A recent Sixth Circuit holding affirmed a federal district court’s ruling that an employer did not violate Title VII of the Civil Rights Act of 1964 by declining to hire a prospective employee because he refused to provide his social security number on religious grounds.
The plaintiff applied for an internship with the defendant, an energy company. However, he refused to provide his potential employer with a social security number. The plaintiff asserted that he did not have a social security number because he disavowed it upon turning 18 due to his sincere religious beliefs. When the defendant refused to hire him, he filed suit alleging religious discrimination in violation of the Civil Rights Act. The defendant filed a motion to dismiss for failure to state a valid legal claim pursuant to Fed. R. Civ. P. 12(b)(6). The district court granted the motion.
A person who files a Civil Rights Act religious discrimination claim must prove three elements:
- There was an employment requirement that conflicts with a genuine religious belief held by the plaintiff;
- The plaintiff advised the employer of the belief; and
- The employer terminated or disciplined the plaintiff for refusing to comply with the employment requirement.
The issue before the court was whether the district court correctly granted the defendant’s motion to dismiss. Therefore, after the plaintiff established his prima facie case by proving the elements above, the defendant had to show that it could not reasonably accommodate the plaintiff’s religious belief without incurring an undue hardship.
The Sixth Circuit affirmed the district court’s ruling because complying with the plaintiff’s religious beliefs would violate federal law. Since it was federal law that required employers to collect their employee’s social security numbers, the plaintiff’s religious belief did not conflict with an employment requirement. Instead, it was a requirement imposed by law. Therefore, the plaintiff could not establish the first element of a religious discrimination case.
In addition to the reasoning adopted by the Sixth Circuit, it signaled that these types of claims might fail because accommodating these beliefs would impose an undue hardship on the employer.
The court’s holding affirms established case law that prevents Tennessee employees from bringing a Civil Rights Act claim for religious discrimination in the event that the plaintiff’s religious belief requires the employer to violate federal law.
If you have been fired or been denied employment because of a religious belief, you may have a discrimination claim under Title VII of the Civil Rights Act of 1964. The Tennessee employment discrimination attorneys at Parks, Chesin & Walbert have helped clients fight the discriminatory practices of employers in Georgia and Tennessee. We can help you protect your religious beliefs. To schedule a free case evaluation, call 404-873-8048.
A Look at Recent Title VII Decisions, December 10, 2014