, holy day observance, etc.) and what accommodation was sought (e.g., exception to dress code, schedule change, leave, etc.). If disputed by Structures Defined R, determine whether CP’s beliefs are “religious” in nature.

If disputed by R, determine whether CP “sincerely holds” the particular religious belief or practice at issue. Ascertain whether CP actually notified R of the need for a religious accommodation, i.e. And Dark Sides Of Jane Eyre Example! , whether it was made known to for Satisfaction Essay R that an accommodation was needed and that it was for religious reasons. Light Of Jane Eyre Essay! The investigator should seek evidence of when, where, how, and to gestational uk whom such notice was given, and the names of any witnesses to the notification. If R claims that it was not notified of CP’s need for an accommodation, the investigator should attempt to resolve the discrepancies between R’s contention and CP’s allegation by 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 accommodation offered, and if so, what? The investigator should obtain R’s statement of all attempts to Light and Dark Sides of Jane example 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 undue hardship in Frustration Strive Essay, terms of cost, disruption, effect on co-workers, or any other reason).

For example, in the event R is 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 and Dark Eyre, 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 gestational uk cost, ascertain the cost of the accommodation in relation to Sides of Jane Eyre Essay R’s size, nature of business operations, operating costs, and the impact, if any, of troy (2004) similar accommodations already being provided to other employees. If R’s undue hardship defense is based on a factor other than cost ( i.e. , disruption, production or staffing levels, security, or other factor), similarly ascertain the Light example impact of the accommodation with respect to gestational R’s particular workplace and business. When there is more than one method of accommodation available that would not cause undue hardship, the investigator should evaluate whether the accommodation offered is Sides Eyre Essay example, reasonable by 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 Business Structures Essay conflict. [211] If R asserts CP failed to and Dark of Jane Eyre cooperate with R in reaching an accommodation, obtain any available evidence regarding the orestes and pylades 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 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. Light And Dark Of Jane Essay! Employers should individually assess each request and diabetes, avoid assumptions or stereotypes about Light Sides Essay what constitutes a religious belief or practice or what type of accommodation is appropriate. Employers and employees should confer fully and promptly to the extent needed to share any necessary information about the employee’s religious needs and the courtship of mr, the available accommodation options. Light Sides Of Jane Eyre Essay Example! 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 solomonic definition, if it is Light and Dark Sides of Jane Eyre Essay, denied, explain to Structures Essay the employee why his proposed accommodation is not being granted. Managers and supervisors should be trained to consider alternative available accommodations if the particular accommodation requested would pose an undue hardship. Light And Dark Sides Example! When faced with a request for a religious accommodation which cannot be promptly implemented, an employer should consider offering alternative methods of accommodation on a temporary basis, while a permanent accommodation is being explored. In this situation, an employer should also keep the Structures Defined 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 of Jane Eyre Essay example requirements of the law and should be flexible in evaluating whether or not an accommodation is feasible.

An employer should not assume that an accommodation will conflict with the troy (2004) 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 Sides of Jane example seniority system or CBA. Of Mr Lyon Quotes! 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. Although an employer may not upset co-workers’ settled expectations, an employer is free to seek a voluntary modification to a CBA in order to accommodate an Light and Dark Sides Essay example, employee’s religious needs. Employers should train managers to be aware that, if the requested accommodation would violate the troy (2004) CBA or seniority system, they should confer with the Light and Dark example employee to determine if an alternative accommodation is Frustration and Aggression: for Satisfaction, available. Employers should ensure that managers are aware that reasonable accommodation may require making exceptions to and Dark of Jane Eyre Essay policies or procedures that are not part of a CBA or seniority system, where it would not infringe on other employees’ legitimate expectations. Employers should work with employees who need an adjustment to their work schedule to accommodate their religious practices. Notwithstanding that the legal standard for undue hardship is “more than de minimis ,” employers may of course choose voluntarily to and pylades incur whatever additional operational or financial costs they deem appropriate to accommodate an employee’s religious need for scheduling flexibility. And Dark Sides Of Jane Eyre Essay Example! Employers should consider adopting flexible leave and scheduling policies and procedures that will often allow employees to meet their religious and other personal needs. Such policies can reduce individual requests for and Aggression: Strive for Satisfaction, exceptions. For example, some employers have policies allowing alternative work schedules and/or a certain number of Light and Dark Sides of Jane Eyre example “floating” holidays for each employee. While such policies may not cover every eventuality and 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 definition, encourage voluntary substitutions and and Dark Sides example, swaps with employees of substantially similar qualifications by 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 Strive for Satisfaction help an employee with a religious conflict find a volunteer to and Dark example 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. However, an employer should only resort to transfer, whether lateral or otherwise, after fully exploring accommodations that would permit the employee to remain in his position. Where a lateral transfer is unavailable, an employer should not assume that an employee would not be interested in a lower-paying position if that position would enable the employee to abide by his or her religious beliefs.

If there is no accommodation available that would permit the employee to remain in his current position or an Business Essay, 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 Procedures. Employers should make efforts to accommodate an employee’s desire to wear a yarmulke, hijab, or other religious garb. If the and Dark Sides example employer is concerned about uniform appearance in a position which involves interaction with the public, it may be appropriate to consider whether the employee’s religious views would permit him to resolve the troy (2004) 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 and Dark Sides of Jane Eyre Essay engage in stereotyping based on religious dress and grooming practices and should not assume that atypical dress will create an orestes, 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 unintentionally pressuring or coercing employees to attend social gatherings after the Light Sides Eyre example employees have indicated a religious objection to attending. Permitting Prayer, Proselytizing, and Other Forms of Religious Expression. Employers should train managers to troy (2004) gauge the actual disruption posed by religious expression in the workplace, rather than merely speculating that disruption may result.

Employers should also train managers to Light and Dark Sides of Jane example 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 gestational diabetes, disrupting other workers). And Dark Sides Eyre Example! 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 Essay managers and employees. Employees should advise their supervisors or managers of the nature of the Sides of Jane Eyre Essay conflict between their religious needs and the work rules. Employees should provide enough information to enable the employer to understand what accommodation is needed, and why it is necessitated by a religious practice or belief. The Courtship Of Mr Lyon Quotes! 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 Color. Title VII’s prohibition against Light and Dark Sides Eyre example, religious discrimination may overlap with Title VII’s prohibitions against discrimination based on national origin, race, and troy (2004), color. Where a given religion is strongly associated or perceived to Light and Dark 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 individual has engaged in protected activity. [214] Protected activity consists of opposing a practice the 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 an investigation, proceeding, or hearing under the statute. EEOC has taken the position that requesting religious accommodation is diabetes, protected activity. And Dark Sides Eyre Essay! [215] Retaliation for diabetes uk, 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 attend is Light and Dark Essay, offensive to Defined her religious beliefs. She takes her request to human resources, and informs them that requiring her to attend these prayer meetings is offensive to her religious beliefs. Despite her supervisor’s objections, the human resources department instructs the and Dark Sides Eyre Essay example supervisor that in troy (2004), the circumstances no undue hardship is posed and he must grant the request. 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 similarly situated employees. Light Of Jane Example! This violates Title VII. Employers can reduce the the courtship risk of retaliation claims by training managers and supervisors to Light Sides Essay 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 carefully and timely recording the accurate business reasons for disciplinary or performance related actions and sharing these reasons with the lyon employee. HOW APPLICANTS OR EMPLOYEES CAN FILE A CHARGE. If you believe you have been discriminated against by Light Sides of Jane 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 because you opposed unlawful discrimination or participated in 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 diabetes uk, no EEOC office in the immediate area, call toll free 1-800?669?4000 or 1?800?669?6820 (TTY) for and Dark Sides Eyre example, more information. To avoid delay, call or write beforehand if you need special assistance, such as an interpreter, to file a charge. 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 which charges of solomonic employment discrimination must be filed or your agency’s EEO office must be contacted. When charges or complaints are filed beyond these time frames, you may not be able to Light and Dark Sides Eyre 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 gestational 300 days if the alleged discrimination arose in Light Sides of Jane Essay example, a state or locality that has a fair employment practices agency (FEPA) with the authority to grant or seek relief for the alleged discrimination. Federal sector employees and applicants must initiate EEO counseling at the agency responsible for the alleged discrimination within 45 days of the orestes alleged discriminatory event. Allegations of harassment based on race, color, religion, sex, or national origin are timely if at and Dark Sides of Jane Eyre, least one incident of harassment that is part of the larger pattern of diabetes harassment occurred within the filing period. If you wish to Sides of Jane Essay remain anonymous during the period when an 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 gestational 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. The information presented in this appendix applies to private sector and state and local government employers only. For information on the processing of Light and Dark Sides complaints against federal agencies, visit the EEOC’s “Federal Sector Information” page on the Internet at 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 solomonic definition race, color, sex, religion, national origin, age (40 or over), disability, opposition to Light and Dark Sides Essay 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 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. The Courtship Of Mr Lyon Quotes! , race, religion, etc.) and issues (hiring, promotion, etc.), and the date(s) of the alleged discrimination. Sides Of Jane Essay Example! You also may be asked to quotes provide a response to the charge and supporting documentation. The EEOC also may ask to Light of Jane Essay visit your work site or to interview some employees. It is important that your company retain records relating to issues under investigation as a result of the charge until the charge or any lawsuit based on the charge is resolved. In some cases, the Structures Defined EEOC notice may offer mediation as a method of Light and Dark Essay resolving the charge before an troy (2004), investigation. Light Sides Of Jane Essay! EEOC’s mediation program is a free service, and Business Defined Essay, participation is voluntary. The process is Essay example, confidential, and and Aggression: for Satisfaction Essay, there is and Dark Sides of Jane, a firewall ( i.e. , total separation) between the of mr lyon quotes mediation program and EEOC’s enforcement activities. Mediation provides employers and charging parties the opportunity to reach mutually agreeable solutions early in Eyre Essay example, the process.

The EEOC will notify your company if a charge is eligible for mediation. The Courtship Lyon Quotes! In the event that mediation does not succeed, the charge is referred for investigation. If the EEOC finds reasonable cause to Light and Dark Sides of Jane Eyre believe that your company discriminated against a charging party, it will invite you to Frustration and Aggression: Strive for Satisfaction 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 and Dark Sides Eyre EEOC does not find discrimination, or if conciliation fails and the EEOC chooses not to file suit, it will issue a notice of 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 troy (2004) 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 the charge. In all cases, your company should remember that it is unlawful to retaliate against Sides Eyre example, the charging party for filing the charge, even if you believe the charge is solomonic, without merit. Light Sides Eyre! You should submit a response to the EEOC and provide the information requested, even if you believe the charge is 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 of mr allegations are incorrect or do not amount to a violation of the law. [1] This document uses examples that refer to the practices and and Dark, beliefs of various religions. These examples are intended to the courtship lyon clarify the legal principles for Light and Dark Sides, which they are used and do not purport to represent the 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 Defined Essay, obtaining additional information. EEOC assumes no responsibility for their content and 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 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 Goldman v. Weinberger (Accommodation of the Wearing of Religious Dress ). The Commission’s Guidelines on Discrimination Because of Religion (hereafter Commission Guidelines ) are not affected by this Section. See Commission Guidelines , 29 C.F.R. Part 1605. [3] Use of the term “employee” in this document should be presumed to include an applicant and, as appropriate, a former employee. [4] 42 U.S.C. Light Of Jane! § 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 definition 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. Light Sides Of Jane Eyre Essay! § 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 and Aggression: Strive reasonably accommodate an and Dark Sides Essay example, 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 orestes and pylades change the current “ de minimis ” standard for establishing undue hardship to require employers to show that the accommodation would cause significant difficulty or expense. See H.R. 1431, 110th Cong. (2007). This compliance manual chapter interprets and applies the current federal law, and takes no position on WRFA. Sides Eyre! Note: Various state and local laws extend beyond Title VII in terms of the protected bases covered, the discrimination prohibited or accommodation required, and the legal standards and defenses that apply. [6] See, e.g., Torcaso v. Watkins , 367 U.S. 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. And Pylades! 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 the Tanenbaum Center for Interreligious Understanding, Religion in the Workplace Survey, at Sides, 6 (Society for Human Resource Management, 2001) (executive summary and diabetes uk, information on obtaining report available at http://www.tanenbaum.org/research.html (last visited July 2, 2008); Pew Forum on example 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 Structures Essay all charges filed with the Commission that year. Statistics regarding the number of religious discrimination charges filed with the and Dark Sides Eyre Essay 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. Companies,” U.S. Department of State’s Bureau of International Information Programs (Nov. 28, 2007), available at Frustration and Aggression: Strive for Satisfaction Essay, 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. Light Of Jane Eyre Essay! , and 2000e-16a. See, e.g. , infra nn.11-15, 66 (directing attention to situations where the Religious Freedom Restoration Act (RFRA) may apply), and gestational diabetes, 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 establishment of religion, or prohibiting the free exercise thereof; or abridging the freedom of speech”) protect individuals against of Jane Eyre Essay, restrictions imposed by Business Structures Defined Essay the government, not by private entities, and therefore do not apply to rules imposed on private sector employees by their employers. The First Amendment, however, does protect private sector employers from and Dark of Jane Eyre, government interference with their free exercise and gestational diabetes, 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. Of Jane Eyre! 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 Essay, http://clinton2.nara.gov/WH/New/html/19970819-3275.html (last visited July 2, 2008)).

Although the Federal Workplace Guidelines are directed at Light and Dark Eyre example, federal employers, they provide useful guidance for private employers as well. In addition, the U.S. Department of Justice maintains a website, www.firstfreedom.gov, which provides information on a variety of constitutional and Defined Essay, statutory religious discrimination issues, including a section on Title VII employment protections based on Light and Dark Sides Essay example 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 and Aggression: Strive requested accommodation would have posed an undue hardship because allowing the 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), cert. Light Sides Of Jane Eyre Example! 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 diabetes uk, 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. Townley Eng’g Mfg.

Co. Light Essay Example! , 859 F.2d 610, 621 (9th Cir. And Aggression: Strive Essay! 1988) (court must balance the application of Title VII to the employment policy against private employers’ right under First Amendment Free Exercise clause to 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 accommodate atheist employee’s request to 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 Pub. 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 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 and Dark Sides Eyre Essay 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 Defined Essay its “no beard” policy to of Jane Essay accommodate his beliefs, while exempting other officers for medical reasons); Draper v. Orestes! Logan County Pub. Light And Dark Essay Example! Library , 403 F. Supp. 2d 608 (W.D.

Ky. Strive For Satisfaction Essay! 2005) (public library employee’s First Amendment free speech and free exercise rights were violated when she was prohibited from wearing a necklace with a cross ornament). [15] Guidance for government workplaces on the First Amendment religious free exercise issues, much of which is also useful for the private sector, is available in of Jane Eyre example, the Federal Workplace Guidelines , supra n.11 ; see also Brown , 61 F.3d at and Aggression: Strive, 658 (applying First Amendment test governing free speech of public employees to First Amendment free exercise claims, court balanced an employee’s right to free exercise with the employer’s interest in providing effective and efficient public services; public employee’s termination constituted both denial of religious accommodation under Title VII and violation of 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 local laws in their jurisdiction prohibiting religious discrimination in Light and Dark of Jane Essay, employment, some of the courtship of mr lyon which may be parallel to and Dark Eyre Essay Title VII and some of which may afford narrower or broader coverage.

[18] “Theistic” is defined as “believing in gestational diabetes, 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. 1978) (the statutory language “all aspects of Eyre Essay example religious practice and belief” is interpreted broadly; “to restrict the act to those practices which are mandated or prohibited by Business Essay a tenet of the religion, would involve the Light Sides Essay court in determining not only orestes and pylades, 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 Essay, not required by gestational uk the tenets of the religion”); s ee also Employment Div., Dep’t of and Dark Sides of Jane Essay example Human Res. of Oregon v. Smith , 494 U.S. Orestes! 872, 887 (1990) (in holding that the Light and Dark of Jane Eyre example 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 plausibility of a religious claim”). [20] Thomas v. Review Bd. of the Indiana Employment Sec. Div. , 450 U.S. 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 Frustration and Aggression: Strive for Satisfaction Lukumi Babalu Aye, Inc. v. City of Hialeah , 508 U.S. 520, 531 (1993) (although animal sacrifice may seem “abhorrent” to some, Santerian belief is religious in Light and Dark Sides of Jane Eyre Essay, nature and gestational, is protected by the First Amendment); U.S. v. Meyers , 906 F. Supp. And Dark Eyre! 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 the courtship judicial function and Sides of Jane, judicial competence to inquire whether the petitioner or [another practitioner] . . And Aggression: Essay! . more correctly perceived the commands of their common faith. Courts are not arbiters of Light and Dark Eyre Essay 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 Welsh v. United States , 398 U.S. 333 (1970), which defined protected “religion” for purposes of the Universal Military Training and Service Act). Unless otherwise noted, cases are cited in this document for the courtship of mr lyon quotes, their Title VII holdings.

[23] Seeger , 380 U.S. at 176. “This standard was developed in [ Seeger ] and [ Welsh ]. The Commission has consistently applied this standard in its decisions.” 29 C.F.R. § 1605.1. [24] Commission Guidelines , 29 C.F.R. § 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 belief is a religious belief of the employee or prospective employee.”); Welsh, 398 U.S. at 343 (petitioner’s beliefs were religious in nature although the church to which he belonged did not teach those beliefs); accord Africa v. 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. And Dark Sides Of Jane! , 164 F. Supp. 2d 1066, 1076 n.15 (N.D. Ind. 2001) (“Title VII’s intention is to provide protection and accommodation for Structures Essay, a broad spectrum of religious practices and and Dark of Jane Eyre, belief not merely those beliefs based upon organized or recognized teachings of a particular sect”). [25] Commission Guidelines , 29 C.F.R. § 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 and pylades 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 Light of Jane Eyre Essay example, compelling its atheist employees to the courtship of mr attend religious services); Young , 509 F.2d 140 (same). [26] United States v. Meyers, 906 F. Sides Eyre Essay Example! Supp. 1494, 1499 (D. Wyo. Troy (2004)! 1995) (the threshold for establishing the religious nature of beliefs is low; under the First Amendment, “if there is any doubt about whether a particular set of of Jane beliefs constitutes a religion, the Court will err on solomonic the side of freedom and find that the beliefs are a religion. . . And Dark Sides Of Jane Essay Example! . [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 the courtship of mr lyon 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 plausibility of a religious claim”). [27] Meyers, 906 F. Supp. at 1502 (religions address “ultimate ideas,” i.e. , “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 Light and Dark Sides Essay, 1483; accord Africa, 662 F.2d at the courtship of mr, 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 of Jane Essay example an isolated teaching”); Dettmer v. Landon , 617 F. Supp. Business Essay! 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 reflects a broad concern for Light and Dark of Jane example, improving the quality of solomonic life for others), aff’d in relevant part and rev’d on other grounds , 799 F.2d 929 (4th Cir. 1986); Church of the Chosen People (No. And Dark Sides Of Jane Eyre Essay! Am. Diabetes! 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 Light and Dark of Jane Eyre Essay ‘man’s nature or his place in the Universe,’ [and is] not merely a personal preference”), aff’d, 589 F.2d 1113 (5th Cir. 1979). Although “religion” is often marked by external manifestations such as ceremonies, rituals or clergy, such manifestations are not required for a belief to Frustration Essay be “religious.” E.g., Malnak v. And Dark Sides Of Jane Eyre! Yogi, 592 F.2d 197, 209-10 (3d Cir. 1979). [28] For example, EEOC and courts have found that the Ku Klux Klan is troy (2004), not a religion within the meaning of Title VII because its philosophy has a narrow, temporal, and political character. Commission Decision No. And Dark Of Jane Eyre! 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. The Courtship Quotes! 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 a Hitler rally because the Ku Klux Klan is “political and and Dark Eyre example, 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. Essay! 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 more than three years, worked to put the church’s teachings into practice, and actively proselytizes. However, the of Jane example Peterson court might have reached a different conclusion had it considered whether the belief was merely one-dimensional and thus not religious, i.e. , not part of a moral or ethical belief system concerning “ultimate ideas” about “life, purpose, and death.” [29] Compare Tiano v. Business Defined Essay! Dillard Dep’t Stores, Inc ., 139 F.3d 679 (9th Cir. 1998) (employer not liable for denying employee’s request to 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 Light and Dark the pilgrimage at another time and that the particular dates she requested were simply a personal preference), with Heller v. The Courtship! EBB Auto Co. , 8 F.3d 1433 (9th Cir. Light And Dark Sides Eyre! 1993) (employer liable for failing to accommodate Jewish employee’s attendance of spouse’s conversion ceremony); see also Wessling v. Orestes And Pylades! Kroger Co. , 554 F. Supp. 548 (E.D.

Mich. And Dark Of Jane Eyre Essay Example! 1982) (employer not liable for denial of accommodation where employee requested leave to help children get into their costumes and solomonic definition, practice before performance of church play; employee’s own testimony revealed her participation in Light of Jane Eyre Essay, this instance was more in the nature of a parental and social obligation); Redmond , 574 F.2d at 901 (employer liable for failing to of mr lyon quotes accommodate employee’s participation in 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 church elders, and employee felt that his participation was at dictate of his elders and Light Sides of Jane Eyre Essay example, constituted a “religious obligation”); Weitkenaut v. Goodyear Tire Rubber Co. , 381 F. Supp. 1284, 1288?89 (D. Vt. 1974) (employer liable for troy (2004), failing to protect minister’s attendance at monthly church organizational meetings where it was considered necessary to Sides Essay example preparing for his pastoral duties and thus essential to his ability to lead his congregation). [30] Cf. LaFevers v. Saffle , 936 F.2d 1117 (10th Cir. And Pylades! 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. Of Jane Essay Example! , 554 F. Supp. 548 (E.D.

Mich. 1982) (court held that plaintiff, who had volunteered to arrive at Church early to set up, decorate, and receive children prior to their performance of troy (2004) a play during Christmas Mass, was engaging in a social and Eyre Essay example, family obligation rather than a religious belief, practice, or observance). [32] See Dettmer v. Landon, 799 F.2d 929, 932 (4th Cir. 1986) (in First Amendment case, rejecting argument that witchcraft was a “conglomeration” of “various aspects of the occult” rather than a religion; religious beliefs need not be “acceptable, logical, consistent or comprehensible to others” to be protected); Washington Ethical Soc’y v. District of solomonic Columbia , 249 F.2d 127, 128 (D.C. Cir. Light Sides Essay! 1957) (Ethical Society qualifies as a “religious corporation or society” and orestes, its building is Light and Dark of Jane Essay, entitled to tax exemption; belief in a Supreme Being or supernatural power is troy (2004), 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. Light And Dark Sides! App. 1957) (same holding with respect to orestes and pylades Secular Humanists). [33] EEOC v. Red Robin Gourmet Burgers, Inc. , 2005 WL 2090677 (W.D. Wash.

Aug. 29, 2005) (denying employer’s motion for summary judgment on accommodation claim arising from employee’s refusal to cover his Kemetic religious tattoos in order to comply with employer’s dress code). [34] These facts are similar to those in Cloutier v. Costco Wholesale Corp. Light And Dark Of Jane Eyre Essay! , 390 F.3d 126 (1st Cir. Troy (2004)! 2004). However, the court in Cloutier did not resolve the issue of whether or not the plaintiff’s facial piercing, which she alleged was displayed pursuant to her adherence to Light and Dark of Jane the beliefs of the Church of gestational Body Modification, was part of a “religious” belief, practice, or observance, instead finding that the proposed accommodation of allowing display of the piercing would have posed an Light Essay example, undue hardship. [35] Seeger , 380 U.S. at 185 (“[w]hile the ‘truth’ of a belief is not open to question, there remains the significant question of troy (2004) 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 his religion, for example that he worked five days a week rather than the of Jane Essay required six, had lied on of mr lyon an employment application, and Sides of Jane Eyre, took an definition, oath before a notary upon becoming a public employee, can be relevant to the evaluation of sincerity but is not dispositive); Hansard v. Light Sides Eyre Essay! Johns-Manville Prods. Corp ., 1973 WL 129 (E.D.

Tex. Feb. Business Structures Essay! 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. Light Sides Essay Example! Waldorf-Astoria , 134 F. Supp. Structures! 2d 591 (S.D.N.Y. 2001) (employer had a good faith basis to doubt sincerity of employee’s professed religious need to wear a beard because he had not worn a beard at any time in his fourteen years of employment, had never mentioned his religious beliefs to anyone at the hotel, and simply showed up for work one night and asked for Sides of Jane, an on-the-spot exception to the no?beard policy), aff’d , 2002 WL 390437 (2d Cir. Mar. 13, 2002) (unpublished). [37] EEOC v. Ilona of Hungary, Inc ., 108 F.3d 1569 (7th Cir. And Pylades! 1997) (en banc) (Jewish employee proved her request for Sides Eyre Essay, 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 definition, conceded that she generally was not a very religious person; the evidence showed that certain events in her life, including the Light of Jane Eyre Essay example birth of her son and the death of her father, had strengthened her religious beliefs over the years); Cooper v. Oak Rubber Co ., 15 F.3d 1375 (6th Cir.

1994) (that employee had worked the orestes and pylades Friday night shift at plant for approximately seven months after her baptism did not establish that she did not hold sincere religious belief against and Dark Sides Essay, working on Saturdays, considering that 17 months intervened before employee was next required to Structures Essay work on Saturday, and 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 faith did not prove that his religious beliefs were insincere at the time that he refused to Light and Dark Sides Essay example work on the Sabbath); s ee also Union Independiente, 279 F.3d at orestes, 57 n.8 (the fact that the alleged conflict between plaintiff’s beliefs and union membership kept changing might call into Sides Essay, question the sincerity of the beliefs or “might simply reflect an and pylades, 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. Sides Of Jane Eyre Essay! U.S.F. Troy (2004)! Logistics (IMC), Inc. Light And Dark! , 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 solomonic phrase was not a requirement of her religion); Rivera v. Choice Courier , 2004 WL 1444852 (S.D.N.Y. 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 Sides of Jane example employers, see supra n.4. Under 42 U.S.C. § 2000e-2(b), it is solomonic definition, unlawful for Light and Dark Essay example, employment agencies to “fail or refuse to the courtship of mr lyon quotes refer for employment, or otherwise to Light and Dark Sides of Jane Essay discriminate against, any individual because of his . Solomonic Definition! . . religion . . . or to classify or refer for employment any individual on the basis of his . . . religion . . . Light Eyre! .” Under 42 U.S.C. § 2000e-2(c), it is unlawful for unions to “(1) to exclude or expel from membership, or otherwise to discriminate against, any individual because of his . . . religion . . Solomonic! . ; (2) to limit, segregate or classify its membership or applicants . And Dark Sides Example! . . or to refuse to refer for Business, employment any individual . . Sides Of Jane Eyre Example! . because of such individual’s . . . religion . Uk! . . ; or (3) to Sides Essay example cause or attempt to cause an gestational, employer to discriminate . . Light And Dark Of Jane Essay Example! . in violation of this section.” [40] See, e.g., Union Independiente, 279 F.3d 49; Bushouse , 164 F. 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 solomonic definition expel from Light of Jane Eyre, 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 Business Structures Defined contract”). See, e.g., Perugini v. Safeway Stores, 935 F. 2d 1083 (9th Cir. 1991) (remand to determine whether union discriminatorily failed to Light Eyre example challenge employer’s refusal to give pregnant worker light duty); Rainey v. Town of orestes and pylades Warren , 80 F. Light Sides! Supp. 2d 5, 17 (D.R.I. 2000) (“[i]t is axiomatic that a union’s failure to adequately represent union members in the face of employer discrimination may subject the the courtship quotes 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 and Dark Eyre example, discrimination, the EEOC disagrees.

See EEOC v. Pipefitters Ass’n Local Union 597 , 334 F.3d 656 (7th Cir. 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 carrying on by such corporation, association, educational institution, or society of its activities. Section 703(e)(2) of 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 the courtship of mr lyon quotes 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 directed toward the propagation of Light Sides example a particular religion.

While Congress did not include a definition of the § 702(a) term “religious corporation” in 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 quotes, entity and a religious sect than what would be required under § 702(a).” See LeBoon v. Lancaster Jewish Cmty. Light Eyre Example! Ctr. , 503 F.3d 217, 237 (3d Cir. 2007) (Rendell, J., dissenting). Executive Order 13279, Equal Protection of the Laws for Faith-Based and 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 solomonic definition the basis of their religious beliefs even if they receive federal funding. See 67 Fed. Light And Dark Sides Eyre! Reg.

77,141 (12/16/02). The Guidance to Faith-Based and Community Organizations on Frustration Strive for Satisfaction Essay 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 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. Light And Dark Sides Eyre Example! Health Care Corp. , 215 F.3d 618, 624-25 (6th Cir. Solomonic Definition! 2000) (college of Light Sides of Jane Essay 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. , 113 F.3d 196 (11th Cir. 1997) (Baptist university was “religious educational institution” where largest single source of funding was state Baptist Convention, all university trustees were Baptists, university reported financially to Convention and to gestational uk Baptist State Board of and Dark Sides of Jane Eyre example Missions, university was member of Association of the courtship lyon quotes Baptist Colleges and Schools, university charter designated its chief purpose as “the promotion of the Christian Religion throughout the world by maintaining and operating institutions dedicated to the development of Christian character in Light Sides Essay, high scholastic standing,” and 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 diabetes uk 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 and Dark of Jane schools are either essentially secular, or neutral as far as religion is the courtship lyon quotes, concerned). [46] See Corp. of the Presiding Bishop of the Church of Jesus Christ of Latter-Day Saints v. Amos , 483 U.S. Light And Dark Example! 327 (1987) (a nonprofit church-run business does not violate Title VII if it refuses to hire anyone other than members of 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. Unification Theological Seminary , 2001 WL 64739 (S.D.N.Y.

Jan. 24, 2001) (seminary operated by Unification Church cannot be sued for religious discrimination by 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. 11, 1998) (unpublished) (religious organization can be held liable for retaliation and national origin discrimination); DeMarco v. Holy Cross High Sch. , 4 F.3d 166 (2d Cir. The Courtship! 1993) (religious institutions may not engage in age discrimination). [49] EEOC v. 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 and Dark Eyre Essay household” health insurance benefits only to single persons and married men). [50] McClure v. Salvation Army , 460 F.2d 553, 558-60 (5th Cir. 1972); s ee also Hollins v. Frustration For Satisfaction! Methodist Healthcare, Inc. , 474 F.3d 223 (6th Cir.

2007) (applying ministerial exception to bar claim by resident in Light and Dark of Jane, hospital’s pastoral care program who alleged disability discrimination); Tomic v. Catholic Diocese of Frustration and Aggression: Essay Peoria , 442 F.3d 1036 (7th Cir. And Dark Sides Example! 2006) (applying ministerial exception to bar age discrimination claim brought by Catholic Diocese music director who was terminated following a dispute with the bishop’s assistant regarding what to lyon quotes play during the of Jane Eyre Essay example Easter Mass); Hankins v. Definition! 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 Light and Dark of Jane Essay 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 gestational diabetes tenured member of Catholic University’s department of religious canon law); DeMarco v. Holy Cross High School , 4 F.3d 166 (2d Cir. Light Essay! 1993) (ministerial exception inapplicable to parochial school teacher’s age discrimination claim because employer’s contention that teacher was terminated specifically for failing to attend Mass and to gestational diabetes lead his students in prayers could be evaluated without risk of excessive entanglement between government and religious institution); Guianan v. Light And Dark Sides! Roman Catholic Archdiocese of Indianapolis, 42 F. Gestational Diabetes! Supp. Sides Essay! 2d 849 (S.D.

Ind. 1998) (ministerial exception inapplicable to parochial school teacher’s age discrimination claim, even though teacher taught at least one class in diabetes uk, religion per Light Essay example, term, and Frustration Strive, organized one worship service per and Dark, month, since vast majority of teacher’s duties involved teaching math, science, and other secular courses). [51] Rayburn v. Gen. Conference of Seventh?Day Adventists , 772 F.2d 1164, 1169 (4th Cir. 1985). [52] Rweyemamu v. Cote , 520 F.3d 198 (2d Cir. Troy (2004)! 2008) (Title VII race discrimination claim by African-American Catholic priest challenging denial of promotion and subsequent termination was barred by the ministerial exception); Petruska v. Gannon Univ. , 462 F.3d 294 (3d Cir. 2006) (ministerial exception bars Title VII sex discrimination claim by female Catholic chaplain against and Dark Sides of Jane example, 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. Of Mr Lyon! Desert Southwest Annual Conf. of the United Methodist Church , 377 F.3d 1099 (9th Cir. 2004) (ministerial exception barred minister’s claim against church for failure to accommodate his disabilities). Light Example! However, some courts have ruled that the ministerial exception does not bar harassment claims by ministers, but rather only lyon, applies to claims involving matters such as hiring, promotion, and termination. Light Sides Eyre Example! 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. Orestes! California Province of the Soc’y of 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. Light And Dark Sides Eyre Essay! Heartland Presbytery, 342 F. Supp. 2d 996 (D. Kan. 2004) (First Amendment Establishment and solomonic definition, 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. Episcopal Church in the Diocese of Colorado, 289 F.3d 648, 657-59 (10th Cir. 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 Sides example doctrine is broader than the ministerial exception and and pylades, bars civil court review of internal church disputes involving matters of doctrine and church governance). [53] Geary v. Visitation of Blessed Virgin Mary Parish Sch. Light Sides Of Jane Eyre Essay Example! , 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 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 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 religious canon law). [54] Alicea?Hernandez v. Catholic Bishop of Frustration and Aggression: for Satisfaction Essay Chicago, 320 F.3d 698 (7th Cir.

2003) (ministerial exception applied to Communications Director who was responsible for crafting the Light Sides of Jane Eyre Essay example Church’s message to the Hispanic community); EEOC v. Roman Catholic Diocese of Raleigh, 213 F.3d 795 (4th Cir. 2000) (ministerial exception applies to cathedral’s director of orestes and pylades music ministry and part-time music teacher); Rayburn , 772 F.2d at 1168 (ministerial exception applies to and Dark of Jane Eyre Essay example 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. Orestes! 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 Light Essay example, 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. Gestational Uk! 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 of Jane Eyre example, the religion context, particularly in the area of recruitment and Frustration and Aggression: for Satisfaction Essay, hiring. See, e.g., Barrow v. Greenville Indep. Sch. Dist. , 480 F.3d 377 (5th Cir. 2007) (affirming summary judgment, citing lack of statistical evidence, for employer on 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 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. Light Sides Of Jane! 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 the courtship lyon hire her was unlawfully based on religion).

[60] In Noyes v. Kelly Servs. Inc ., 488 F.3d 1163 (9th Cir. And Dark Sides Essay Example! 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 the courtship a small religious group and favored and promoted other members of the religious group. Light And Dark Eyre Example! The court ruled that while the employee did not adhere to a particular religion, the and Aggression: Essay 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 create an issue for trial on whether the Light employer’s decision to 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 of mr quotes a Seventh-day Adventist was pretextual and that the real reason was religious discrimination because of the Sides of Jane Eyre Essay inconvenience caused by gestational uk employee’s inability to work on Saturdays); s ee also Campos v. City of Light and Dark Sides of Jane Blue Springs, 289 F.3d 546 (8th Cir. 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 proceed to trial in case brought on orestes 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 her religion); Altman v. Minn. And Dark Eyre Essay! Dep’t of Corr. , 251 F.3d 1199, 1203 (8th Cir. Gestational Uk! 2001) (in case raising both Title VII and First Amendment claims, holding that employer may not discipline employees for religiously based conduct because it is religious in nature if it permits such conduct by other employees when not motivated by Sides of Jane Eyre Essay 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. Solomonic Definition! , Goldmeier v. Allstate Ins. Co. , 337 F.3d 629 (6th Cir.

2003) (resignation 53 days prior to Light and Dark Sides of Jane Eyre Essay example effective date of employer’s policy that would have posed conflict with employees’ religious beliefs did not constitute constructive discharge); Shabat v. Blue Cross Blue Shield , 925 F. Supp. 977 (W.D.N.Y. 1996) (plaintiff’s contention that he received a promotion only by pressuring management did not allege an “adverse” employment action). [62] See infra § IV, Reasonable Accommodation. [63] 42 U.S.C. § 2000e-2(a)(1) (discriminating in Strive for Satisfaction Essay, hiring, discharge, or otherwise with respect to compensation, terms, conditions, or privileges of and Dark Sides Essay example employment); see also 42 U.S.C. Gestational Diabetes! § 2000e-2(a)(2) (discriminating by Light of Jane Eyre example limiting, segregating, or classifying employees or applicants in a way which would deprive or tend to deprive employment opportunities or otherwise adversely affect employment status); cf. Ansonia Bd. of Educ. Troy (2004)! v. Philbrook , 479 U.S. 60, 71 (1986) (a benefit “that is part and Light of Jane Eyre Essay, parcel of the employment relationship may not be doled out in a discriminatory fashion, even if the employer would be free . . . not to provide the benefit at 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 Defined Essay denying this privilege to any group promoting or advocating any religious or political position, where the company excluded not only groups advocating a particular religious position but also those espousing religious indifference or opposition.

See Moranski v. General Motors Corp. , 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 Sides example claims of religious harassment and discriminatory termination where he was not allowed to orestes bring a Bible to work, pray, or display religious pictures in his booth, while Somali Muslim employees were permitted to take prayer breaks and to example display religious materials in their booths). [65] This fact pattern may also give rise to a denial of accommodation claim. Definition! See infra § IV-C-6.

[66] Determining whether religious expression disrupts co-workers or customers is discussed in §§ III-C and IV-C-6, infra . Additionally, in a government workplace, the First Amendment Free Exercise Clause and Establishment Clause may affect the employer’s or employee’s ability to restrict or engage in religious expression. Light Of Jane Eyre! See supra nn.11-15 infra nn.201-203 ; see also Federal Workplace Guidelines , supra n.11, at sections 2-B and 2-E, noting implications of the Religious Freedom Restoration Act (RFRA) for orestes and pylades, neutral rules that burden religion in the federal workplace. [67] 42 U.S.C. Light Sides Of Jane Essay Example! § 2000e-2(g) (permitting covered entities to discharge or refuse to “hire and and pylades, employ” or refer an individual who does not meet federal security requirements). And Dark Sides Of Jane Essay! However, the Commission is aware of no statute or order that requires or permits distinctions based on religion. See infra § IV-B-5 (discussion of security requirements and 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 a university which had a contract to supply physicians on rotation at a Saudi Arabian hospital when the troy (2004) hospital presented no evidence to support its contention that Saudi Arabia would actually have refused an entry visa to a Jewish faculty member), and Rasul v. District of Columbia , 680 F. Supp.

436 (D.D.C. 1988) (Department of Corrections failed to and Dark Sides Eyre example demonstrate that Protestant religious affiliation was a BFOQ for position as prison chaplain because chaplains were recruited and hired on a facility-wide basis and were entrusted with the and pylades job of of Jane Eyre planning, directing, and maintaining a total religious program for Essay, all inmates, whatever their respective denominations), with Kern v. And Dark Of Jane Eyre Essay Example! 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 gestational uk 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. 1984), and Pime v. Loyola Univ. of Chicago , 803 F.2d 351 (7th Cir. Light Of Jane Eyre Example! 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 Frustration and Aggression: for Satisfaction Essay Jesuits, continues to have Jesuit tradition, and Light Sides Essay example, requires all of its undergraduates to take philosophy).

[70] Faragher v. Boca Raton , 524 U.S. 775, 788 (1998) (harassment claims are actionable on 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. Gestational Diabetes Uk! , 242 F. Supp. 2d 1051, 1063 (N.D. Ala. 2003), aff’d , 97 Fed.

Appx. 906 (11th Cir. 2004) (Table). [71] See Venters v. Light And Dark Sides Eyre! City of Delphi , 123 F.3d 956 (7th Cir. Quotes! 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 Sides Essay her supervisor’s religious beliefs, and also that a hostile work environment was created). [72] Meritor Sav. Bank, 477 U.S. at 66 (1986) (prohibition on discrimination “in the Business Structures Essay terms, conditions, or privileges of employment” requires employers to maintain a workplace free from harassment based upon protected status).

[73] See, e.g., Venters , 123 F.3d at 964 (employee established that she was discharged on the basis of her religion after supervisor, among other things, repeatedly called her “evil” and and Dark Essay, stated that she had to share his Christian beliefs in order to be a good employee). [74] Many of the example’s facts are taken from Sattar v. Motorola, Inc ., 138 F.3d 1164 (7th Cir. Gestational Diabetes Uk! 1998). Light Sides Of Jane Example! However, in Sattar the plaintiff did not prevail because the 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 and pylades 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 of Jane example Title VII). [76] Venters , 123 F.3d at 972 (“the accommodation framework . . . has no application when the 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 gestational diabetes uk any of Title VII’s protected bases); Meritor Sav. Bank, 477 U.S. at 67 (same); see also EEOC Enforcement Guidance: Vicarious Employer Liability for Essay, 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 religion; supervisor mistreated all of definition her employees and Light of Jane Eyre Essay example, had poor management and interpersonal skills). [81] Turner v. Barr , 811 F. Supp. Structures Defined Essay! 1, 2 (D.D.C. 1993) (hostile environment created where Jewish employee was subjected to a “joke” about the Holocaust, denied opportunity to work overtime, and ridiculed as a “turnkey”; although the and Dark Essay latter two incidents did not refer to religion, the facts showed that he was singled out for such treatment because of his religion). [82] See EEOC v. Sunbelt Rentals, Inc. , 521 F.3d 306 (4th Cir. 2008) (reversing summary judgment for the employer and remanding the gestational 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 Light and Dark Sides of Jane Essay example hostile work environment religious harassment when fellow employees repeatedly called him “Taliban” and “towel head,” made fun of solomonic definition 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. , 496 F.3d 393 (5th Cir. Light And Dark Sides Of Jane Essay Example! 2007) (reversing summary judgment for the employer and 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 definition, is a practicing Muslim was severe or pervasive and motivated by his national origin and religion). And Dark Of Jane Eyre Example! 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 the United States, that all Muslims support jihad, that all Muslims were sympathetic to the 9/11 attack, and that all Muslims are proponents of radical Islam.” 521 F.3d at 318. [83] See Abramson, 260 F.3d at and Aggression: Strive for Satisfaction, 279 (supervisor’s criticism of professor’s refusal to work on and Dark Eyre Essay example her Sabbath, scheduling meetings on and Aggression: Strive for Satisfaction Jewish holidays, and charging her for leave on those holidays could be found to have “infected [professor’s] work experience” because of her religion). [84] Henson v. Of Jane Eyre Essay! 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 the courtship of mr having been referred to as a “Muslim extremist,” and constantly called “Taliban” among other terms); Khan v. And Dark Of Jane Eyre Essay Example! United Recovery Sys., Inc., 2005 WL 469603 (S.D. And Aggression: Strive For Satisfaction Essay! Tex. 2005) (plaintiff’s religious harassment claim was based on alleged comments by 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 face of the earth,” that plaintiff might get shot for wearing an “Allah” pendant, and questioning plaintiff about what was being taught at 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 come into his office and justify such activity). [87] Human resources professionals who responded to a survey by Eyre example the Society for Human Resource Management (SHRM) and the Tanenbaum Center for solomonic definition, Interreligious Understanding reported that 19% of the employees in their organizations engaged in Light and Dark of Jane Eyre Essay, proselytizing to co-workers. While 32% of the gestational diabetes employees perceived increased cooperation and communication within their organizations due to acceptance of 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 Light of Jane Eyre, 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 telling her supervisor he had “crossed the line,” she established that the definition comments were unwelcome). [89] Id. (“whatever questions there might have been as to and Dark Sides of Jane Eyre Essay example 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 troy (2004), 21-22; Faragher , 524 U.S. at 788 (“We have made it clear that conduct must be extreme to amount to example a change in the terms and conditions of employment.”). [91] Faragher , 524 U.S. at 787-88; Oncale v. Sundowner Offshore Servs. , 523 U.S. 75, 82-83 (1998) (“[t]he real social impact of troy (2004) workplace behavior often depends on and Dark Sides of Jane Eyre example a constellation of surrounding circumstances, expectations, and uk, relationships which are not fully captured by a simple recitation of the Light and Dark Eyre Essay words used or the the courtship of mr lyon physical acts performed”); Harris , 510 U.S. at 23.

[92] Bains LLC v. Light Of Jane! Arco Prods. Business! 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 Sides Eyre example, “towel-heads,” and the courtship, were asked to Light Sides of Jane Eyre clean up fuel spills with their turbans). [93] Williams v. Gen. Definition! Motors Corp ., 187 F.3d 553, 564 (6th Cir. 1999) (“a work environment viewed as a whole may satisfy the legal definition of an Light Sides Eyre Essay, abusive work environment, for purposes of a hostile environment claim, even though no single episode crosses the Title VII threshold”). [94] Jones v. Gestational Uk! United Space Alliance , 2006 WL 250761 (11th Cir. Feb. 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 and Dark of Jane Essay community bulletin board a flyer describing events at Frustration and Aggression: for Satisfaction Essay, the plaintiff’s church, the Light and Dark Sides of Jane Eyre Essay example 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 and pylades, he was accused of Light and Dark Sides of Jane Essay 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 orestes plaintiff’s job performance).

[95] EEOC v. AKZ Mgmt., Inc. , Civil Action No. 07-8356 (S.D.N.Y. Light And Dark Sides Eyre Essay Example! consent decree filed Sept. Gestational! 26, 2007) (settlement of example religious harassment and disparate treatment claims on behalf of employees who were pressured by management to practice or conform to Scientology). Business Defined! See Johnson v. Spencer Press of 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 e-mails with dire warnings of the divine punishments that awaited those who refuse to and Dark Essay example follow Islam) ; Preferred Mgmt. Solomonic Definition! Corp ., 216 F. Supp. 2d 763 (Christian employer violated Title VII by and Dark example requiring employees to conform to her views). [96] Harris , 510 U.S. at Business Essay, 21; Meritor , 477 U.S. at 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 of Jane Essay their race, gender, religion, or national origin offends Title VII’s broad rule of Business Structures Defined workplace equality . Of Jane Eyre! . . . Certainly Title VII bars conduct that would seriously affect a reasonable person’s psychological well?being, but the of mr lyon 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 Light Sides example, Harris of an unreasonable interference with work performance was not intended to penalize the employee who possesses the dedication and troy (2004), fortitude to Light Sides of Jane Essay complete her assigned tasks even in the face of offensive and abusive [conduct] . . . Orestes And Pylades! . As Justice Scalia separately explained in Harris , the Light and Dark Essay 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 Strive Essay, 23 (“whether an environment is and Dark Sides of Jane Eyre Essay, ‘hostile’ or ‘abusive’ can be determined only by looking at gestational diabetes uk, all the circumstances . . . And Dark Sides Of Jane Essay Example! ; no single factor is required”). [99] Faragher , 524 U.S. at 788 (citing Oncale , 523 U.S. at the courtship quotes, 80); Sheikh v. Indep.

Sch. Dist. Sides Of Jane Eyre! 535 , 2001 WL 1636504 (D. Orestes And Pylades! Minn. 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 and Dark of Jane, the terms and conditions of for Satisfaction employment). [100] See Marcus , 2002 WL 1263999 at Sides of Jane Eyre Essay, *11 (asking very religious employee to swear on a Bible to orestes and pylades 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 create a hostile work environment); Sublett v. Edgewood Universal Cabling Sys., Inc. Sides! , 194 F. Gestational Diabetes! Supp. 2d 692, 703 (S.D. Eyre Essay Example! Ohio 2002) (supervisor’s single comment to 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. The Courtship! , 1997 WL 458489 at *8 (D. Of Jane Eyre Example! 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 alleged conduct rises to Frustration and Aggression: Strive for Satisfaction Essay 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 that the work environment created thereby may exceed the 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 plaintiff’s religion also once put the Light and Dark of Jane Eyre example point of a knife under plaintiff’s chin, in troy (2004), addition to threatening to kill him with a hand grenade, run him over with a car, and shoot him with a bow and arrow). [105] As with any harassment claim, employer liability will depend on whether the employee can show, in a case of co-worker harassment, that the Light and Dark Eyre Essay example employer knew or should have known of the misconduct and the courtship of mr quotes, failed to take prompt and appropriate corrective action. Light Sides Example! Additionally, in the case of harassment by non-employees, employer liability will depend on whether the employer had control over such individuals’ misconduct. 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. , 307 F.3d 535 (7th Cir. Troy (2004)! 2002) (the impact of Light Sides Essay example actions not directed at a complaining employee is not as great as the Frustration and Aggression: Strive Essay impact of harassment directed at him and the combined impact of all the and Dark Sides Eyre example 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 788; Preferred Mgmt. Corp. , 216 F. Supp. 2d at 839 n.25 (employer’s anti-harassment policy was inadequate because it did not include a prohibition on the courtship lyon religious harassment, employer did not provide training on religious harassment, and managers responded to complaints of religious harassment by and Dark Sides of Jane Eyre Essay requiring employees to participate in a training program based on religious principles). However, under agency principles an employer is automatically liable for hostile work environment harassment even if it does not result in and Aggression: for Satisfaction Essay, a tangible employment action if “the agent’s high rank in Light and Dark Sides example, the company makes him or her the employer’s alter ego.” Ellerth , 524 U.S. at 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 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 solomonic definition, 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 Light and Dark stop alleged harassment of Muslim employee by his co-workers); see Guidelines on Discrimination Because of orestes National Origin , 29 C.F.R. § 1606.8(d) (employer liable for Sides of Jane Eyre Essay example, co-worker harassment about which it knew or should have known and failed to act). [109] Cf. Powell v. Yellow Book USA, Inc. , 445 F.3d 1074 (8th Cir. 2006) (employer not liable for Defined, religious harassment of plaintiff because upon learning of her complaints about a co-worker’s proselytizing, the employer promptly held a meeting and told the co-worker to Light Sides of Jane Essay stop discussing religion matters with plaintiff, and there was evidence that the uk company continued to monitor the and Dark Eyre situation to ensure that the Defined co-worker did not resume her proselytizing). [110] 29 C.F.R. Light Sides Of Jane Eyre! § 1606.8(e). Berry v. Delta Airlines, Inc. , 260 F.3d 803 (7th Cir.

2001) (employer not liable for orestes and pylades, alleged sexual harassment of Light and Dark of Jane Eyre example 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 solomonic definition 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 Light Sides of Jane example Americans answered yes. See George Gallup, Jr. Timothy Jones, The Next American Spirituality: Finding God in the Twenty-First Century , at 72 (Cook Communication Ministries 2000). [112] Employers are permitted to exercise their religion to solomonic the extent that such exercise does not infringe on their employees’ religious beliefs. And Dark Eyre Essay Example! Townley , 859 F.2d at 621 (“Where the religious practices of employers . . . and troy (2004), employees conflict, Title VII does not, and and Dark Essay, could not, require individual employers to abandon their religion. Rather, Title VII attempts to reach a mutual accommodation of the conflicting religious practices.”). [113] In a survey conducted by the Tanenbaum Center for Interreligious Understanding, 66% of employees surveyed reported that they had witnessed religious discrimination in the workplace. Religious Bias in the Workplace: The Employee’s View (Tanenbaum Center for Interreligious Understanding, 1999) (executive summary available at 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 Frustration Essay circumstances under which reasonable accommodation of religious expression in Sides example, 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. v. Hardison, 432 U.S. Orestes! 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. Of Jane Eyre Essay Example! Volkswagen of Am., Inc., 797 F.2d 129, 136 (3d Cir.

1986) (“[t]his is . . . part of our ‘happy tradition’ of avoiding unnecessary clashes with the dictates of orestes and pylades conscience”) (citation omitted). [119] See Seshadri v. Of Jane Eyre Essay Example! 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 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 902 (relying on Business Structures Essay Mann , concluding that “an employee who is Light and Dark Eyre example, disinterested in informing his employer of his religious needs ‘may forego the right to have his beliefs accommodated by his employer’”). [120] See Heller , 8 F.3d at 1439 (employee’s request for leave to solomonic participate in religious conversion ceremony of his wife and children was sufficient to Light of Jane Eyre Essay place employer on notice that this was pursuant to diabetes uk a religious practice or belief; an employer need have “only enough information about an employee's religious needs to permit the employer to Light and Dark Essay example understand the Structures Essay existence of Light Sides of Jane Eyre example 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 orestes and pylades, a religious accommodation, court held employer was on notice of the need for accommodation given that it reprimanded employee for engaging in Light Sides of Jane, known religious activities); Hellinger v. Eckerd Corp., 67 F. Supp. 2d 1359 (S.D. Fla. 1999) (although applicant did not himself inform employer about and pylades his religious conflict on his job application, employer had learned when he contacted applicant’s former supervisor for and Dark Sides Eyre Essay example, a reference that the Business Essay applicant had refused to Eyre example sell condoms at prior job due to a religious objection, and was therefore on notice); cf. The Courtship! Wessling , 554 F. Supp. at 552 (employee’s request to leave work early in order to Light of Jane Eyre example arrive early for Defined, 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 Eyre Essay example a social activity or family obligation that happened to be associated with the church). [121] Cary v. Carmichael, 908 F. Business Structures Defined Essay! 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. Sept. 20, 2001) (employer not liable for disciplining employee for tardiness where employee failed until after his discharge to explain that tardiness was because he attended a prayer service), aff’d on other grounds , 318 F.3d 130 (2d Cir. 2003). [122] Notwithstanding the different legal standards for 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 the “interactive process” used for 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 Light and Dark Sides Eyre, equally applicable to the obligation to offer a reasonable accommodation to lyon an individual whose religious beliefs conflict with an employment requirement”); Elmenayer , 2001 WL 1152815, at Light and Dark Sides Eyre Essay example, *5 (same), aff’d on of mr other grounds , 318 F.3d 130 ; Kenner v. Light Of Jane! Domtar Indus., Inc ., 2006 WL 662466 (W.D.

Ark. Troy (2004)! Mar. 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 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 an acceptable reconciliation of the needs of the employee’s religion and the exigencies of the employer’s business’”) (quoting Brener v. Light And Dark Of Jane Essay! Diagnostic Ctr. Hosp. , 671 F.2d 141, 145-46 (5th Cir. 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 seniority rights] or any other reasonable accommodation, the company is in no position to argue that it was unable to accommodate reasonably [plaintiff’s] religious needs without undue hardship on the conduct of orestes and pylades its business”); EEOC v. Ithaca Indus., Inc. , 849 F.2d 116 (4th Cir. 1988) (employer’s failure to attempt to of Jane Essay accommodate violated Title VII). [124] Shelton v. Univ. of Med. Dentistry of N.J. , 223 F.3d 220, 227 (3d Cir. 2000) (by refusing to meet with employer’s human resources department, employee failed to satisfy her duty to diabetes uk cooperate in finding a reasonable accommodation). [125] Ansonia Bd. of Educ. Light Sides Of Jane Example! , 479 U.S. at 69 (employer could satisfy its obligation by offering an alternative reasonable accommodation to the particular one proposed by the employee); Brener , 671 F.2d at 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. v. Mann , 561 F.2d 1282, 1286 (8th Cir. 1977) (where employee “will not attempt to accommodate his own beliefs through the means already available to him or cooperate with his employer in its conciliatory efforts, he may forego the right to have his beliefs accommodated”), cert. Solomonic! denied , 434 U.S. 1039 (1978). [126] See also Bushouse , 164 F. Supp. 2d 1066. [127] Id. at Light of Jane Eyre, 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 troy (2004) present case” and Light and Dark Eyre example, 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. Orestes And Pylades! Ark. consent decree entered Aug. Light And Dark Sides Of Jane! 14, 2000) (settlement of Title VII challenge to employer’s policy of uk requiring a letter from Light and Dark of Jane, a church in support of all accommodation requests). [129] See EEOC v. The Courtship Of Mr Quotes! Ilona of Hungary, Inc. , 108 F.3d 1569 (7th Cir. 1997) (employer did not satisfy reasonable accommodation requirement by offering to let Jewish employees take off a day other than Yom Kippur, because that would not eliminate the conflict between religion and work); Shelton , 223 F.3d at 225 (citing Ansonia Bd. of and Dark of Jane Eyre example Educ ., 479 U.S. at solomonic, 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. Bruff v. And Dark Sides Eyre Essay Example! 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 its in-house employment counselor to find another position where the conflict between the duties and 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 solomonic definition offer reasonable accommodation of her religious practice of and Dark refraining from work during seven-day religious festival, where employer did not show undue hardship). [130] See infra nn.131-133. Under the the courtship of mr lyon quotes Commission’s approach, a reasonable accommodation must eliminate the conflict between work and 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 and Dark Sides Eyre, a manner that conflicts with longstanding Commission and orestes, judicial precedent. See, e.g., EEOC v. Firestone Fibers Textiles Co. , 515 F.3d 307 (4th Cir. Light Sides Essay Example! 2008) (analyzing reasonableness of proposed accommodation based on facts typically considered as part of undue hardship analysis); Sturgill v. And Aggression: Strive! United Parcel Service, Inc. , 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 and Dark of Jane Essay example, determined as a matter of law without regard to the facts of an individual case, or that an employer is not permitted to gestational diabetes choose among alternative accommodations, or that even accommodations which conflict with a CBA or otherwise pose an undue hardship must be granted). The Commission’s approach is more straightforward and more in keeping with the purpose of Light Sides Essay example 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 uk, undue hardship.

Moreover, the of Jane example employer need not grant an employee’s requested reasonable accommodation if the employer wishes instead to offer an alternative accommodation of definition its own choosing that also would eliminate the Light Sides Eyre work-religion conflict and uk, does not adversely affect the employee’s terms, conditions, or privileges of Light and Dark of Jane 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 Title VII when it demonstrates that it has offered a reasonable accommodation to the employee; “where the 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 and Aggression: Strive for Satisfaction, 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. An employer that does not provide a reasonable accommodation may nevertheless avoid liability if it shows that providing the accommodation would pose an example, undue hardship. Undue hardship is addressed below in § IV.B. [132] Ansonia Bd. of and Aggression: Strive for Satisfaction Educ. , 479 U.S. at 70-71 (“requiring [an employee] to Sides Eyre take unpaid leave for Strive Essay, holy day observance rather than use personal paid leave days provided for 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 Light of Jane Eyre Essay, not a reasonable accommodation when paid leave is provided for all purposes except religious ones . . . Business! [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 accommodation beyond that otherwise available to the employee, but may have to provide unpaid leave as an Sides of Jane Eyre, 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 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 accept any alternative favored by the employee, and, thus, are not inconsistent with Ansonia . In fact, the Court in Ansonia recognized that the Business limitation in the Commission’s guidelines that alternatives must be considered if they will not “disadvantage an and Dark Sides Essay, individual’s employment opportunities” distinguished the Commission’s position from the position of the Second Circuit that was rejected in diabetes, Ansonia . 470 U.S. at Light Sides, 69 n.6. Troy (2004)! Appellate courts in 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. Sides Of Jane Eyre Example! 2002) (an accommodation might be unreasonable if it imposes a “significant work-related burden on solomonic definition 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 Light Sides Eyre Essay example, employee, “in order to accommodate his religious practices, had to accept a reduction in Structures Defined Essay, 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 Light and Dark of Jane Eyre example schedule employee to work in the afternoon or evenings on troy (2004) Sundays, rather than the mornings, was not a “reasonable” accommodation under Title VII where employee’s religious views required not only Light and Dark, attending Sunday church services but also refraining from work on Sundays). [136] Wilshin v. Allstate Ins. Troy (2004)! Co., 212 F. Supp. 2d 1360 (M.D. Light Of Jane Essay! Ga. Orestes! 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 Light of Jane Eyre Essay example newborn intensive care unit was reasonable accommodation for her religious beliefs which prevented her from 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 a district with no abortion clinics resolved his religious objection to being assigned to Frustration and Aggression: Strive Essay guard such facilities; Title VII did not compel employer to instead grant his preferred accommodation of remaining in his district but being relieved of Light and Dark Sides of Jane Eyre example such assignments); Wright , 2 F.3d at 217 (7th Cir. Gestational Uk! 1993) (employer reasonably accommodated employee by suggesting he exercise his rights under CBA to bid on Light and Dark Essay example jobs that would have eliminated the conflict between work and religion). [138] Townley , 859 F.2d at 614 n.5 (citing Am. Postal Workers Union v. Postmaster , 781 F.2d 772, 774?75 (9th Cir. 1986)); see also Rodriguez v. City of Chicago, 1996 WL 22964, at *3 (N.D. Ill. Jan. The Courtship Of Mr! 12, 1996) (rejecting employer’s argument that a threat of Light adverse action is not enough to state a claim; “it is orestes and pylades, nonsensical to suggest that an Light and Dark Sides of Jane Eyre Essay, employee who, when forced by his employer to choose between his job and his faith, elects to avoid potential financial and/or professional damage by 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 definition 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. Light And Dark Sides Of Jane Essay! Pipe Foundry Co. , 527 F.2d 515 (6th Cir. 1975) (resorting to Business transfer where accommodation was possible in and Dark Essay, employee’s current position is Structures Defined Essay, actionable as denial of reasonable accommodation). However, an employer need not accommodate an employee who chooses to resign before notifying the and Dark of Jane example employer of the need for accommodation or fails to cooperate with the employer in the accommodation process. And Pylades! See, e.g., Goldmeier v. Allstate Ins. Co. , 337 F.3d 629 (6th Cir. 2003) (resignation 53 days prior to Light Sides of Jane example effective date of and pylades employer’s policy that would have posed conflict with employees’ religious beliefs did not constitute constructive discharge); Lawson v. Sides Eyre Essay Example! Washington , 296 F.3d 799 (9th Cir. 2002) (Jehovah’s Witness who quit state patrol rather than salute the 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. Troy (2004)! 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 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. This “more than de minimis ” Title VII undue hardship standard is substantially lower than the 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. Sides Eyre! § 2000e(j), and the Commission Guidelines , at 29 C.F.R. Solomonic Definition! § 1605.2(b), require an and Dark of Jane Eyre example, employer to reasonably accommodate an definition, employee’s or applicant’s religious beliefs and practices “unless the employer demonstrates” that doing so would pose an undue hardship. Even under the 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 employer still has the Light and Dark Sides of Jane example burden of Strive Essay 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. 1981).

[144] Commission Guidelines , 29 C.F.R. § 1605.2(e). [145] Compare Cooper , 15 F.3d at 1380(employee’s request not to Light Sides Eyre Essay example be scheduled for Saturday work due to Sabbath observance posed undue hardship for employer because it would have required hiring an the courtship, additional worker), and Beadle v. Tampa , 42 F.3d 633 (11th Cir. Light And Dark Sides Eyre Essay Example! 1995) (requiring police department to orestes and pylades alter training program schedule involving more than 900 employees to accommodate one employee’s religious needs amounts to Light Sides of Jane more than de minimis cost and thus undue hardship), with Protos , 797 F.2d 129 (employee’s request not to be scheduled for and Aggression:, 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. Light Of Jane Essay! Motors Corp., 601 F.2d 956, 960 (8th Cir. 1979) (“projected ‘theoretical’ future effects cannot outweigh the undisputed fact that no monetary costs and de minimis efficiency problems were actually incurred during the three month period in Business Essay, which [employee] was accommodated”); EEOC v. Alamo Rent-A-Car, LLC , 432 F. Supp. 2d 1006 (D. Ariz. Light And Dark Of Jane Essay Example! 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 troy (2004) 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 1243 (“undue hardship cannot be supported by merely conceivable or hypothetical hardships . And Dark Sides Eyre Essay! . . . The magnitude as well as the fact of hardship must be determined by definition ‘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. And Dark Sides! 1978)); EEOC v. Alamo Rent-A-Car, LLC , 432 F. Supp. 2d at troy (2004), 1016 (“‘hypothetical hardships’” based on assumptions or “pure speculation” about accommodations which have never been put into practice are insufficient to and Dark of Jane Essay show undue hardship”). [149] Id. Compare EEOC and Electrolux Reach Voluntary Resolution in Business Structures Defined, 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 and Dark Sides of Jane Essay example religious request of 165 Somali workers who, pursuant to orestes and pylades the tenets of the Islamic faith, must offer at Light of Jane Essay, least five daily prayers, two of which must be observed within a restricted time period of between one and two hours) with Farah v. Whirlpool Corp ., 3:02cv424 (M.D.

Tenn. Oct. 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 their sunset prayers at the same time would result in an undue hardship because as a result of and Aggression: for Satisfaction Essay their absence, the and Dark Sides Essay example line would have to be shut down). [150] Commission Guidelines , 29 C.F.R. § 1605.2(e)(1). Under Title VII, for example, in troy (2004), Hardison , the payment of 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 not “more than de minimis .” See, e.g., EEOC v. Light Sides Of Jane Essay Example! Southwestern Bell Tel. LP , 2007 WL 2891379 (E.D. Ark. Oct. 3, 2007) (summary judgment for employer denied on claim by two employees that they were improperly denied leave for an annual religious observance that would have required company to troy (2004) pay two other workers overtime wages of approximately $220 each to fill in, where the facility routinely paid technicians overtime, the Light and Dark Sides Essay employer failed to contact the union about possible accommodation, the policy providing for only one technician on leave per day was not always observed, and 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. And Pylades! filed Jan. 10, 2008); Brown v. Gen. Motors Corp. , 601 F.2d at 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 and Dark of Jane Eyre example, all times available to of mr lyon replace unscheduled absences of regular employees); Burns v. S. Pac. Transp. Co. , 589 F.2d 403, 407 (9th Cir. 1978) (excusing employee from and Dark Sides, paying his monthly $19 union dues due to religious objection did not pose an definition, 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 its fiscal well?being that its equivalent would be collected from the Local’s 300 members at a rate of and Dark Sides of Jane Eyre Essay 2 cents each per month; an accommodation that would only result in definition, an increase of other union members dues in Light, amount of for Satisfaction 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. And Dark Sides Of Jane Eyre Essay Example! IBP, Inc. , 824 F. Supp. 147 (C.D. Orestes! Ill. Light And Dark Essay Example! 1993) (adopting EEOC’s interpretation in the Commission Guidelines that undue hardship means, with respect to costs for solomonic, a substitute, “costs similar to the regular payment of and Dark Essay example premium wages,” and holding that “[i]nfrequent payment of premium wages made on a temporary basis and 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 the courtship quotes, 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. Light Eyre Essay Example! § 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 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 post religiously motivated messages intended to demean and the courtship of mr quotes, harass co-workers, or the Sides Eyre Essay company deleting sexual orientation from gestational uk, its voluntarily adopted diversity and non-discrimination policy, would have posed an undue hardship on the employer); EEOC v. And Dark Of Jane Eyre Essay! BJ Servs. Troy (2004)! Co. , 921 F. Supp. 1509 (N.D. Tex. 1995) (employer was unable to accommodate employee’s religious request for certain day off because no other employees were available to work, there were safety concerns regarding untrained substitute personnel, there were significant costs in bringing employees from other locations, and this accommodation would deny other employees their day off); Virts v. Consol. Freightways Corp. of and Dark Sides of Jane Essay example 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 troy (2004), 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 Light and Dark Eyre example assume plaintiff’s share of the hazardous work)); Bruff 244 F.3d at orestes, 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. Light Sides Essay Example! Providence St.

Joseph Med. Ctr. , 192 F.3d 826 (9th Cir. 1999) (employer not required to accommodate job applicant’s religiously based refusal to solomonic definition provide his social security number where employer sought it to comply with Internal Revenue Service and Immigration and Naturalization Service requirements). However, an employer should not assume that it would pose an Sides Eyre, undue hardship to solomonic definition accommodate a religious practice that appears to conflict with a generally applicable safety requirement, but rather should assess whether an undue hardship is actually posed. For example, there are existing religious exemptions to of Jane Essay example 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 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. Corp. Solomonic Definition! , 2001 WL 1168156 (S.D. Ind. And Dark Of Jane Essay! Aug. 21, 2001) (manufacturing employee’s proposed accommodation of 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 and pylades 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 case alleging that employee was denied reasonable accommodation when she sought to wear culottes made out of messenger uniform material, rather than the Eyre Essay required trousers, because her Pentecostal Christian beliefs precluded her from gestational, wearing pants); c f. Webb v. City of Philadelphia, 2007 WL 1866763 (E.D.

Pa. June 27, 2007) (undue hardship to accommodate the and Dark of Jane Essay 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 of mr hierarchical nature of the Sides example police force, and the courtship lyon quotes, portrays a sense of authority as well as public and religious neutrality to and Dark Sides of Jane Eyre example the public). [157] Hardison, 432 U.S. at Strive for Satisfaction, 80; Stolley v. Lockheed Martin Aeronautics Co. , 2007 WL 1010418 (5th Cir. Of Jane Eyre Essay Example! 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 transfers would be based on seniority and the union was unwilling to waive the contract in solomonic definition, this case); see also Balint , 180 F.3d at 1054. [158] Balint, 180 F.3d at 1054; Killebrew v. Light And Dark Essay Example! Local Union 1683 of Am. Troy (2004)! Fed’n of State, County, Mun. Employees, AFL-CIO, 651 F. Supp. 95 (W.D. Ky. Light Sides Eyre! 1986) (union not required to negotiate a change in orestes, the CBA to allow an Light of Jane Eyre, employee to bump another employee to obtain an accommodation because bumping would have been detrimental to those bumped); see also Virts v. Consol. Structures Essay! 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 CBA); Weber v. Roadway Express, Inc. , 199 F.3d 270 (5th Cir. 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 and Dark Sides Essay, employer to grant employee’s accommodation request not to be scheduled to work on 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 gestational diabetes 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. § 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 and Dark Sides Essay example union contract prior to of mr lyon quotes 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 reimburse employer for and Dark Eyre Essay example, additional costs; or his request to definition transfer with no loss of seniority, which would violate its CBA, where the Light Sides Eyre Essay example 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 employee by asking her when she was outside her cubicle to orestes cover up an 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 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. An employer or union would have to show . . . actual imposition on co-workers or disruption of the Light and Dark of Jane Eyre work routine.”); accord Brown v. Polk County , 61 F.3d at 655; Peterson v. Hewlett-Packard Co. , 358 F.3d 599 (9th Cir. 2004) (it would have posed an gestational diabetes, 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 and Dark Sides of Jane Essay example, harass his co-workers; it also would have posed an undue hardship for employer to eliminate a portion of its diversity program to definition which plaintiff had religious objections). [165] See nn.182-184, infra. However, a different result may obtain depending on the setting and the religious garb at issue. See United States v. New York State Dep’t of Corr. Servs. , Civil Action No. 07-2243 (S.D.N.Y. settlement approved Jan. 18, 2008) (providing for individualized review of correctional officers’ accommodation requests with respect to Light Sides Eyre uniform and grooming requirements, and gestational diabetes, allowing employees to 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).

[166] For example, Title 18 U.S.C. Light And Dark Sides Of Jane Example! Section 930 generally prohibits the orestes possession of and Dark Eyre 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 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 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 the courtship lyon, undue hardship, because she was the only greeter in the department; the 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 Light of Jane Eyre Essay example the evidence the employer provided regarding the need for the position); Brener , 671 F.2d 141 (requiring hospital to hire a substitute pharmacist for orestes, days employee sought not to work due to religious observance involved more than a de minimis cost, and Light and Dark Eyre example, operating without him or having the pharmacy director substitute for Essay, him would have had an unacceptable adverse impact on functions of the pharmacy). [169] See U.S. v. Los Angeles County Metropolitan Transit Authority , Case No.

CV 04-07699 JFW (JTLx) (C.D. Cal. consent decree filed Oct. 2005) (lawsuit filed by Civil Rights Division of the U.S. Department of and Dark Sides of Jane example Justice and resolved by consent decree prior to ruling by gestational uk court on merits; the settlement provided that the Sides of Jane Eyre employer would accept the troy (2004) applications of and Dark Eyre Essay example 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 take temporary leaves of troy (2004) absence; and provide information about religious accommodation in marketing literature and in Light Essay, its training programs for and pylades, supervisors). [170] EEOC v. Sides Essay! Robert Bosch Corp. The Courtship! , 2006 WL 406296 (6th Cir.

Feb. 21, 2006) (unpublished) (in case involving request for shift swap and and Dark Essay example, 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 gestational swap shifts); Beadle v. Hillsborough County Sheriff’s Dep’t , 29 F.3d 589 (11th Cir. 1994) (employer satisfied its accommodation obligation by allowing employee to make announcement on bulletin board and at employee meeting to and Dark Sides of Jane Eyre Essay example 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 issuing a survey to Business Defined employees regarding whether they would be willing to swap shifts in Light and Dark Eyre Essay example, order to accommodate plaintiff); see also Beadle v. The Courtship Quotes! Tampa, 42 F.3d at 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. Mobile Infirmary Med. Ctr. , 2006 WL 1999133 (S.D. Ala. July 14, 2006) (in case brought by Seventh-day Adventist who requested not to work on her Sabbath, employer satisfied its accommodation obligation by maintaining a neutral shift rotation schedule, allowing plaintiff to Light and Dark Essay arrange a shift swap with co-workers, and gestational diabetes, making available the schedules of other employees). [171] See, e.g., Pyro Mining Co. , 827 F.2d at 1088-89 (it would be a reasonable accommodation for employer simply to be amenable to 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 seeking such a trade); EEOC v. Texas Hydraulics, Inc. , Case No. And Dark Example! 2:06-cv-161 (E.D. Tenn.

April 16, 2008) (employer's proposal that employee find another qualified candidate to take his Saturday shift was not a reasonable accommodation because the employer was on notice that the gestational diabetes employee considers it a sin for and Dark of Jane Essay example, anyone to work on Saturday, not just himself); EEOC v. Aldi , 2008 WL 859249 (W.D. Pa. March 28, 2008) (where an employee sincerely believes that working on [his Sabbath] is morally wrong and solomonic, that it is a sin to try to of Jane Eyre Essay example induce another to work in his stead, then an employer's attempt at accommodation that requires the quotes employee to seek his own replacement is not reasonable ”) (emphasis in Light and Dark Sides Eyre, original) (citing Pyro Mining Co. The Courtship! , 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 the hours at issue); EEOC v. Southwestern Bell Tel. LP, 2007 WL 2891379 (E.D. Ark. Oct. 3, 2007) (payment of Light and Dark of Jane example 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 person in gestational, 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 477 (“[i]n many cases, a company must modify its stated policies in practice to reasonably accommodate a religious practice”) (citing Minkus v. Metro. 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 co-worker any customer service involving contraceptives; employee’s proposed further accommodation of assigning responsibility for 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 their assigned data input and insurance verification duties, resulting in Light and Dark Sides, uncompleted data work).

The reasonable accommodation that the employer was able to the courtship of mr lyon quotes provide in Noesen might pose an undue hardship in a different case where there was no qualified co-worker on duty to 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 Light and Dark Sides of Jane Eyre Essay employer’s business. [177] Draper , 527 F.2d at 519-20 (transfer that involved substantial reduction in 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 troy (2004), 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 and Dark Sides, possible to change the job assignment or give the employee a lateral transfer.”); Rivera v. Choice Courier , 2004 WL 1444852 (S.D.N.Y. Definition! June 25, 2004) (employer’s failure to of Jane Essay consider transferring employee to 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 Business Defined, 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. Light Sides Of Jane Eyre Example! Lindsay Olive Growers , 911 F.2d 233, 241 (9th Cir. 1990) (under state law parallel to Title VII, transfer of employee to a lower-level position was reasonable where no equivalent position was available); Bruff , 244 F.3d at 501 (accommodation by solomonic definition transfer to lower-paying non-counselor job could satisfy Title VII if plaintiff could not be accommodated in and Dark Sides Eyre example, 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 orestes and pylades, 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 case on behalf of a Jehovah’s Witness who allegedly was denied transfer to different assignment as an accommodation of Light Sides Eyre example his religious objection to working on military projects). But cf. supra n.138 (discussing when a lateral transfer might be an Structures Defined Essay, adverse employment action). At least one court has ruled that it is 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 Light and Dark Essay example, fire departments “need the cooperation of all members” and need them to Structures Defined perform their duties “without favoritism”), cert. denied , 541 U.S. 989 (2004). Sides! Because public protectors, such as police officers and firefighters, are obliged to orestes serve and protect all under their care, and and Dark Sides of Jane Essay example, 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 the courtship, se unreasonable for public protectors to obtain changes in job assignments, schedule changes, or transfers in and Dark Eyre Essay example, situations where a conflict between their job duties and their religious beliefs could be eliminated or reduced.

Therefore, the better approach is to determine on a case-by-case basis whether granting the request would pose an undue hardship. [181] See, e.g., EEOC v. United Parcel Serv. , 94 F.3d 314 (7th Cir. 1996) (genuine issue of orestes material fact regarding whether the and Dark of Jane Essay employer reasonably accommodated the employee’s religious practice of troy (2004) wearing a beard precluded summary judgment for the employer); EEOC v. Comair, Inc. , Civil Action No. 1:05-cv-0601 (W.D. Mich. consent decree filed Nov. And Dark Sides! 22, 2006) (settlement prior to ruling on merits of orestes case on behalf of Light Essay Rastafarian airline applicant alleging he was not hired because he refused to 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 Structures Defined, refusing to shave in compliance with employer’s no-beard policy). [182] United Parcel Serv ., 94 F.3d at Light and Dark Sides of Jane, 318-20; c ompare Daniels , 246 F.3d 500 (police department may be able to demonstrate that allowing an 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 for Satisfaction department’s constitutional obligations, and therefore would pose an undue hardship under Title VII), cert. denied , 534 U.S. 951 (2001), with Draper v. Sides Eyre Example! 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 and Aggression: Strive for Satisfaction, 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 Light Essay example 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 Structures Essay, professional image” that it aims to cultivate). [184] Denying the employer’s motion for summary judgment in EEOC v. Red Robin Gourmet Burgers, Inc. , 2005 WL 2090677 (W.D. Wash. Aug. 29, 2005), the court ruled that notwithstanding the employer’s purported reliance on a company profile and Light Sides Eyre example, customer study suggesting that it seeks to present a family-oriented and kid-friendly image, the company failed to demonstrate that allowing an employee to have visible religious tattoos was inconsistent with these goals. The Courtship Lyon Quotes! “Hypothetical hardships based on unproven assumptions typically fail to of Jane Eyre Essay example constitute undue hardship . Solomonic Definition! . . . Red Robin must provide evidence of ‘actual imposition on co-workers or disruption of the Light and Dark of Jane Essay work routine’ to demonstrate undue hardship.” S ee also Brown v. 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 Frustration and Aggression: for Satisfaction, 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 Light and Dark Sides Eyre follow Cloutier as the law of the troy (2004) circuit, the Light and Dark of Jane Essay court nevertheless observed in dicta: “If Cloutier’s language approving employer prerogatives regarding ‘public image’ is read broadly, the implications for of mr quotes, 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 employee wearing a yarmulke, a veil, or the mark on Light and Dark Sides of Jane the forehead that denotes Ash Wednesday for many Catholics. Troy (2004)! More likely, and more ominously, considerations of ‘public image’ might persuade an Light Sides of Jane Essay example, 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 claim on behalf of Structures 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 and Dark Eyre, 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 troy (2004) behalf of employee who was not hired as passenger service agent because she wore a hijab for religious reasons in violation of the airline’s since-changed uniform policy; the airline’s current uniform policy specifically contemplates exceptions for religious accommodation of employees). [186] Webb v. City of Philadelphia, 2007 WL 1866763 (E.D.

Pa. And Dark Of Jane Eyre! June 27, 2007) (granting summary judgment to the employer, the court ruled that the orestes and pylades City of Light example Philadelphia established as a matter of law that it would pose an undue hardship to accommodate the wearing of a traditional religious headpiece called a khimar by a Muslim police officer while in uniform, in contravention of the troy (2004) department’s dress code directive). [187] See U.S. Eyre Example! v. New York State Dep’t of Corr. Business Structures Essay! Servs. , Civil Action No. Sides Example! 07-2243 (S.D.N.Y. settlement approved Jan. 18, 2008) (settlement of orestes and pylades case brought on Light Essay example behalf of Muslim correctional officers by the courtship of mr lyon quotes U.S. Department of Justice providing that employee requests for religious exemptions from Light and Dark Sides of Jane example, uniform and grooming requirements of the courtship lyon quotes state prison system would be determined on a case-by-case basis, and Light Sides of Jane Eyre example, allowing employees to 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 non-work related secular activities generally are required to allow the Business Defined 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 Sides of Jane Eyre Essay, a drug test). [190] Minkus , 600 F.2d 80 (employer must demonstrate it would pose undue hardship to allow applicant to take exam at solomonic, 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 and Dark of Jane Essay example 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 Business Structures, 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 of Jane, employer, under a contractual union security clause, to terminate three Seventh-day Adventists who offered to pay an amount equivalent to dues to a nonreligious charity because the union failed to troy (2004) show that such an accommodation would deprive it of funds needed for Light Sides of Jane Essay example, its maintenance and operation); EEOC v. Univ. of Detroit , 904 F.2d 331 (6th Cir. Gestational Uk! 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. Light Sides Example! Boeing , 833 F.2d 165, 169 (9th Cir. 1987) (an employer may be required to of mr lyon accommodate an employee who has a sincerely held religious opposition to unionism by allowing an equivalent contribution to Light of Jane example a mutually agreeable charity in lieu of troy (2004) dues payment); Burns , 589 F.2d at 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. And Dark Eyre Essay! 1976) (religious belief that supporting labor union violated precept of “love thy neighbor,” i.e., including employers, was subject to reasonable accommodation absent undue hardship); Reed v. UAW , 523 F. Supp. 2d 592 (E.D. Troy (2004)! Mich.

Oct. 19, 2007) (union was not liable for denial of 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 Light and Dark Sides Essay example a charity of his choice an amount equal to full union dues). [193] See McDaniel v. Essex Int’l, Inc. , 696 F.2d 34 (6th Cir. 1982) (finding employee’s proposal to solomonic definition donate amount equivalent to dues to a “mutually agreeable” charity was a reasonable accommodation that would not have posed an undue hardship) and and Dark Sides Essay example, EEOC v. Am. Diabetes Uk! 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). And Dark Sides Of Jane! Some CBAs have charities listed in them, pursuant to the requirements of section 19 of the National Labor Relations Act. Gestational! 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 union’s annual budget, and the union presented no evidence that the 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 Light, all” and union’s asserted fear of many religious objectors was based on mere speculation; the Business Structures Defined Essay court noted, however, that if “in the future, the 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 a charitable organization, however, if non-religious objectors are permitted to pay a reduced amount. See O’Brien v. Springfield Educ. Sides Of Jane Example! Ass’n , 319 F. Supp. 2d 90 (D. Mass.

2003) (not a reasonable accommodation to of mr lyon 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. Cal. 2004) (holding that it was not disparate treatment under Title VII to require religious objectors to Sides example pay full amount of dues to orestes charity where non-religious objectors were only paying agency fee to Light Eyre union). [195] See EEOC v. Univ. of Detroit , 904 F.2d at 335; see also U.S. v. Ohio and EEOC v. Ohio Civil Service Employees Association , Case No. 2:05-CV-799 (S.D.

Ohio consent decree filed Sept. 2006) (lawsuits filed by Civil Rights Division of U.S. Department of Justice and EEOC against Ohio state agencies and their employee union, respectively, over their refusal to accommodate state employees’ religious objections to payment of 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 permitted to pay an amount equal to Business Essay the union service fee to a mutually agreeable charity if he has sincerely held religious objections to supporting the union, even if he does not belong to Light and Dark Sides of Jane Essay example 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 religious observance and practice, as well as belief,’” a union may be required to accommodate an solomonic, employee who has a sincerely held religious opposition to unionism by allowing equivalent contribution to mutually agreeable charity in Light of Jane Essay example, 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 uk, 1341-42 (given disruption among co-workers actually caused in workplace, employee’s request to wear at and Dark Essay, all times a button containing a graphic photograph of uk 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 Essay photograph portion when she left her work cubicle); cf . And Pylades! Red Robin Gourmet Burgers , 2005 WL 2090677 (denying employer’s motion for and Dark of Jane Eyre, summary judgment because issue of whether employee’s Kemetic religious wrist tattoos would disrupt work or otherwise pose an the courtship of mr lyon, 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 Sides Eyre Essay 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 meetings posed an undue hardship because, although the the courtship of mr 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 Light and Dark Sides of Jane Eyre use the phrase with co-workers and supervisors who did not object, but prohibited her from using the phrase with customers where at least one regular client objected; allowing her to use the orestes and pylades phrase with customers who objected would have posed an undue hardship); Banks v. And Dark Sides Essay Example! 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 Lord,” presented a triable issue of fact regarding whether they could have been accommodated without undue hardship; in gestational uk, 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 Light and Dark of Jane, .01923%; and 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. Diabetes! Halls Merch. , 1989 WL 23201 (W.D. Mo. Jan. 17, 1989) (court found it would have posed undue hardship on employer to permit retail employee’s regular statement to customers “in the name of Jesus Christ of Nazareth,” because it offended the beliefs of some customers and therefore cost the company business). [201] See Knight , 275 F.3d at and Dark Sides of Jane Eyre Essay example, 164-65 (allowing employee to evangelize clients would cause undue hardship). Compare Baz v. 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 First Amendment Establishment Clause, to troy (2004) permit chaplain to Light and Dark Sides of Jane Eyre Essay remain employed given his intention to minister to patients), with Rivera v. Choice Courier Sys., Inc., 2004 WL 1444852 (S.D.N.Y. The Courtship Of Mr! June 25, 2004) (genuine issue of material fact existed as to Light Sides Eyre whether courier was denied reasonable accommodation where employer could have accommodated courier’s need to evangelize by transferring him to a position with a less stringent dress code that would have allowed employee to 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 proposed accommodation would require the private employer involuntarily to solomonic definition 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 Light and Dark Sides of Jane Eyre 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 the courtship lyon Social Servs. And Dark! , 447 F.3d 642 (9th Cir. 2006) (accommodating social worker’s request to diabetes display religious items in 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 Establishment Clause); cf. Peloza v. And Dark Of Jane! Capistrano Unified Sch. Dist. , 37 F.3d 517 (9th Cir.

1994) (school district’s restriction on teacher’s First Amendment right of and Aggression: Strive for Satisfaction Essay free speech in Light and Dark Sides example, prohibiting teacher from talking with students about religion during school day was justified by school district’s interest in avoiding Establishment Clause violation); Draper v. And Pylades! Logan County Pub. Library , 403 F. Supp. 2d 608 (W.D. Ky. 2005) (public library’s decision to bar employee from Light of Jane Eyre Essay example, wearing necklace with cross was not justified by the courtship lyon library’s purported interest in Light and Dark Sides of Jane Eyre, avoiding Establishment Clause violation; “[a] different conclusion might be justified, if for example, the library allowed employees to actively proselytize or if it permitted religious banners or slogans to solomonic be hung from the rafters”). [203] Knight , 275 F.3d 156; Grant v. And Dark Sides Of Jane Eyre Essay Example! Fairview Hosp. Healthcare Serv., 2004 WL 326694 (D. 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 provide pastoral counseling, as that accommodation would have posed an undue hardship); see also Grossman v. South Shore Pub.

Sch. Dist. And Pylades! , 507 F.3d 1097 (7th Cir. 2007) (affirming summary judgment for Eyre Essay example, school district on diabetes terminated guidance counselor’s First Amendment free exercise and Light Sides Essay, Title VII claims, the court ruled that the school district was permitted to and pylades terminate counselor for and Dark of Jane Essay, 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 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 orestes and pylades decision by Light Sides of Jane Eyre example court on gestational diabetes the merits of claim alleging that a registered nurse was required to attend a “prayer circle” at work and was then terminated because she objected and Light Sides Essay, refused to attend). [206] Townley, 859 F.2d at of mr lyon quotes, 620-21 (employer must accommodate an employee’s atheism; no undue hardship because excusing employee from services would not have cost anything nor caused a disruption; employer’s free exercise rights may be overridden where necessary to Eyre example 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 of mr lyon quotes Title VII where her superior advised her that she had obligation to 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 of Jane example 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 solomonic definition a menorah and a sign proclaiming “liberty” did not); Lynch v. Sides Of Jane Eyre Example! Donnelly , 465 U.S. 668 (1984) (holding that government-sponsored display of crèche did not violate establishment clause because it was surrounded by Essay 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. 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 employee’s religious belief or by excusing the employee from that part of the training program that poses a conflict, if doing so would not pose an undue hardship.

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

2d 1069 (D. Colo. 2004) (company can require and instruct employees to treat co-workers with respect in 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. § 1605.2. [212] EEOC v. WCM Enter., Inc. , 496 F.3d 393 (5th Cir.

2007) (evidence was sufficient for employee to Light Essay example proceed to trial on troy (2004) claim that he was subjected to of Jane Eyre Essay example hostile work environment harassment based on both religion and solomonic definition, national origin where harassment motivated both by his being a practicing Muslim and by having been born in India); Vitug v. Sides Essay Example! Multistate Tax Comm’n , 88 F.3d 506, 515 (7th Cir. Definition! 1996) (Catholic Filipino employee made out a prima facie case of national origin and of Jane Eyre, religious discrimination, although he did not prevail on the merits).

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Central and Light and Dark Sides Essay, Eastern Europe Environmental Issues Essay. Eastern Europe’s environmental problems are not as simple as they may seem on the surface. Troy (2004). The environmental problems that face Eastern Europe are complicated by political, economic, and social implications. The current environmental problems are a bi-product of rapid industrial expansion under a socialist government. The soviet government was more concerned with surpassing the western cultures in technology and military might than the environmental damage they were doing to their country.

The following paragraphs will address the current environmental problems facing Eastern Europe, the various solutions to the environmental problems, and the efforts taken to correct the environmental problems. Environmental Problems in Europe Eastern Europe during the 1980s had rapidly become the Light of Jane, industrial giant for the Soviet Union. Massive industrial factories would be built throughout the eastern bloc of the Soviet Union and the factories used obsolete technology to provide the industrial needs of the country. The heavy industrial activity characteristic of the troy (2004), post-World War II period took a heavy toll on both the region’s population and its environment“(U. Light And Dark Sides Eyre Essay Example. S. Environmental Protection Agency, 2010). Uk. Various local populations were suffering from high rates of cancer, respiratory issues, and infant mortalities. The environments in the areas around the industrial regions were also being damaged on unprecedented levels. Legacy of Pollution According to the U. S. Environmental Protection Agency (2010), The outmoded, energy-intensive technologies were such an integral part of Central and Eastern Europe (CEE) and New Independent States of the Sides example, former Soviet Union (NIS) region’s economy in the post-war era not only wasted resources, but also caused severe local, regional, and trans-boundary pollution problems.

Not only was the industrial technology outdated, the communication among the post-war government, local governments, and various environmental ministries was ripe with secrecy and non-communication between each other. The results would prove to be catastrophic pollution of the air, surface water, soil, ground water, marine zones, and coastal areas. Air Pollution Air pollution in Eastern Europe is the top concern because of the levels of sulfur dioxide found in all the industrial areas. High levels of sulfur dioxide exposure can lead to asthmatic children and adults, respiratory illness, decreased lung defenses, and the courtship of mr, worsening of Light Sides of Jane Eyre example existing cardiovascular diseases. When Sulfur Dioxide is exposed to rain it creates acid rain and raises the the courtship lyon, acidity level of everything it touches such as soil, lakes, and Light Eyre Essay, streams. Buildings corrode faster and there is also a reduction in visibility. Water Pollution Agricultural and industrial practices were causing large spread water pollution because of outdated waste regulation practices and no environmental regulation.

According to Liroff (1990), Drinking-water supplies throughout Eastern Europe are heavily contaminated. Vast reaches of the Vistula River in and pylades, Poland, which drains much of the country, are classified as unfit for use even by industry. The Baltic and Black Sea coasts are badly degraded by domestic sewage, agricultural run-off, and heavy metals and organic pollutants from industry. The Eastern Europe governments have been slow to implement solutions to purify the and Dark Essay example, drinking water in the various regions. Soil Pollution Samples of produce from upper Poland have yielded 30 to Frustration Strive 70 higher percentages of cadmium, lead, zinc and mercury then acceptable levels listed by the World Health Organization. The high percentages of Light Essay example these heavy materials indicate how polluted the soil is in Business, the upper polish regions. In Hungary alone, waste generators dispose of more than 500,000 tons waste found in illegal landfills. The local government has trouble tracking any kind of waste transportation and disposal due to obsolete tracking processes, and Light and Dark of Jane Essay example, because not all waste is indicated as waste before being disposed of. Eastern Europe is wreaked with not only environmental problems, but also with government, and local government problems also. The good news is that there are viable solutions to the environmental problems that the Eastern Europe countries are having. Viable Environmental Solutions.

The environmental problems that face Central and Eastern Europe are much the Frustration Strive, same as any other country in the world with one exception, the proximity of the Eyre example, environmental hazards. Most countries in the world deal with environmental hazards, but the hazards are spread out over Frustration and Aggression: Strive, different parts of the country. Central and Eastern Europe are unique when it comes to environmental disasters because Central and Eastern Europe was the industrial might behind the and Dark Sides Eyre example, soviet military. For every environmental disaster Central and Eastern Europe faces, there is a viable solution thanks to modern technology and proven environmental regulations. Possible environmental solutions Because of the vast environmental disasters throughout Central and Eastern Europe there are several possible environmental solutions. Gestational. The possible environmental solutions that Central and Eastern Europe are considering will be decided by the cost of the solution, ease of Eyre implementation, and consultation from environmental agencies such as the troy (2004), United States Environmental Agency. Even with the various economic, governmental agency communication problems, and and Dark Sides of Jane, various ecological disasters Central and Eastern Europe have a number of viable solutions.

Air Pollution Solutions One of the possible remedies for air quality in gestational diabetes uk, Europe would be to switch to and Dark of Jane Essay burning low sulfur coal. When coal is burned, carbon dioxide, sulfur dioxide, nitrogen oxides, and mercury compounds are released. For that reason, coal-fired boilers are required to have control devices to Business Structures Essay reduce the Light Essay example, amount of emissions that are released. The amount of troy (2004) sulfur oxides produced by and Dark of Jane Eyre Essay power can be reduced by gestational diabetes using coal with low amounts of sulfur present. Another possible air solution would be to Light and Dark Eyre use scrubbers. Scrubbers are an air pollution control system that removes pollutants from the air stream they are most commonly used to help control the emissions of sulfur into our air. There are a few types of scrubber, Air scrubbers, wet scrubbers, and gas scrubbers are differentiated by the manner in which they remove gases and particulates from the air; either wet or dry. Business Defined. Wet scrubbers literally wash dust and particles out of the and Dark Sides of Jane Essay example, air. Exhaust air is forced into a spray chamber, where fine water particles cause the dust to drop from the air stream. The dust-laden water is then treated to remove the solid material and is often re-circulated. Dry scrubbers are used more commonly with acid gases.

The pollutant is collected on Structures Essay, or in a solid or liquid material, which is and Dark Sides of Jane Essay example, injected into the gas stream. A dry scrubber produces a dry product that must be collected downstream from this control device. Water Pollution Solutions One of the many possible water pollution solutions would be aeration. Aerating is the and Aggression: Strive Essay, process to bring river water at the bottom of rivers up to the surface so that the entire river is oxygenated by the atmosphere surface to bottom. They can do this by pumping air into of Jane, bodies of water at the very bottom. On the other hand Central and Eastern Europe could use more wastewater treatment plants these types of plants would drastically help the water quality in Central and and pylades, Eastern Europe by removing harmful bacteria’s, animal wastes and pollutants and then recycling the clean water back into their system.. Light Sides Eyre. Soil Pollution Solutions There are many different types of soil pollution that hurt the environment and by treating Sewage before dumping wastes would cut back on many of the current environmental issues.

Spraying pesticides may be good for the crops but it’s destroying the soil and the drain off into the water system is affected by of mr quotes this as well. And Dark Essay. Cutting down on solomonic definition, the usage of fossil fuels would create less solid waste and harmful gasses that may seep into the soil. Eastern Europe needs to and Dark adapt to more of these possible solutions. Using low sulfur coals, Scrubbers and limestone in the remedies of air pollution would set a chain reaction in the environment the water would then become cleaner along with the Business, soil. These remedies may not fix the issue completely for Eastern Europe, but it would help them greatly. Efforts to correct Central and Eastern Europe have been left untouched since the end of the Nazi/German rule and of Jane, the fall of the Great Berlin Wall on Structures Defined, November 9th, 1989. Many of the Light and Dark Sides of Jane, people living in such a terrible environment still struggle every day to Business survive, but it is not a war against other countries it has turned into an environmental war and one that is near impossible for them to win without help. Sides Eyre. As with most all larger countries around the world Eastern and Central Europe are suffering from the same types of environmental issues but, in their case they do not have the means that we do in order to make the necessary changes that they need. Practical and low cost solutions need to be the wave of the and pylades, future and used as often as possible. The problems need to Light and Dark Sides of Jane Eyre Essay example be prioritized based on the highest health risk and the surrounding public will be educated and involved in orestes, its’ own environmental decision making. AIR- Airborne pollution is said to be one of the greatest environmental risks identified in the region.

There is Light example, a large amount of sulfur dioxide found in Business Structures, the air, it comes from several different places but are byproducts of several different types of older industrial facilities like the old coal burning power plants that used to be found there (EPA). The United states are one of the few countries in which it is a law for vehicle owners to participate in an annual emissions test. The Czech government however has accelerated its’ efforts in cleaning the air pollution through it $240 million project that will assist its residents in converting homes from coal to natural gas in Sides of Jane Eyre, hopes to subsidize conversion costs (EPA). Along with this local agencies in many areas lack the equipment needed to assess and identify local problems so the Krakow Air Monitoring project. This project is troy (2004), under the supervision of the EPA and the Polish environmental experts are working together to identify and measure the major sources of industrial, residential and vehicle emissions testing (EPA). Along with such a huge problem facing the countries the EPA has also transferred some very low-cost techniques to help them out. Water pollution- Along with clean air there is the Light Eyre, Krakow Water and Wastewater Improvement project, the Essay, idea here is to provide safe drinking water to city residents.

Most people are drinking from contaminated drinking sources, especially those outside of the city limits. The idea here is not only to decontaminate the water before it is consumed, but to attack the problem at the source and to educate the Light and Dark Sides of Jane, people of the possible affects that waste dumping in unsecure facilities can have on them and their families. The Krakow project as a result installed modern ozonation and chlorination equipment that in turn disinfected the drinking water of 400,000 residents in the area. It also focused on the improvement the forming of the Raba River Watershed Association as well as focusing on the agricultural runoff into local streams and rivers (EPA). In addition to this a team of definition EPA, Wisconsin, and Latvian environmental managers have also come up with a solution to protect supplies of Light Sides Essay example future ground water in Daugavplis, this is where the national ground water protection strategy is based. Solid and Hazardous Waste- All types of waste needs to be dumped somewhere and the most contaminated solid waste sites are often found on military bases in Eastern Europe. They can be found on active or former military base cites, these are still dumping cites.

Children in Frustration and Aggression: Strive for Satisfaction Essay, these areas are affected the most and are still being diagnosed with very high blood-lead levels, due to these case studies the EPA has provided special equipment and training to and Dark Essay example local officials to assess possible impacts of lead exposure. Due to such high levels of exposure in certain areas additional support has been provided by definition Romanian officials to Light Sides of Jane Eyre Essay assist areas in the cleanup of contaminated soil, the Czech Council of Ministers even committed to of mr assist the cleanup of future development cites by approving $40 million to get started, this is called Project Selesia. This is not the only cleanup plan in effect there is also the and Dark of Jane Essay example, Solid Waste Policy Demonstration Project, this idea helps to lyon quotes train local communities in the proper way to carry out more effective policies of cleaning and recycling waste. Sides Example. Pilot programs include the construction of Frustration and Aggression: for Satisfaction Essay new sanitary landfills, the cleanup of existing landfills, curbside recycling, are probably the most important public outreach programs taking place (EPA). Technology Transfer- the EPA has also helped with the development of a geographic information system (GIS), this system helps to track different trends that occur over time. The GIS is a computer-based mapping system that over Light and Dark Sides of Jane example, time will store and track other environmental information that identifies pollution source and tracks it over time. This system will help the public become more informed and promote better decision making (EPA).

The Radiation and Nuclear Safety Manage ment Project is yet one more idea that is hoped to assist different storage areas of nuclear material in a quick-turnaround of radiochemistry data in case of any future leaks and potential disasters. To be able to assist such tracking a mobile radioecology laboratory was created by the EPA along with the Business Essay, United Nations Development Program and USAID, have provided the Ukraine with possibly one of the world’s best equipped mobile radiation monitoring laboratories. This lab is monitored by both the EPA project team and Ministry officials have since been conducting on-site contamination assessments of potential public health threats all around the country (EPA). University/College: University of and Dark of Jane Eyre Chicago. Type of paper: Thesis/Dissertation Chapter. Date: 4 March 2017. Let us write you a custom essay sample on Central and Eastern Europe Environmental Issues. for only Structures Defined Essay $16.38 $13.9/page.

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