Scholarly Commons @ IIT Chicago-Kent College of Law

Article Title

Honor Thy Father and Thy Mother: Religious Accommodation Under Title VII in Adeyeye v. Heartland Sweeteners, LLC

Authors

Zeke Katz, IIT Chicago-Kent College of Law

Abstract

Title VII of the Civil Rights Act provides that an employer must reasonably accommodate an employee's request for a leave of absence due to a religious observance or practice, as long as that accommodation does not present an undue hardship for the employer. The amendments to Title VII, and the Guidelines issued by the Equal Opportunity Employment Commission in response to Title VII, reveal a trend towards a broad interpretation of religious accommodation in the workplace. The Seventh Circuit Court of Appeals continued and exemplified this trend in Adeyeye v. Heartland Sweeteners, LLC.

In Adeyeye, where an employee requested a leave of absence to attend his father's funeral ceremony in Africa, the Seventh Circuit presented a liberal understanding of religious accommodation and acknowledged a variety of non-traditional and less common religions. The court analyzed whether the employer, Heartland Sweeteners, LLC, provided sufficient accommodation for Adeyeye's religious request, or in the alternative, whether the employer showed that this request would present Heartland with an undue hardship. The court found that Adeyeye's request arose from a sincere religious belief and would not have presented Heartland with an undue hardship.

This Article explains the Seventh Circuit's interpretation of religious accommodation in the workplace by looking to the amendments of Title VII, the relevant EEOC Guidelines, and the recognition of sincere religious beliefs by the Supreme Court in cases regarding conscientious objectors. This Article asserts that the Seventh Circuit's decision in Adeyeye reflects the appropriate tolerant statutory interpretation of Title VII regarding reasonable accommodations for religious requests. This decision came from the movement towards greater religious acceptance and understanding as reflected in the statutory language of Title VII and the evolution of the EEOC Guidelines.

Recommended Citation

Zeke Katz, Honor Thy Father and Thy Mother: Religious Accommodation Under Title VII in Adeyeye v. Heartland Sweeteners, LLC, 9 Seventh Circuit Rev. 110 (2013).
Available at: https://scholarship.kentlaw.iit.edu/seventhcircuitreview/vol9/iss1/6