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Federal Appeals Court Explains What Can Qualify as a Religion for the Purposes of an Anti-Discrimination Claim

Anti-discrimination laws are clear that an employer cannot discriminate against employees based upon their religion. This, however, leads to another question:  what does or does not count as a religion under federal law? One recent case involving a hospital worker offers some perspective on this issue. Although the worker lost his discrimination case, the court’s opinion makes it clear that the range of beliefs that qualify as a religion is broader than one might assume. For advice about this and other areas of employment discrimination law, talk to a knowledgeable New Jersey religious discrimination attorney.

The hospital worker, Paul, had been an employee of a Catholic hospital in southwest Philadelphia since 1994. In 2012, the hospital required its employees to receive a flu vaccination or else submit a form indicating that the employee was medically exempt or exempt based upon religious beliefs.

Paul did not belong to any organized religion. He held strong personal convictions when it came to receiving vaccines, but they were not connected to any religion. In the first two years, Paul submitted the religious exemption form with a lengthy piece of prose explaining his beliefs. Each time, the hospital granted him an exemption. In 2014, the worker submitted the same paperwork and essay. This time, the employer denied the exemption. It required that Paul provide a letter from a clergyperson related to his beliefs, which he could not do. On Dec. 31, 2014, the hospital terminated the worker for not complying with the flu vaccination rule.

Paul eventually sued his former employer for religious discrimination and failure to accommodate in violation of Title VII. Paul lost his case in both the trial court and the appeals court, but his defeat is very useful and instructive for other employees who might need to pursue a Title VII religious discrimination case in the federal courts.

The key to the employee’s unsuccessful outcome in this case was the nature of his beliefs. If the worker’s views stated in his essay were enough to meet the legal definition of a religion, he had a valid Title VII claim. If they didn’t, he did not. Paul’s generalized anti-vaccination views were not enough to amount to a religion, according to the courts. His beliefs didn’t address “deep and imponderable matters,” and they weren’t comprehensive; he just didn’t believe in vaccines. No matter how strongly held, Paul’s beliefs weren’t religious. Had Paul been a Christian Scientist or a member of the Dutch Reformed Church and based his beliefs on his practice of those religions, he might have obtained a different outcome.

While this employee’s beliefs regarding vaccines were not a religion, the court’s opinion is helpful in pointing out that the legal definition of “religion” in terms of discrimination law is broader than you might think. For example, your beliefs do not need to have a focus upon God or any divine being(s) in order to qualify; non-theistic religions can still entitle an employee to an accommodation. Thus, whether you are Christian or Druid, Jewish or Pagan, Muslim or Wiccan, you are still entitled to be free from discrimination based upon your religion.

This worker lost his religious discrimination case, but his case had a specific set of facts that worked against him. Federal law actually acknowledges a wide array of beliefs as valid religions for the purposes of Title VII discrimination lawsuits. For advice and representation with regard to your religious discrimination or other employment discrimination issue, talk to the skilled New Jersey religious discrimination attorneys at Phillips & Associates. If you believe you’ve been treated adversely at work due to your religion, contact us online or at (609) 436-9087 today to set up a free and confidential consultation. Talk to one of our attorneys to find out how we can help you.

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Nurse Who Pursued Her New Jersey Race Discrimination Case Without Legal Representation Does Not Meet with Success, New Jersey Employment Lawyer Blog, Dec. 26, 2017

Bipolar Disorder and Legal Protections Against Disability Discrimination in New Jersey, New Jersey Employment Lawyer Blog, Dec. 11, 2017

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