Accommodation of Religious Beliefs Does Not Require Violation of Federal Law
Is an employer required to disregard other federal laws in order to reasonably accommodate an employee’s religious beliefs? The Sixth Circuit (covering Ohio, Kentucky, Tennessee, and Michigan) responded with a resounding “no” in Yeager v. FirstEnergy Generation Corporation.
Mr. Yeager refused to provide a Social Security number to his prospective employer. His refusal was premised on his sincerely-held religious beliefs. FirstEnergy, in turn, rejected his application. Yeager filed a Title VII and Ohio religious discrimination lawsuit.
Yeager’s claims were dismissed. To establish a base claim of religious discrimination, Yeager had to prove:
- he held a sincere religious belief that conflicts with an employment requirement;
- he informed his employer about his conflicts; and
- he was not hired because he failed to comply with that employment requirement.
If Yeager established a base claim, then FirstEnergy would have the burden to show it could not reasonably accommodate Yeager’s religious belief without “undue hardship.”
FirstEnergy contended the collection of an applicant’s Social Security number was not an “employment requirement.” Rather, it was imposed by the Internal Revenue Code. The federal appellate court did not parse words in its decision.
Whether the Social Security number was a legal (and not an employment) requirement or whether the violation of a federal law, such as the Internal Revenue Code, would impose an undue hardship, FirstEnergy prevailed. Title VII does not require an employer to reasonably accommodate an employee’s (or applicant’s) religious beliefs if such accommodation would violate a federal law.