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Cause and Effect Essay: Divorce Causes Problems For Children
book report 1 Collins, Suzanne. Mockingjay. Essay? New York, New York: Scholastic. Term Paper? September 30, 2012. Reason, Type and Setting: I selected this book because the last two books I have read were from the Hunger Games series. I love the Hunger Games books because they are action packed with the essay, right amount of suspense. Mockingjay falls under science fiction, young adult, and theoretical, even a little tragedy and romance. Of Divorce? My book takes place in a post apocalyptic United States. It takes place in the future but there was never a specified date in the books. There were a few major conflicts in the story.
The main conflict of the story was of Peeta’s kidnapping. Katniss managed to escape out of the arena and reach District 13 as Peeta was captured by President Snow’s minions. Essay? Throughout almost half the story, she worked to get him out of divorce from the Capitol and back with her. Once they got him back, he was brainwashed by Snow and him and Katniss were never the mcgraw hill accounting homework answers, same. One other conflict was who Katniss loved, Peeta or Gale. Of Divorce? She was conflicted throughout the book and even the foreign policy theoretical, two past books, but she had believed she would pick Gale because Peeta was so crazy since he was brainwashed. Over time, Peeta slowly but surely found himself again and him and Katniss lived happily ever after together.
They settled down and had two kids in essay of divorce District 12. The last conflict was her going through with being the Ancient em, Mockingjay, the face of the essay, rebels. As time went on and the more involved she was in the war, she realized how so many people are sacrificing and dying for her to overturn the Capitol. She wanted to american foreign policy theoretical quit many times throughout the book, and it really hit her hard when she saw her sister die. What was really surprising is with all the pain Snow brought to her and the rebels, she chose to kill President Coin instead of essay of divorce, President Snow since Katniss had found out that Coin had killed her sister. Snow ended up dying as well but not by Katniss. Peeta is a white teenager with a stocky build.
He has blonde hair with blue eyes. He had two legs but one was lost after the 74th Hunger Games. He was forced to get his leg amputated and he later got a prosthetic leg. Peeta is phonemic script a very peaceful and dependable person. Of Divorce? He is also strong, and very intelligent as it showed through his actions in the Hunger Games. Peeta was the second main character of the story, and plays a huge role in the story. He is the american policy theoretical, person who kept Katniss fighting throughout the war. With Peeta dead, Katniss knew she would have lost her drive to fight.
So Peeta in essay of divorce a way was Katniss’ “fire”. He was also part of the “Team Gale” and “Team Peeta” controversy. Throughout the series, readers wondered if Katniss would end up loving either Gale or Peeta. She ended up with Peeta. I picked this character because he never seemed like such an important person, but as you read more and more, you realize that he is so vital to Katniss’ life. When you read about him being brainwashed, you get the sad feeling that him and Katniss will never have the how to writing, same relationship, and it is sad as a reader to know that. In the end, Peeta was his old self again and him and Katniss get to live their life that they always wanted, which is happy to know.
What interests me about Peeta is his love for Katniss. When he was brainwashed, he hated her since he didn’t know any better. Once he was getting therapy he was still not the essay of divorce, same, but you could see that little spark in Peeta that he is outdoors essay trying to get his old life back, fighting for essay of divorce, Katniss. Throughout all these books Peeta has fought so hard just so Katniss could be his, and it is hard to believe he even went through war and for psychology class, abuse for her. You never realize it until after you finish the essay, book and think about it. The plot was the reason why Peeta was kidnapped, the outdoors essay, reason why he was brainwashed, and essay, why Katniss and Peeta went through all these hardships just to go back to normal.
All in phonemic script all, this was a good novel. Essay Of Divorce? Right after I had finished reading the book I thought that the ending was bad since I wanted Katniss to pick Gale over Peeta. After thinking through everything that had happened it did not really matter to me and I was just happy what Katniss had did when she was going to execute Snow. (If you did not know, she killed President Coin instead of Snow (the president that came into power after Snow)) This book was very interesting and entertaining because the book kept me on my feet and kept me guessing, two things that I need in a book. It had also informed me of an idea of how countries with dictators work. The dictator is class so overbearing and controlling that it just makes the citizens want to rise up and rebel. Life lessons to remember from Mockingjay is to fight for what you believe in.
Do not be pushed around by others. Do not listen to those overbearing, controlling, and violent people, fight for your rights and your freedom. Of Divorce? I would definitely recommend this book to people if you love action and term for psychology class, suspense. The feeling of reading this book and thinking that the outcome of something will be this, but is something totally different is what makes a book a page turner. Of Divorce? This book compares to real life situations like North Korea. Both of these countries are led by a dictator. Both countries experience the lives they are forced to live by everyday. This book reminds me of the how to writing, Civil War. A group wanting to control and dictate a group of people, and another group who wants equality and freedom for all. This relates to essay the book and how Katniss and the rebels fought back for their freedom.
This book is important for others to read because within this book are life lessons to american essay foreign policy be learned. This book is essay of divorce not just for mcgraw answers, reading, but to learn lessons for essay, the future and to inspire others. If I were to paper for psychology be in the main character’s shoes, I would not act the same way because I would not have that drive to fight like Katniss did. I do not have someone that important in my life like her. Some other conclusions that the author could have ended with is of divorce same ending but Katniss ends up with Gale. Another would be for Katniss to become the leader of Panem instead of just settling down and having kids. I would have wanted to Ancient em either become the leader of Panem or her dying so the rebels could succeed in taking over Panem.
Author, Context and Trivia: Suzanne Collins is most known for writing her Hunger Games trilogy, which included Hunger Games, Catching Fire, and Mockingjay. Essay Of Divorce? Another series she is well known for is the Underland Chronicles Series and phonemic script, then the book When Charlie McButton Lost Power. Collins has also worked on Nickelodeon TV shows and other children books. Of Divorce? This book does not remind me of any other books I have read. The only book I could compare Mockingjay with is its’ sister book The Hunger Games. I do not read much, and books I have read have had the outdoors essay, same aspects of action and suspense, since I need that to keep me interested. The books I have read never had the same theme of rising up against essay, a country or rebellion. I do not plan to read any more books from for psychology, this author since she isn’t an author that focuses on action and suspense.
I do plan on reading types of books like this though, since I love books with suspense and action.
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George Orwell: ‘Nineteen Eighty-Four’ Newspeak was the official language of Oceania and had been devised to meet the ideological needs of Ingsoc, or English Socialism. Essay Of Divorce! In the year 1984 there was not as yet anyone who used Newspeak as his sole means of communication, either in speech or writing. Mcgraw Accounting Answers! The leading articles in of divorce the Times were written in phonemic script it, but this was a tour de force which could only be carried out by a specialist. It was expected that Newspeak would have finally superseded Oldspeak (or Standard English, as we should call it) by about the year 2050. Meanwhile it gained ground steadily, all Party members tending to essay, use Newspeak words and grammatical constructions more and more in Roman em their everyday speech. The version in essay use in 1984, and embodied in hill accounting homework the Ninth and Tenth Editions of the essay, Newspeak Dictionary, was a provisional one, and class, contained many superfluous words and archaic formations which were due to of divorce, be suppressed later. How To Writing! It is with the final, perfected version, as embodied in the Eleventh Edition of the Dictionary, that we are concerned here. The purpose of Newspeak was not only to provide a medium of expression for the world-view and mental habits proper to the devotees of Ingsoc, but to make all other modes of thought impossible. It was intended that when Newspeak had been adopted once and for all and Oldspeak forgotten, a heretical thought — that is, a thought diverging from the principles of Ingsoc — should be literally unthinkable, at least so far as thought is dependent on words. Its vocabulary was so constructed as to give exact and often very subtle expression to every meaning that a Party member could properly wish to express, while excluding all other meanings and also the possibility of arriving at essay of divorce, them by indirect methods.
This was done partly by hill homework the invention of essay new words, but chiefly by eliminating undesirable words and by stripping such words as remained of unorthodox meanings, and term paper for psychology class, so far as possible of all secondary meanings whatever. Of Divorce! To give a single example. The word free still existed in Newspeak, but it could only be used in such statements as ‘This dog is free from lice’ or ‘This field is essay foreign theoretical, free from weeds’. It could not be used in its old sense of essay of divorce ‘politically free’ or ‘intellectually free’ since political and intellectual freedom no longer existed even as concepts, and were therefore of necessity nameless. Accounting Homework! Quite apart from the suppression of definitely heretical words, reduction of vocabulary was regarded as an end in itself, and essay, no word that could be dispensed with was allowed to survive. Newspeak was designed not to extend but to mcgraw hill homework answers, diminish the range of thought, and of divorce, this purpose was indirectly assisted by cutting the choice of words down to a minimum. Newspeak was founded on the English language as we now know it, though many Newspeak sentences, even when not containing newly-created words, would be barely intelligible to an English-speaker of our own day. Newspeak words were divided into three distinct classes, known as the A vocabulary, the B vocabulary (also called compound words), and class, the C vocabulary. It will be simpler to discuss each class separately, but the grammatical peculiarities of the language can be dealt with in essay of divorce the section devoted to the A vocabulary, since the same rules held good for all three categories. The A vocabulary.
The A vocabulary consisted of the words needed for the business of phonemic script everyday life — for such things as eating, drinking, working, putting on of divorce one's clothes, going up and down stairs, riding in accounting homework answers vehicles, gardening, cooking, and the like. Of Divorce! It was composed almost entirely of words that we already possess words like hit , run , dog , tree , sugar , house , field — but in comparison with the present-day English vocabulary their number was extremely small, while their meanings were far more rigidly defined. All ambiguities and shades of american essay theoretical meaning had been purged out of them. So far as it could be achieved, a Newspeak word of of divorce this class was simply a staccato sound expressing one clearly understood concept. It would have been quite impossible to use the A vocabulary for literary purposes or for political or philosophical discussion. Mcgraw Homework Answers! It was intended only to express simple, purposive thoughts, usually involving concrete objects or physical actions. The grammar of Newspeak had two outstanding peculiarities. The first of these was an almost complete interchangeability between different parts of essay speech. Any word in the language (in principle this applied even to very abstract words such as if or when ) could be used either as verb, noun, adjective, or adverb.
Between the how to writing, verb and the noun form, when they were of the same root, there was never any variation, this rule of itself involving the destruction of many archaic forms. Of Divorce! The word thought , for example, did not exist in Newspeak. Term Paper Class! Its place was taken by think , which did duty for both noun and of divorce, verb. No etymological principle was followed here: in some cases it was the original noun that was chosen for retention, in other cases the verb. Even where a noun and verb of kindred meaning were not etymologically connected, one or other of them was frequently suppressed. There was, for example, no such word as cut , its meaning being sufficiently covered by the noun-verb knife . Term Paper For Psychology Class! Adjectives were formed by adding the suffix - ful to the noun-verb, and adverbs by of divorce adding - wise . Thus for Roman em example, speedful meant ‘rapid’ and essay of divorce, speedwise meant ‘quickly’. Certain of our present-day adjectives, such as good , strong , big , black , soft , were retained, but their total number was very small. There was little need for them, since almost any adjectival meaning could be arrived at for psychology class, by adding - ful to a noun-verb. None of the now-existing adverbs was retained, except for a very few already ending in essay of divorce - wise : the - wise termination was invariable.
The word well , for em example, was replaced by goodwise . In addition, any word — this again applied in essay of divorce principle to every word in the language — could be negatived by adding the affix un -, or could be strengthened by the affix plus -, or, for still greater emphasis, doubleplus -. Thus, for example, uncold meant ‘warm’, while pluscold and doublepluscold meant, respectively, ‘very cold’ and ‘superlatively cold’. It was also possible, as in present-day English, to modify the meaning of almost any word by mcgraw hill accounting answers prepositional affixes such as ante -, post -, up -, down -, etc. Of Divorce! By such methods it was found possible to bring about an enormous diminution of vocabulary. Given, for instance, the word good , there was no need for such a word as bad , since the required meaning was equally well — indeed, better — expressed by ungood . All that was necessary, in any case where two words formed a natural pair of opposites, was to decide which of american theoretical them to suppress. Dark , for example, could be replaced by unlight , or light by undark , according to preference. The second distinguishing mark of Newspeak grammar was its regularity. Subject to a few exceptions which are mentioned below all inflexions followed the same rules. Thus, in essay of divorce all verbs the preterite and the past participle were the same and ended in outdoors essay - ed . The preterite of of divorce steal was stealed , the preterite of think was thinked , and so on throughout the language, all such forms as swam , gave , brought , spoke , taken , etc., being abolished. Outdoors Essay! All plurals were made by adding - s or - es as the of divorce, case might be.
The plurals of mcgraw hill answers man , ox , life , were mans , oxes , lifes . Comparison of adjectives was invariably made by adding - er , - est ( good , gooder , goodest ), irregular forms and the more , most formation being suppressed. The only classes of words that were still allowed to inflect irregularly were the pronouns, the relatives, the demonstrative adjectives, and the auxiliary verbs. All of these followed their ancient usage, except that whom had been scrapped as unnecessary, and the shall , should tenses had been dropped, all their uses being covered by will and would . There were also certain irregularities in word-formation arising out of the need for rapid and easy speech. A word which was difficult to utter, or was liable to be incorrectly heard, was held to of divorce, be ipso facto a bad word: occasionally therefore, for the sake of euphony, extra letters were inserted into a word or an archaic formation was retained. Ancient! But this need made itself felt chiefly in connexion with the essay of divorce, B vocabulary. Homework Answers! Why so great an importance was attached to ease of pronunciation will be made clear later in this essay. The B vocabulary. The B vocabulary consisted of words which had been deliberately constructed for essay political purposes: words, that is to american policy, say, which not only essay, had in every case a political implication, but were intended to impose a desirable mental attitude upon the person using them. Without a full understanding of the phonemic script, principles of Ingsoc it was difficult to use these words correctly.
In some cases they could be translated into Oldspeak, or even into words taken from the A vocabulary, but this usually demanded a long paraphrase and always involved the loss of certain overtones. Essay Of Divorce! The B words were a sort of verbal shorthand, often packing whole ranges of ideas into a few syllables, and at the same time more accurate and forcible than ordinary language. The B words were in all cases compound words (2) . They consisted of two or more words, or portions of words, welded together in an easily pronounceable form. Roman Em! The resulting amalgam was always a noun-verb, and inflected according to the ordinary rules. To take a single example: the word goodthink , meaning, very roughly, ‘orthodoxy’, or, if one chose to regard it as a verb, ‘to think in an orthodox manner’. This inflected as follows: noun-verb, goodthink ; past tense and essay of divorce, past participle, goodthinked ; present participle, goodthinking ; adjective, goodthinkful ; adverb, goodthinkwise ; verbal noun, goodthinker . The B words were not constructed on any etymological plan.
The words of which they were made up could be any parts of speech, and phonemic script, could be placed in any order and mutilated in any way which made them easy to essay, pronounce while indicating their derivation. Essay Policy! In the word crimethink (thoughtcrime), for essay of divorce instance, the how to writing, think came second, whereas in thinkpol (Thought Police) it came first, and in the latter word police had lost its second syllable. Because of the great difficulty in securing euphony, irregular formations were commoner in the B vocabulary than in essay of divorce the A vocabulary. For example, the adjective forms of Minitrue , Minipax , and outdoors essay, Miniluv were, respectively, Minitruthful , Minipeaceful , and Minilovely , simply because - trueful , - paxful , and - loveful were sliightly awkward to pronounce. In principle, however, all B words could inflect, and all inflected in exactly the same way. Some of the B words had highly subtilized meanings, barely intelligible to anyone who had not mastered the language as a whole. Consider, for example, such a typical sentence from a Times leading article as Oldthinkers unbellyfeel Ingsoc . The shortest rendering that one could make of this in essay Oldspeak would be: ‘Those whose ideas were formed before the Revolution cannot have a full emotional understanding of the principles of English Socialism.’ But this is not an adequate translation. Em! To begin with, in essay order to em, grasp the full meaning of the Newspeak sentence quoted above, one would have to have a clear idea of what is meant by Ingsoc . And in addition, only a person thoroughly grounded in Ingsoc could appreciate the of divorce, full force of the word bellyfeel , which implied a blind, enthusiastic acceptance difficult to imagine today; or of the word oldthink , which was inextricably mixed up with the idea of answers wickedness and decadence. But the special function of essay certain Newspeak words, of outdoors essay which oldthink was one, was not so much to express meanings as to of divorce, destroy them.
These words, necessarily few in number, had had their meanings extended until they contained within themselves whole batteries of words which, as they were sufficiently covered by a single comprehensive term, could now be scrapped and forgotten. American Foreign! The greatest difficulty facing the compilers of the Newspeak Dictionary was not to invent new words, but, having invented them, to make sure what they meant: to make sure, that is to say, what ranges of words they cancelled by their existence. As we have already seen in the case of the word free , words which had once borne a heretical meaning were sometimes retained for essay of divorce the sake of convenience, but only with the foreign policy theoretical, undesirable meanings purged out of essay them. Countless other words such as honour , justice , morality , internationalism , democracy , science , and religion had simply ceased to outdoors essay, exist. A few blanket words covered them, and, in covering them, abolished them. All words grouping themselves round the concepts of liberty and essay, equality, for instance, were contained in the single word crimethink , while all words grouping themselves round the concepts of objectivity and rationalism were contained in the single word oldthink . Greater precision would have been dangerous. What was required in a Party member was an outdoors essay outlook similar to that of the ancient Hebrew who knew, without knowing much else, that all nations other than his own worshipped ‘false gods’. He did not need to know that these gods were called Baal, Osiris, Moloch, Ashtaroth, and the like: probably the less he knew about them the better for his orthodoxy. He knew Jehovah and the commandments of of divorce Jehovah: he knew, therefore, that all gods with other names or other attributes were false gods.
In somewhat the same way, the Ancient Roman, party member knew what constituted right conduct, and in exceedingly vague, generalized terms he knew what kinds of departure from essay of divorce, it were possible. His sexual life, for example, was entirely regulated by the two Newspeak words sexcrime (sexual immorality) and goodsex (chastity). Sexcrime covered all sexual misdeeds whatever. It covered fornication, adultery, homosexuality, and other perversions, and, in addition, normal intercourse practised for its own sake. There was no need to enumerate them separately, since they were all equally culpable, and, in principle, all punishable by death. In the term paper for psychology class, C vocabulary, which consisted of scientific and technical words, it might be necessary to give specialized names to certain sexual aberrations, but the ordinary citizen had no need of them. Essay Of Divorce! He knew what was meant by goodsex — that is to essay policy, say, normal intercourse between man and wife, for the sole purpose of begetting children, and without physical pleasure on the part of the of divorce, woman: all else was sexcrime . In Newspeak it was seldom possible to follow a heretical thought further than the perception that it was heretical: beyond that point the class, necessary words were nonexistent. No word in the B vocabulary was ideologically neutral. Essay Of Divorce! A great many were euphemisms. Such words, for instance, as joycamp (forced-labour camp) or Minipax (Ministry of Peace, i.e. How To Writing! Ministry of War) meant almost the essay, exact opposite of what they appeared to mean.
Some words, on the other hand, displayed a frank and contemptuous understanding of the real nature of Oceanic society. An example was prolefeed , meaning the rubbishy entertainment and spurious news which the Party handed out to the masses. Mcgraw Hill Homework! Other words, again, were ambivalent, having the essay of divorce, connotation ‘good’ when applied to the Party and phonemic script, ‘bad’ when applied to its enemies. But in addition there were great numbers of of divorce words which at first sight appeared to homework answers, be mere abbreviations and which derived their ideological colour not from their meaning, but from their structure. So far as it could be contrived, everything that had or might have political significance of any kind was fitted into the B vocabulary. The name of every organization, or body of people, or doctrine, or country, or institution, or public building, was invariably cut down into the familiar shape; that is, a single easily pronounced word with the smallest number of syllables that would preserve the essay, original derivation. In the Ministry of Truth, for example, the Records Department, in which Winston Smith worked, was called Recdep , the Fiction Department was called Ficdep , the Teleprogrammes Department was called Teledep , and so on. This was not done solely with the object of saving time. Even in the early decades of the twentieth century, telescoped words and how to writing, phrases had been one of the characteristic features of political language; and essay, it had been noticed that the tendency to use abbreviations of this kind was most marked in totalitarian countries and totalitarian organizations. Examples were such words as Nazi , Gestapo , Comintern , Inprecorr , Agitprop . In the beginning the practice had been adopted as it were instinctively, but in Newspeak it was used with a conscious purpose.
It was perceived that in thus abbreviating a name one narrowed and subtly altered its meaning, by term paper class cutting out most of the associations that would otherwise cling to essay, it. Ancient! The words Communist International , for essay instance, call up a composite picture of universal human brotherhood, red flags, barricades, Karl Marx, and the Paris Commune. The word Comintern , on the other hand, suggests merely a tightly-knit organization and a well-defined body of doctrine. For Psychology Class! It refers to something almost as easily recognized, and as limited in essay of divorce purpose, as a chair or a table. Comintern is a word that can be uttered almost without taking thought, whereas Communist International is a phrase over which one is obliged to policy theoretical, linger at least momentarily. In the essay, same way, the phonemic script, associations called up by a word like Minitrue are fewer and more controllable than those called up by Ministry of Truth . This accounted not only for the habit of abbreviating whenever possible, but also for the almost exaggerated care that was taken to make every word easily pronounceable. In Newspeak, euphony outweighed every consideration other than exactitude of meaning. Regularity of grammar was always sacrificed to it when it seemed necessary. And rightly so, since what was required, above all for political purposes, was short clipped words of unmistakable meaning which could be uttered rapidly and which roused the minimum of echoes in the speaker's mind.
The words of the B vocabulary even gained in force from the fact that nearly all of essay of divorce them were very much alike. Almost invariably these words — goodthink , Minipax , prolefeed , sexcrime , joycamp , Ingsoc , bellyfeel , thinkpol , and countless others — were words of two or three syllables, with the stress distributed equally between the first syllable and the last. The use of them encouraged a gabbling style of speech, at once staccato and monotonous. And this was exactly what was aimed at. Homework! The intention was to make speech, and especially speech on any subject not ideologically neutral, as nearly as possible independent of consciousness. For the purposes of everyday life it was no doubt necessary, or sometimes necessary, to reflect before speaking, but a Party member called upon to make a political or ethical judgement should be able to spray forth the correct opinions as automatically as a machine gun spraying forth bullets. His training fitted him to do this, the language gave him an almost foolproof instrument, and the texture of the words, with their harsh sound and of divorce, a certain wilful ugliness which was in term paper accord with the spirit of Ingsoc, assisted the process still further. So did the fact of having very few words to essay of divorce, choose from. Relative to our own, the Newspeak vocabulary was tiny, and new ways of reducing it were constantly being devised.
Newspeak, indeed, differed from most all other languages in that its vocabulary grew smaller instead of larger every year. Each reduction was a gain, since the smaller the area of choice, the smaller the temptation to take thought. Ultimately it was hoped to make articulate speech issue from the larynx without involving the higher brain centres at all. This aim was frankly admitted in Ancient the Newspeak word duckspeak , meaning ‘to quack like a duck’. Like various other words in the B vocabulary, duckspeak was ambivalent in meaning.
Provided that the essay of divorce, opinions which were quacked out hill answers were orthodox ones, it implied nothing but praise, and when the Times referred to one of the orators of the essay of divorce, Party as a doubleplusgood duckspeaker it was paying a warm and valued compliment. The C vocabulary. The C vocabulary was supplementary to the others and consisted entirely of scientific and technical terms. These resembled the scientific terms in use today, and mcgraw hill homework answers, were constructed from the same roots, but the usual care was taken to essay of divorce, define them rigidly and strip them of undesirable meanings. They followed the same grammatical rules as the term class, words in the other two vocabularies. Very few of the C words had any currency either in everyday speech or in political speech. Any scientific worker or technician could find all the words he needed in the list devoted to his own speciality, but he seldom had more than a smattering of the essay, words occurring in the other lists. Outdoors Essay! Only a very few words were common to all lists, and of divorce, there was no vocabulary expressing the how to writing, function of Science as a habit of mind, or a method of thought, irrespective of its particular branches. There was, indeed, no word for ‘Science’, any meaning that it could possibly bear being already sufficiently covered by the word Ingsoc . From the foregoing account it will be seen that in Newspeak the expression of unorthodox opinions, above a very low level, was well-nigh impossible. It was of essay course possible to utter heresies of a very crude kind, a species of blasphemy. It would have been possible, for example, to say Big Brother is ungood . American Essay Policy! But this statement, which to an orthodox ear merely conveyed a self-evident absurdity, could not have been sustained by reasoned argument, because the necessary words were not available.
Ideas inimical to Ingsoc could only be entertained in a vague wordless form, and could only be named in essay of divorce very broad terms which lumped together and condemned whole groups of heresies without defining them in doing so. One could, in fact, only use Newspeak for unorthodox purposes by Roman em illegitimately translating some of the words back into Oldspeak. For example, All mans are equal was a possible Newspeak sentence, but only in the same sense in which All men are redhaired is a possible Oldspeak sentence. It did not contain a grammatical error, but it expressed a palpable untruth — i.e. that all men are of equal size, weight, or strength. The concept of political equality no longer existed, and this secondary meaning had accordingly been purged out of the word equal . In 1984, when Oldspeak was still the normal means of of divorce communication, the danger theoretically existed that in for psychology class using Newspeak words one might remember their original meanings. In practice it was not difficult for any person well grounded in doublethink to avoid doing this, but within a couple of generations even the possibility of essay of divorce such a lapse would have vaished.
A person growing up with Newspeak as his sole language would no more know that equal had once had the secondary meaning of ‘politically equal’, or that free had once meant ‘intellectually free’, than for instance, a person who had never heard of chess would be aware of the secondary meanings attaching to queen and rook . There would be many crimes and errors which it would be beyond his power to commit, simply because they were nameless and class, therefore unimaginable. Of Divorce! And it was to be foreseen that with the passage of time the outdoors essay, distinguishing characteristics of essay Newspeak would become more and more pronounced — its words growing fewer and fewer, their meanings more and more rigid, and the chance of term putting them to improper uses always diminishing. When Oldspeak had been once and for all superseded, the last link with the of divorce, past would have been severed. History had already been rewritten, but fragments of the literature of the past survived here and there, imperfectly censored, and so long as one retained one's knowledge of Oldspeak it was possible to read them. In the future such fragments, even if they chanced to term class, survive, would be unintelligible and of divorce, untranslatable. It was impossible to translate any passage of Oldspeak into Newspeak unless it either referred to mcgraw hill accounting answers, some technical process or some very simple everyday action, or was already orthodox ( goodthinkful would be the Newspeak expression) in tendency. In practice this meant that no book written before approximately 1960 could be translated as a whole. Of Divorce! Pre-revolutionary literature could only be subjected to ideological translation — that is, alteration in american essay foreign sense as well as language.
Take for example the well-known passage from the Declaration of Independence: We hold these truths to be self-evident, that all men are created equal, that they are endowed by their creator with certain inalienable rights, that among these are life, liberty, and the pursuit of happiness. That to secure these rights, Governments are instituted among men, deriving their powers from the of divorce, consent of the Ancient em, governed. That whenever any form of Government becomes destructive of those ends, it is the right of the People to essay, alter or abolish it, and to institute new Government. It would have been quite impossible to render this into Newspeak while keeping to the sense of the original. Class! The nearest one could come to doing so would be to swallow the of divorce, whole passage up in the single word crimethink . A full translation could only be an Ancient em ideological translation, whereby Jefferson's words would be changed into essay of divorce a panegyric on absolute government.
A good deal of the literature of the hill, past was, indeed, already being transformed in this way. Considerations of prestige made it desirable to preserve the essay of divorce, memory of certain historical figures, while at term for psychology class, the same time bringing their achievements into line with the philosophy of Ingsoc. Various writers, such as Shakespeare, Milton, Swift, Byron, Dickens, and some others were therefore in of divorce process of translation: when the task had been completed, their original writings, with all else that survived of the outdoors essay, literature of the of divorce, past, would be destroyed. Outdoors Essay! These translations were a slow and essay of divorce, difficult business, and it was not expected that they would be finished before the first or second decade of the twenty-first century. There were also large quantities of merely utilitarian literature — indispensable technical manuals, and the like — that had to be treated in the same way. It was chiefly in order to allow time for hill homework answers the preliminary work of translation that the final adoption of Newspeak had been fixed for so late a date as 2050. GEORGE ORWELL: ‘NINETEEN EIGHTY-FOUR’; A NOVEL.
First published by of divorce Secker and mcgraw answers, Warburg, London in 1949.
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Causes of Divorce: Cause and Effect Essay Samples | AcademicHelp
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In principle, members’ personal information will be retained and essay used for 7 (seven) years after collection or 7 (seven) years after members’ use of class, Spring Professional’s services. Essay Of Divorce. However, the Company destroys the personal information of essay foreign, relevant members without delay if he/she withdraws from membership. However, if any personal information of a member is required to be retained under the of divorce applicable laws and regulations, the Company will retain the personal information for how to writing, the period as prescribed under such applicable laws and regulations as follows: Procedures and Method of of divorce, Destruction of Personal Information Destruction Procedures Any information input provided by the member for membership subscription, etc. will be moved to a separate database (“ DB ”) (for papers, a separate document box) and destroyed after being retained for a certain period pursuant to phonemic script the Company’s internal policies for retention of of divorce, personal information and other applicable laws and regulations (please see Period of Retention and Use). Unless otherwise required by applicable laws and regulations, the personal information moved to a separate DB will not be used for purposes other than retaining thereof. Destruction Method Any personal information stored in essay foreign theoretical the form of essay of divorce, electronic file will be destroyed using a technical method which makes the records irreproducible, and any print-out version of personal information will be shredded using a shredder or incinerated. Transfer of Personal Information to a Third Party.
Provision of recruiting services Grievance handling Notification and contact for various issues including result of recruitment Offering contents including recruitment information Delivery of term paper, newsletters, information on services, etc. Provision of personnel information relating to the requested recruiting services Delivery of various notifications relating to service provision Settlement of charges related to of divorce consultation and services. To determine whether to employ a member or not. For the term paper for psychology class performance of Services, the Company delegates the processing of personal information to the following external professional service providers: Users and their legal guardians may, at any time, access to or correct their personal information or personal information of children under 14 and request for withdrawal from membership. If you want to access to or correct your personal information or personal information of children under 14, you may click “My Dashboard”. If you want to withdraw from membership (withdrawal of consent), you may click “Close Account” to directly withdraw from membership after proceeding with the identity verification. For immediate assistance, you may contact a personal information administration manager by phone or via email. If you request us to of divorce correct any factual errors in Ancient em your personal information, we will not use nor provide the information until we complete correction of the error. In the event that wrong personal information has already been provided to a third party, we will correct such errors by of divorce, promptly notifying the result of correction to how to writing such third party. The personal information which is cancelled or deleted upon the request of users or legal guardians will be managed in accordance with the “Period of Retention and Use of Personal Information” and the information will not be reviewed or used for any other purposes.
Installation, Operation and Refusal of Personal Information Automatic Collection Devices. A cookie is essay, a special text file that our website sends to your hard disk. Cookies are transmitted in the form that is policy theoretical, only readable at the server of our website, and are stored under the essay directory of browser used by individuals. Cookies have been designed to help a website to remember the users movements. In other words, cookies are used for phonemic script, smooth communications between the website and visitors by essay, streamlining users’ experiences and providing customized services, and it is impossible to identify a person only with the information collected through cookies. Our purposes of collecting information through cookies are the same as the mcgraw hill accounting “Purposes of Collection and Use of Personal Information”, and the information collected will not be used for essay of divorce, any other purposes. Even if information is collected for the same purpose as the mcgraw homework “Purposes of Collection and Use of Personal Information”, we do not analyze such information by incorporating it with any existing real personal name-related data of relevant person. If a user subscribes for membership, logs in and uses a scrap function, we store the essay of divorce information that the user has selected through the relevant recruitment notice so as to help the user to conveniently use the scrap function. Any visitor has an option to install cookies. You may go to how to writing option tab of Tool/Internet Option of the essay web browser and directly choose to accept all cookies, accept cookies after giving consent, or block all cookies.
Grievance Handling on Ancient Roman em Personal Information. Personal Information Administration Manager: Carlos Estrada. The department responsible for essay, the protection of mcgraw hill accounting homework answers, personal information: Head of Legal. Tel: +65 6697 7831. You may report any grievance relating to personal information that you suffer while using our services to essay the Personal Information Administration Manager or the responsible department. Phonemic Script. The Company will provide a prompt response to the reports of our users. Privacy Consent form for essay of divorce, Application for Employment.
Consent to Collection and Use of Personal Information. Account details: address, suburb, postcode, state, country, mailing address, mailing suburb, mailing postcode, mailing state, mailing country, gender, date of birth, phone number (house), phone number (workplace), mobile phone number, fax number, level of education, tags Profile: image, headline, current status, short bio Role preferences: location, area, classification, sub-classification, work type Education and qualifications: qualification, institution name, education period (year of start and end) Achievements, memberships and certificates Experience: job title, company name, duration of employment (year/month of start and end), summary of phonemic script, experience Skills Personal information which are contained in the submitted cover letter or resume. Purposes of Collection and Use. Provision of recruiting services including application for essay, employment, etc. Notification and contact for various issues including interview, recruitment notice, result of recruitment, etc. Performance of contracts relating service provision; offering contents including recruitment information Provision of various kinds of more effective and customized services, including recruitment information, employment agency, application for employment, etc. Period of Retention and outdoors essay Use. In principle, your personal information will be retained and used for essay, 7 (seven) years after registration or 7 (seven) years after your use of Spring Professional’s services (e.g., application for employment or headhunting).
User verification and personal identification pursuant to the use of membership services; confirmation of willingness to subscribe; confirmation of membership status; prevention of any fraudulent use and unauthorized use of members personal information; and grievance handling including complaints Notification and contact for various issues including interview, recruitment notice, result of recruitment, etc. Essay. Performance of contracts relating to the provision of class, Services by the Company; settlement of charges related to consultation and essay of divorce Service provision by the Company; Delivery of newsletter, information on Services or advertising information for profit, such as employment information or recruitment information, and use for sales and marketing purposes Provision of various kinds of more effective and term for psychology class customized services, including but not limited to recruitment information, employment agency, application for employment, etc. Essay Of Divorce. Provision of american essay policy, personnel information relating to the requested recruiting services, including recruitment by proxy, dispatch of personnel, outsourcing, etc. Delivery of various notifications relating to provision of Services by the Company Search for of divorce, members with the qualifications and similar work experience as required by recruiting companies Period of Retention and Use of Personal Information. In principle, members’ personal information will be retained and used for 7 (seven) years after collection or 7 (seven) years after members’ use of Spring Professional’s services. However, the Company destroys the personal information of relevant members without delay if he/she withdraws from membership.
However, if any personal information of a member is required to be retained under the term paper for psychology applicable laws and regulations, the Company will retain the personal information for the period as prescribed under such applicable laws and regulations as follows: Procedures and Method of essay, Destruction of hill answers, Personal Information Destruction Procedures Any information input provided by of divorce, the member for membership subscription, etc. will be moved to a separate database (“ DB ”) (for papers, a separate document box) and destroyed after being retained for a certain period pursuant to the Company’s internal policies for phonemic script, retention of personal information and other applicable laws and regulations (please see Period of essay, Retention and Use). Unless otherwise required by how to writing, applicable laws and essay of divorce regulations, the personal information moved to a separate DB will not be used for purposes other than retaining thereof. Destruction Method Any personal information stored in the form of electronic file will be destroyed using a technical method which makes the records irreproducible, and any print-out version of personal information will be shredded using a shredder or incinerated. Transfer of Personal Information to a Third Party. Provision of recruiting services Grievance handling Notification and contact for various issues including result of recruitment Offering contents including recruitment information Delivery of newsletters, information on how to writing services, etc. Provision of personnel information relating to the requested recruiting services Delivery of various notifications relating to service provision Settlement of charges related to consultation and services. To determine whether to employ a member or not. For the performance of Services, the Company delegates the processing of personal information to the following external professional service providers: Users and their legal guardians may, at essay of divorce any time, access to or correct their personal information or personal information of outdoors essay, children under 14 and request for of divorce, withdrawal from membership.
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During the course of providing the Ancient Services through the Company’s Website, the following information may be automatically created and collected: Records on use of Services, access log, cookies and essay IP information Purposes of Collection and Use of Personal Information. The Company’s Website has been established to help members find jobs and hire personnel. The Company collects personal information to provide services appropriate for the effective assistance in term paper class finding jobs, hiring personnel and career development. The Company uses the collected personal information for the following purposes: User verification and personal identification pursuant to the use of membership services; confirmation of willingness to of divorce subscribe; confirmation of membership status; prevention of any fraudulent use and unauthorized use of foreign, members personal information; and grievance handling including complaints Notification and contact for various issues including interview, recruitment notice, result of recruitment, etc. Performance of contracts relating to the provision of Services by the Company; settlement of charges related to consultation and essay Service provision by the Company; Delivery of newsletter, information on how to writing Services or advertising information for profit, such as employment information or recruitment information, and use for sales and marketing purposes Provision of various kinds of more effective and customized services, including but not limited to essay of divorce recruitment information, employment agency, application for essay foreign policy theoretical, employment, etc.
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For immediate assistance, you may contact a personal information administration manager by phone or via email. If you request us to correct any factual errors in your personal information, we will not use nor provide the information until we complete correction of the error. Essay. In the event that wrong personal information has already been provided to a third party, we will correct such errors by promptly notifying the result of correction to such third party. The personal information which is cancelled or deleted upon the request of users or legal guardians will be managed in accordance with the “Period of Retention and term paper class Use of Personal Information” and the information will not be reviewed or used for any other purposes. Installation, Operation and Refusal of Personal Information Automatic Collection Devices. A cookie is a special text file that our website sends to your hard disk. Cookies are transmitted in the form that is only readable at the server of our website, and are stored under the directory of browser used by individuals. Cookies have been designed to help a website to remember the users movements. In other words, cookies are used for essay of divorce, smooth communications between the website and visitors by streamlining users’ experiences and providing customized services, and it is impossible to identify a person only phonemic script with the information collected through cookies. Our purposes of collecting information through cookies are the same as the “Purposes of Collection and Use of Personal Information”, and the information collected will not be used for any other purposes.
Even if information is collected for the same purpose as the “Purposes of Collection and Use of Personal Information”, we do not analyze such information by incorporating it with any existing real personal name-related data of relevant person. If a user subscribes for membership, logs in and uses a scrap function, we store the information that the essay user has selected through the relevant recruitment notice so as to mcgraw answers help the user to essay conveniently use the scrap function. Any visitor has an option to mcgraw hill accounting homework install cookies. You may go to option tab of Tool/Internet Option of the web browser and directly choose to accept all cookies, accept cookies after giving consent, or block all cookies. Grievance Handling on Personal Information. Personal Information Administration Manager: Carlos Estrada. The department responsible for the protection of personal information: Head of Legal. Tel: +65 6697 7831. You may report any grievance relating to essay of divorce personal information that you suffer while using our services to the Personal Information Administration Manager or the responsible department.
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Essay on Divorce - 730 Words | Bartleby
100 Cause and Effect Essay Topics. VirginiaLynne has been a University English instructor for over 20 years. She specializes in helping people write essays faster and easier. Examine why something has happened or exists. Essay Of Divorce! Speculate about what caused the situation. Em! Examine the results of an of divorce event, choice, or situation. Trace the start of a situation to a discussion of its results. Here's how you can use the following topic ideas to write an essay: Reword the term paper for psychology class, question to fit your assignment.
Use a question for your topic idea helps keep you organized. Of Divorce! Use the question for your title or put it right before your topic sentence. The answer to the question is your thesis. Simple! What causes divorce?
What is the effect of phonemic script divorce on essay of divorce, children? Does the age of the child make a difference? How does the divorce of parents affect the dating and marriage relationships of their children? What is the effect of long distance on relationships? How does living together before being married affect a relationship? What causes men to be afraid of how to writing commitment? What effect has the feminist movement had on men's and women's views of dating? What causes some women to essay of divorce repeatedly get involved in destructive relationships?
What effect does having an abortion have on a dating relationship? What causes children to rebel against their parents? What effect has social media had on family relationships? What causes sibling rivalry? What effect does birth order have on personality (or career)? What effect does a happy and fulfilling marriage have on paper, a person's health?
Does going to college cause people to have better marriages? What is the effect of grandparents raising a child? What causes teenagers to become sexually active? How does a girl's relationship with her dad affect her relationship with other men? What is the effect of growing up in a single-parent household?
What is the effect of being a twin? What the effect has China's one child had on family relationships? How will the new two child policy change family dynamics? What are the effects on children when their parents are very wealthy or very famous? What causes parents to over-schedule their children's activities? (Or what is the effect of over-scheduling on the child?) What causes a family to have close relationships? What is the effect of family vacations on family relationships? Why are more children poor than any other group? What causes poverty in the U.S.? What are the effects of growing up in of divorce, poverty?
What causes homelessness? What effect does growing up with food insecurity have on children? What has caused the increase in international adoption in Western countries? What is the effect on american essay policy, children (or adults) of watching news reports of natural disasters, terrorist strikes, sexual predators, and other fearful situations? What effect do non-profit organizations (perhaps pick a particular one) have on social problems? What is the effect of more baby boomers reaching retirement age? What is the cause of men still out-earning women in wages? What is the effect? What is the effect of religious oppression on a society (perhaps pick a particular country or religion)? What are the causes of poor water quality for essay of divorce many people around the world? What is the effect of hill homework people not having shoes to wear?
What are the effects of essay inadequate sanitation on a community? What is the cause (or effect) of continued discrimination and racism? What causes people with disabilities to be unable to get jobs? What is the outdoors essay, effect on essay, children of growing up in poverty? What has caused the dramatic rise in overweight and obese adults in the U.S. in the last ten years? What will be the outdoors essay, effects of this rise in obesity on essay of divorce, the healthcare system? What causes the increasing number of children affected by Autistic Spectrum Disorder? What effect does lack of adequate medical insurance have on an individual's health? What causes people to not go to the doctor when they have medical problems? What effect does not finishing a prescription medication have on future health?
What is the cause (or the effect) of mcgraw hill accounting homework answers people not getting their children vaccinated? What causes the spread of essay HIV/AIDS in Africa? What is the effect of climate change on infectious medical diseases? What is the american, effect of globalization on of divorce, the spread of disease? What causes some diseases like malaria or HIV to be so difficult to eradicate? What effect does stress have on how to writing, health? What effect has cancer research had on stopping cancer deaths? What causes people to get cancer? What causes pancreatic cancer to be so deadly? What has caused cancer to be so difficult to cure? What causes people to seek non-Western medical cures like traditional Chinese medicine or herbal supplements?
What is the effect of abortion(s) on a woman's subsequent reproductive health? What effect does birth control have on of divorce, women? What effect do regular dental check-ups have on oral health? What causes people to go blind? What causes people to develop allergies?
What effect does an increased use of technology have on health? What causes cardiovascular disease? What effect does exercise have on the body? What causes people to mcgraw accounting homework make healthy living choices? What causes so many healthcare providers to be overweight?
What are the social effects of having braces on teeth? What effect does cell phone use have on teenagers? What causes families to buy unlimited cell phone plans? What are the effects of essay violent video games on young children or teenagers? What effects does playing video games cause in the brains of elderly people? Does online shopping cause people to outdoors essay spend more money? What effect does social media have on teen relationships?
What are the of divorce, causes (or effects) of cyber bullying? What causes social media sites to lose popularity? What are the effects of picture and term paper for psychology class, video-based social media sites like Snapchat or Instagram on teenage social interaction? What causes a video game to be popular? What effect does moving away from computers and towards tablets and smartphones have on how we browse the Internet? What effect does typing on a screen rather than a keyboard have on how people communicate?
What causes Google to be the most popular search engine? What are the social effects of of divorce everyone on the planet having cell phones? How have smartphones affected business practices? How does standardized testing affect student dropout rates? What effect does being labeled gifted and talented have on students? What effect does being identified as having dyslexia or ADHD have on a child?
What causes students to homework think school is boring? Does using technology like iPads or smartboards in classrooms cause students to essay learn better? What is the effect on outdoors essay, learning when students do most of their work reading from essay a computer or tablet rather than paper and books? What are the effects of homeschooling on children? (Or what are the phonemic script, social effects?) What effect have magnet or charter schools had on the educational system in your town or state? How do school programs against bullying affect the essay, actual bullying and fears of students? Do single-sex classrooms cause students to learn better? What are the positive and negative effects of having school uniforms? What is the effect of having an open high school campus? What is the essay foreign policy, effect on the education of students when a district has year-round schooling? What causes teachers to burn out? What causes some schools to essay of divorce fail to educate students?
What causes American students to lag behind students from american theoretical other countries on international tests? What effect do fine arts have on students? What effect does a good physical education program have on elementary school students? What effect do longer school days have on a school's educational outcomes? What effect does parent involvement in schools have on education? What caused the Civil War? What are the continuing effects of slavery on of divorce, American society? What was the cause of the increasing interest in feminism in the 1960s and 1970s? How were WWII veterans affected by their wartime experiences?
What effect did WWII have on outdoors essay, the Jewish people? What effect did Christianity have on essay of divorce, the Roman empire? What caused the Arab Spring? What are the effects of the term, Arab Spring? What effect has the GI Bill, which educates soldiers, had on universities in the U.S.? What was the effect of colonialism on essay, Britain's view of itself? What were the causes and effects of colonialism?
In the how to writing, viewpoint of the British, what were the causes and effects of the American Revolution? What causes the drug wars in Colombia? What causes illegal immigration? What are the effects of essay immigration on a country (pick any country)? What is the effect of online sales on outdoors essay, businesses (in any country)?
What was the effect of the essay, printing press (or other invention) on world history? What are the effects of for psychology globalization on the position of women? What are the effects of essay of divorce American drone attacks on terrorists and how to writing, civilians? What was the cause of the destruction of the World Trade Center on 9/11? What is the cause of essay increased militancy on the part of North Korea? by LisaKoski 29. Research Topics in English Literature. by outdoors essay, LisaKoski 34. Essay! 100 Exploratory Essay Topic Ideas.
by Virginia Kearney 0. Ancient Roman! How to Write a Summary, Analysis, and essay of divorce, Response Essay Paper With Examples. by Virginia Kearney 56. How to Write a Proposal Essay/Paper. by Laura Writes 40. 100 Problem Solution Essay Topics with Sample Essays. by Virginia Kearney 42. This was great for me because I had to phonemic script write an essay about some kind of topic with a cause and an effect and this website gave me some really good ideas, Thank You! Virginia Kearney 3 months ago from United States. Sophia--I'm so glad that this helped you. I especially enjoy teaching Chinese students. I have traveled in China four different times and love your country very much! I am a Chinese student and I think your sharing did help me a lot. Thank you ! this is a great sight for my informational reading and writing class its good.
Hi thanks for essay helping me. these topics are really good.. i used some of these topics for my projects and got great marks.. i got A+ in all my projects , i am in 7th grade. hubber8893 18 months ago. I think you have presented some great Ideas for hub about relationships. Hugh Johnson 18 months ago. These topics had a BIG impact on my life. Thanks for your LARGE ammount of tips. These topics really helped me for school. Outdoors Essay! Ruby 19 months ago from United States.
Creative idea for a hub, what was your case and of divorce, effect for making it lol. Term Paper Class! WOW this is super great to look up stuff for an assignment. Awesome topics thanks a million. Dwight Goliday Jr 23 months ago from of divorce East Saint Louis. Wow. There are a lot things that cause and outdoors essay, effect. Very informative write.
Virginia Kearney 23 months ago from essay United States. Term Paper Class! Thanks Zakeycia and YoLex. My students have come up with most of these topics through the essay, years and now this is my most visited article so they must have done a good job! I think it got over 2000 views one day last week! This is outdoors essay, awesome I wish I'd found this hub before I graduated college lol! Great work! Zakeycia Dickens 23 months ago. I have a cause and effect essay to type for my English class. I was having a hard time coming up with a topic. Your website and topic suggestions were very helpful.
Thank you. Essay Of Divorce! Rasheedah Abdul-Hakeem 2 years ago. Thanks. Great topics. James Packard 2 years ago from term paper Columbia, Missouri. What a great hub! Debatable issues (especially political, social, environmental and behavioural) are great hub topics. They are good to write about to do research and clear up one's own viewpoint, but they also get people talking, and also spark very needed discussion. Thanks for sharing. Of Divorce! Liza Treadwell Esq aka Liza Lugo JD 2 years ago from New York, NY. I love this one, VirginiaLynne.
Your hubs are so valuable to students and outdoors essay, professional writers. Cause and effect papers are among the most interesting to read. Essay Of Divorce! I voted this hub up, useful, and interesting. I am bookmarking this hub for future reference. I know I'll be using it! Keep up the excellent work here. Mcgraw Hill Answers! Marilyn L Davis 2 years ago from essay of divorce Georgia. Good afternoon, Virginia; excellent examples for how to writing all categories.
Well done. Virginia Kearney 2 years ago from United States. Virginia Kearney 2 years ago from United States. Essay Of Divorce! Hi Gertrude--These two words are ones that are often confused. Affect also means to how to writing produce an essay of divorce effect upon as well as to phonemic script influence. I will double check my usage in this Hub just to make sure I haven't made an error. Thanks! Gertrude McFuzz 2 years ago. These are great topics. I just have one comment.
Sometimes you use effect when you should use affect. Of Divorce! affect = influence - usually a verb. effect= result - usually a noun. effect= cause - not used that often - verb. Shamim Rajabali 3 years ago from Texas. This will come in handy for my English class. How To Writing! Thanks. I Love it very much. rakesh ranjana 3 years ago. Social causes are growing up in lot more ways, knowing it and having a knowledge about it through this site, will help a lot in many ways for essay of divorce people to understand there relationship and social problems. Great hub! I like your ideas, it is something different innovative. Vote up! Thanks!
This is helpful. Vote up. Virginia Kearney 3 years ago from United States. Ancient Roman Em! Sumnerswett--I teach MLA format because that is used by of divorce, most American colleges in their English departments. Em! However, you are very right to essay of divorce point out phonemic script that APA and Chicago and other formats are used in different types of courses. Essay Of Divorce! I think considering cause and outdoors essay, effect is sometimes a bit confusing because it depends on of divorce, where you view the start of the situation.
Often a cause creates an effect, which causes another situation. Sometimes it is hard to pull them apart. That is why I usually like to Ancient call this a speculating about causes essay, because we can't always definitively determine the absolute cause, but we can always speculate and argue for the most important causes, or the most important effects that we see in a situation. Sumner Swett 3 years ago from Owls Head Maine. Okay so cause and effect essays are written in different formats, but let me say in my college profession for of divorce the essays to be written were to be in APA format, and it is interesting when researching and writing whether it is from information you have researched or if it free lance. I like to research topics before writing and also note taking is how to writing, effective. The cause is what causes the situation and the effect is what you have to take into consideration to the cause as we all know it. Kimberly Lake 3 years ago from California. Great topics! Voted up and shared.
Virginia Kearney 3 years ago from United States. Essay Of Divorce! Leidy--That is a great essay topic. I think that some of that labeling can be positive and other aspects are negative. It can encourage students to believe that they are capable, but it can discourage them by making them think that they don't need to outdoors essay work hard, or that if they don't achieve a high grade on everything, they have failed. Seth Tomko 3 years ago from Macon, GA. A good and diverse collection of topics. I'll be sure to of divorce have my students check out some of these for their own essays. Annie Miller 4 years ago from paper for psychology class Wichita Falls, Texas.
Very interesting and in depth Hub. I am passing this along and saving it, as well! Chris Achilleos 4 years ago. Great hub Virginia, I have written these types of essays before, and I have found the information that you have presented here to be excellent. Thank you for sharing. Voted up and useful! Virginia Kearney 4 years ago from United States.
Thanks so much Carol! You are always an encouragement. carol stanley 4 years ago from Arizona. This is something to save when trying to come up with new writing ideas. Great hub. Going to pass this along and of course vote up. Copyright 2017 HubPages Inc. and essay, respective owners. Other product and company names shown may be trademarks of their respective owners. HubPages ® is a registered Service Mark of HubPages, Inc. HubPages and Hubbers (authors) may earn revenue on this page based on affiliate relationships and advertisements with partners including Amazon, Google, and others.
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Divorce(causes and effects) essays
compliance resume SUBJECT: EEOC COMPLIANCE MANUAL. PURPOSE: This transmittal covers the essay issuance of Section 12 of the new Compliance Manual on “Religious Discrimination.” The section provides guidance and instructions for foreign, investigating and essay of divorce 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 Ancient Ansonia Board of of divorce Education v. How To Writing! 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 essay of divorce 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 outdoors essay 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 essay Religion, 29 C.F.R. Part 1605, remain in mcgraw accounting answers, effect. SECTION 12: RELIGIOUS DISCRIMINATION. SECTION 12: RELIGIOUS DISCRIMINATION. This Section of the Compliance Manual focuses on religious discrimination under Title VII of the Civil Rights Act of 1964 (Title VII).  Title VII protects workers from employment discrimination based on their race, color, religion, sex, national origin, or protected activity. Solely with respect to religion, Title VII also requires reasonable accommodation of employees’  sincerely held religious beliefs, observances, and essay practices when requested, unless accommodation would impose an undue hardship on business operations.  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 foreign theoretical “undue hardship” defense under the essay of divorce Americans with Disabilities Act (ADA), which is defined instead as “significant difficulty or expense.”  The prohibition on discrimination and term 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.  Questions about religion in the workplace have increased as religious pluralism has increased.
In a 2001 survey of human resource professionals conducted by of divorce the Society for Human Resource Management and the Tanenbaum Center for Roman, Interreligious Understanding, 36% of human resource professionals who responded reported an increase in the religious diversity of their employees in the preceding five years.  Further, the number of religious discrimination charges filed with EEOC has more than doubled from 1992 to essay of divorce, 2007, although the total number of such charges remains relatively small compared to charges filed on other bases.  Many employers seek legal guidance in managing the issues that arise as religious diversity in the American workplace continues to increase.  This Section of the Compliance Manual is designed to be a practical resource for how to writing, employers, employees, practitioners, and EEOC enforcement staff on Title VII’s prohibition against religious discrimination. The Section defines religious discrimination, discusses typical scenarios in which religious discrimination may arise, and provides guidance to employers on of divorce how to american essay, balance the needs of individuals in a diverse religious climate.  The Section is of divorce, organized by legal topic, as follows: I - Coverage issues , including the definition of “religion” and how to writing “sincerely held,” the religious organization exception, and the ministerial exception. II - Disparate treatment analysis of 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 bona fide occupational qualifications. Essay Of Divorce! III - Harassment analysis , including religious belief or practice as a condition of employment or advancement, hostile work environment, and employer liability issues.
IV - Reasonable accommodation analysis , including notice of the conflict between religion and work, scope of the accommodation requirement and mcgraw accounting homework undue hardship defense, and common methods of essay of divorce accommodation. V - Related forms of homework answers discrimination , including discrimination based on national origin, race, or color, as well as retaliation. Some charges of essay of divorce religious discrimination may raise multiple claims, for example requiring analysis under disparate treatment, harassment, and denial of reasonable accommodation theories of liability. In addition, there are some instances where Title VII religious discrimination cases implicate federal constitutional provisions.  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 outdoors essay First Amendment.  A private sector employer may contend that its own First Amendment rights under the Free Exercise or Free Speech Clauses would be violated if it is of divorce, compelled by Title VII to phonemic script, grant a particular accommodation. Essay Of Divorce!  In addition, government employees often raise claims under the First Amendment parallel to their Title VII accommodation claims.  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 term for psychology, order to illustrate how they often arise in Title VII cases.  Title VII prohibits covered employers, employment agencies, and of divorce unions  from: (1) treating applicants or employees differently (disparate treatment) based on their religious beliefs or practices or lack thereof in any aspect of american foreign policy theoretical employment, including recruitment, hiring, assignments, discipline, promotion, and 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 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 essay accommodation will not impose an undue hardship on the conduct of the business;  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 outdoors essay, someone else’s EEO matter), or opposition relating to of divorce, alleged religious discrimination ( e.g. , complaining to phonemic script, 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 of divorce, disparate treatment, harassment, denial of american foreign policy theoretical reasonable accommodation, and/or retaliation. Of Divorce! Therefore, these charges should be investigated and analyzed under all four theories of hill accounting homework answers liability to the extent applicable, even if the essay charging party only raises one claim. Overview: Religion is very broadly defined under Title VII. Religious beliefs, practices, and observances include those that are theistic  in nature, as well as non-theistic “moral or ethical beliefs as to hill accounting homework answers, what is right and wrong which are sincerely held with the strength of essay traditional religious views.” Religious beliefs can include unique views held by how to writing a few or even one individual; however, mere personal preferences are not religious beliefs. Essay! Title VII requires employers to accommodate religious beliefs, practices, and american essay policy observances if the beliefs are “sincerely held” and the reasonable accommodation poses no undue hardship on essay the employer. Title VII defines “religion” to mcgraw hill homework answers, include “all aspects of religious observance and practice as well as belief.”  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 essay of divorce, by a small number of people, or that seem illogical or unreasonable to others.  Further, a person’s religious beliefs “need not be confined in either source or content to traditional or parochial concepts of religion.”  A belief is “religious” for Title VII purposes if it is “‘religious’ in the person’s own scheme of things,”  i.e. , it is “a sincere and meaningful belief that occupies in the life of its possessor a place parallel to that filled by God.”  An employee’s belief or practice can be “religious” under Title VII even if the mcgraw homework answers employee is 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. 
Religious beliefs include theistic beliefs as well as non-theistic “moral or ethical beliefs as to what is right and wrong which are sincerely held with the essay of divorce strength of traditional religious views.”  Although courts generally resolve doubts about particular beliefs in em, favor of finding that they are religious,  beliefs are not protected merely because they are strongly held. Essay! Rather, religion typically concerns “ultimate ideas” about “life, purpose, and death.”  Social, political, or economic philosophies, as well as mere personal preferences, are not “religious” beliefs protected by Title VII.  Religious observances or practices include, for example, attending worship services, praying, wearing religious garb or symbols, displaying religious objects, adhering to certain dietary rules, proselytizing or other forms of religious expression, or refraining from certain activities. Determining whether a practice is religious turns not on the nature of the activity, but on 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. Outdoors Essay!  For example, one employee might observe certain dietary restrictions for religious reasons while another employee adheres to essay of divorce, the very same dietary restrictions but for Roman, secular ( e.g. , health or environmental) reasons. Essay!  In that instance, the same practice might in one case be subject to reasonable accommodation under Title VII because an employee engages in theoretical, the practice for religious reasons, and in essay of divorce, another case might not be subject to reasonable accommodation because the practice is class, engaged in for of divorce, secular reasons. The following examples illustrate these concepts: Employment Decisions Based on “Religion” An otherwise qualified applicant is not hired because he is how to writing, a self-described evangelical Christian. A qualified non-Jewish employee is denied promotion because the supervisor wishes to of divorce, give a preference based on religion to a fellow Jewish employee. An employer terminates an employee based on his disclosure to 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 applicant or employee, and therefore is based on “religion” within the phonemic script 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 life thereof, which is the blood thereof, shall ye not eat,” (Genesis 9:4). Her vegetarianism is essay of divorce, a religious practice, even though not all Seventh-day Adventists share this belief or follow this practice, and phonemic script even though many individuals adhere to a vegetarian diet for purely secular reasons. Types of of divorce 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 exception allowing her to wear her bindi (religious forehead marking). Phonemic Script! An atheist asks to be excused from the religious invocation offered at the beginning of of divorce 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 american foreign policy theoretical, 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 meaning of Title VII. By contrast, a request for a schedule change to help set up decorations or prepare food for essay, a church event, for instance, typically does not involve a “religious” belief or practice within the meaning of Title VII.  Supervisor Considers Belief Illogical. Morgana asks for time off on October 31 to attend the “Samhain Sabbat,” the New Year observance of Wicca, her religion. Her supervisor refuses, saying that Wicca is not a “real” religion but an “illogical conglomeration” of foreign policy theoretical “various aspects of the 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.”  Unique Belief Can Be Religious. Edward practices the Kemetic religion, based on essay ancient Egyptian faith, and affiliates himself with a tribe numbering fewer than ten members.He states that he believes in phonemic script, various deities, and follows the of divorce faith’s concept of Ma’at, a guiding principle regarding truth and order that represents physical and how to writing 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 Egyptian god of the sun. When his employer asks him to of divorce, cover the term paper for psychology class tattoos, he explains that it is a sin to essay, cover them intentionally because doing so would signify a rejection of Ra. These can be religious beliefs and practices even if no one else or few other people subscribe to them. Paper For Psychology!  Personal Preference That is Not a Religious Belief. Sylvia wears several tattoos and has recently had her nose and of divorce eyebrows pierced. A newly hired manager implements a dress code that requires that employees have no visible piercings or tattoos. 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 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 phonemic script, any “ultimate concerns” such as life, purpose, death, humanity’s place in essay, the universe, or right and wrong, and they are not part of essay policy theoretical a moral or ethical belief system. Therefore, her belief is a personal preference that is not religious in essay of divorce, nature.  Title VII requires employers to how to writing, accommodate only those religious beliefs that are “sincerely held.”  Therefore, whether or not a religious belief is essay, “sincerely held” by phonemic script an applicant or employee is only relevant to religious accommodation, not to claims of essay of divorce 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. A detailed discussion of reasonable accommodation of sincerely held religious beliefs appears in term paper, § IV, but the essay meaning of phonemic script “sincerely held” is of divorce, addressed here. Like the hill accounting “religious” nature of a belief or practice, the “sincerity” of an employee’s stated religious belief is of divorce, usually not in dispute. Nevertheless, there are some circumstances in american essay foreign policy theoretical, which an essay of divorce employer may assert as a defense that it was not required to 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 professed belief;  whether the accommodation sought is how to writing, a particularly desirable benefit that is likely to be sought for essay of divorce, secular reasons; whether the timing of the phonemic script request renders it suspect ( e.g. , it follows an earlier request by the employee for the same benefit for essay of divorce, secular reasons); and whether the Ancient Roman employer otherwise has reason to believe the accommodation is not sought for religious reasons. Essay! However, none of these factors is term for psychology class, dispositive. Essay Of Divorce! For example, although prior inconsistent conduct is relevant to the question of sincerity, an individual’s beliefs or degree of adherence may change over time, and therefore an employee’s newly adopted or inconsistently observed religious practice may nevertheless be sincerely held.  An employer also should not assume that an employee is insincere simply because some of his or her practices deviate from the commonly followed tenets of his or her religion. Phonemic Script!  3. Employer Inquiries into Religious Nature or Sincerity of Belief. Because the definition of religion is broad and protects beliefs and practices with which the 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 of divorce employee requests religious accommodation, and outdoors essay an employer has an objective basis for questioning either the essay religious nature or the sincerity of how to writing 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. Essay Of Divorce! 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 investigator may need to ask follow-up questions about the nature and tenets of the asserted religious beliefs, and/or any associated practices, rituals, clergy, observances, etc., in essay foreign, order to identify a specific religious belief or practice or determine if one is at issue. Since religious beliefs can be unique to an individual, evidence from others is essay of divorce, not always necessary. 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 how to writing 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 determine whether CP’s asserted practice or belief is “religious” as defined under Title VII, the investigator’s general knowledge will be insufficient, and additional objective information will have to be obtained, while nevertheless recognizing the intensely personal characteristics of adherence to a religious belief. If the of divorce Respondent disputes that CP’s belief is “sincerely held,” the essay foreign policy following evidence may be relevant:
Oral statements, an 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 the belief or practice; and/or, Oral statements, affidavits, or other documents from essay potential witnesses identified by CP or R as having knowledge of paper whether CP adheres or does not adhere to 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 essay of divorce, all religious discrimination claims under the statute. However, specially-defined “religious organizations” and essay policy “religious educational institutions” are exempt from certain religious discrimination provisions, and a “ministerial exception” bars Title VII claims by of divorce employees who serve in clergy roles. Title VII’s prohibitions apply to employers, employment agencies, and unions,  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 mcgraw hill accounting answers, a nondiscriminatory manner and provide reasonable accommodation unless doing so would impose an undue hardship.  Unions also can be liable if they knowingly acquiesce in employment discrimination against their members, join or tolerate employers’ discriminatory practices, or discriminatorily refuse to represent employees’ interests.  Under Title VII, religious organizations are permitted to essay of divorce, give employment preference to members of Ancient em their own religion. Essay!  The exception applies only to those institutions whose “purpose and character are primarily religious.”  That determination is to be based on “[a]ll significant religious and secular characteristics.”  Although no one factor is dispositive, significant factors to 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 term for psychology class 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 a church or other religious organization?  This exception is not limited to religious activities of the essay of divorce organization.  However, it only allows religious organizations to prefer to employ individuals who share their religion.  The exception does not allow religious organizations otherwise to discriminate in phonemic script, employment on protected bases other than religion, such as race, color, national origin, sex, age, or disability.  Thus, a religious organization is not permitted to engage in essay of divorce, racially discriminatory hiring by Ancient Roman em asserting that a tenet of its religious beliefs is not associating with people of other races. Similarly, a religious organization is essay, not permitted to how to writing, deny fringe benefits to married women but not to of divorce, married men by asserting a religiously based view that only phonemic script, men can be the head of of divorce a household. Sex Discrimination Not Excused.
Justina works at outdoors essay Tots Day Care Center. Tots is run by a religious organization that believes that, while women may work outside of the essay of divorce home if they are single or have their husband’s permission, men should be the heads of essay theoretical their households and the primary providers for their families. Believing that men shoulder a greater financial responsibility than women, the organization pays female teachers less than male teachers. The organization’s practice of unequal pay based on sex constitutes unlawful discrimination.  Courts have held, based on First Amendment constitutional considerations, that clergy members cannot bring claims under the 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 its ministers is its lifeblood.”  This “ministerial exception” comes not from the essay text of the statutes, but from the First Amendment principle that governmental regulation of church administration, including the appointment of how to writing clergy, impedes the free exercise of religion and constitutes impermissible government entanglement with church authority.  Thus, courts will not ordinarily consider whether a church’s employment decision concerning one of its ministers was based on essay of divorce discriminatory grounds, although some courts have allowed ministers to bring sexual harassment claims.  The ministerial exception applies only to those employees who perform essentially religious functions, namely those whose primary duties consist of engaging in church governance, supervising a religious order, or conducting religious ritual, worship, or instruction.  The exception is not limited to ordained clergy,  and has been applied by courts to accounting answers, others involved in clergy-like roles who conduct services or provide pastoral counseling. However, the exception does not necessarily apply to everyone with a title typically conferred upon clergy ( e.g. , minister).  In short, in each case it is necessary to make a factual determination of whether the 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 essay, 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 how to writing a certain religion, may not impose stricter promotion requirements for persons of a certain religion, and may not impose more or different work requirements on an employee because of of divorce that employee’s religious beliefs or practices.  The following sub-sections address work scenarios that may lead to theoretical, claims of of divorce religious discrimination. 1. Recruitment, Hiring, and hill accounting answers Promotion. Employers that are not religious organizations may neither recruit individuals of a particular religion nor adopt recruitment practices, such as word-of-mouth recruitment, that have the 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.” 
For example, an employer may not refuse to hire an applicant simply because he does not share the employer’s religious beliefs, and conversely may not select one applicant over another based on essay of divorce a preference for employees of outdoors essay a particular religion.  Similarly, employment agencies may not comply with requests from employers to engage in discriminatory recruitment or referral practices, for example by screening out applicants who have names often associated with a particular religion ( e.g., Mohammed). Of Divorce! 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.  Charles, the president of a company that owns several gas stations, needs managers for american foreign policy, the new convenience stores he has decided to essay, add to the stations. He posts a job announcement at the Hindu Temple he attends and term 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 Hindus, Charles is engaging in unlawful discrimination. Mary is essay of divorce, a human resources officer who is filling a vacant administrative position at essay foreign her company. During the application process, she performs an Internet search on the candidates and learns that one applicant, Jonathan, has written an essay of divorce article for the local chapter of the Ethical Society setting forth his view that religion has been historically divisive and how to writing explaining why he subscribes to 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 essay of divorce she believes they would be more comfortable working with someone like-minded. By not hiring Jonathan because of his lack of religious identification, the essay foreign theoretical company violated Title VII. Darpak, who practices Buddhism, holds a Ph.D. degree in essay, engineering and for psychology class applied for a managerial position at the research firm where he has worked for ten years. He was rejected in essay of divorce, favor of a non-Buddhist candidate who was less qualified. Outdoors 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 of divorce firm’s clients, many of whom are Christian. Outdoors Essay! 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 of divorce best qualified candidate for the position, suggests that the proffered reason was a pretext for discrimination against Darpak because of how to writing his religious views.  Title VII also prohibits employers from disciplining or discharging employees because of their religion.  Joanne, a retail store clerk, is frequently 10-15 minutes late for her shift on several days per week when she attends Mass at essay a Catholic Church across town. Her manager, Donald, has never disciplined her for this tardiness, and instead filled in for her at phonemic script the cash register until she arrived, stating that he understood her situation. On the of divorce 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 phonemic script, 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 disciplining only 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 reasonable accommodation. While the essay of divorce employer may require employees to be punctual, it may have to accommodate an employee who seeks leave or a schedule change to resolve the outdoors essay conflict between religious services and of divorce a work schedule, unless the accommodation would pose an undue hardship.  3. Compensation and Other Terms, Conditions, or Privileges of Employment. Title VII prohibits discrimination on Ancient Roman em a protected basis “with respect to essay, . Phonemic Script! . . compensation, terms, conditions, or privileges of employment,” for example, setting or adjusting wages, granting benefits, and/or providing leave in a discriminatory fashion. Essay Of Divorce!  Wages and Benefits. Janet, who practices Native American spirituality, is a newly hired social worker for an agency. As a benefit to its employees, the outdoors essay agency provides tuition reimbursement for professional continuing education courses offered by essay of divorce selected providers. Janet applied for tuition reimbursement for accounting homework, an approved course that was within permitted cost limit. Janet’s supervisor denied her request for tuition reimbursement, stating that since Janet believes in essay, “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 her employment, Janet’s supervisor has discriminated against Janet on foreign policy theoretical the basis of of divorce religion. Title VII’s prohibition on phonemic script disparate treatment based on religious beliefs also can apply to disparate treatment of religious expression in the workplace. 
Eve is a secretary who displays a Bible on her desk at of divorce work. Xavier, a secretary in the same workplace, begins displaying a Quran on mcgraw hill accounting answers his desk at work. 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 essay, the display of a religious item at work constitutes disparate treatment based on religion in violation of Title VII.  Charges involving religious expression may present claims not only of disparate treatment, but also of harassment and/or denial of term paper class reasonable accommodation. Investigation of claims of harassment and denial of reasonable accommodation are addressed respectively in §§ III and IV of this document. As discussed in greater detail in those sections, Title VII requires employers to essay, accommodate expression that is based on mcgraw answers a sincerely held religious practice or belief, unless it threatens to constitute harassment or otherwise poses an essay of divorce undue hardship on the conduct of the business. For Psychology Class! Thus, for example, an essay of divorce employer can restrict religious expression where it would cause customers or co-workers reasonably to perceive the materials to Roman, express the employer’s own message, or where the item or message in question is harassing or otherwise disruptive.  For further discussion of how to analyze when accommodation of religious expression would pose an undue hardship, refer to the sections on Harassment at essay of divorce § III-C and Ancient Roman Accommodation at § IV-C-6. If an employer takes an action based on the discriminatory preferences of essay of divorce others, including co-workers or clients, the employer is 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 work crew from the phonemic script construction site near the 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 let him go because the customers’ discomfort is essay of divorce, 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. 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 term for psychology, a nondiscriminatory manner. For example, an employer may not require Muslim applicants to undergo a background investigation or more extensive security procedures because of their religion while not imposing the same requirements on similarly situated applicants who are non-Muslim, unless such job requirements are imposed by essay of divorce federal statute or Executive Order in the interest of national security. Outdoors Essay! 
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 the normal operation of that particular business or enterprise.”  Religious organizations do not typically need to rely on this BFOQ defense, however, because the “religious organization” exception in Title VII permits them to prefer their co-religionists. See supra § I-C. It is well settled that for employers that are not religious organizations and therefore seek to of divorce, rely on the BFOQ defense to hill accounting homework, justify a religious preference, the defense is essay of divorce, a narrow one and can rarely be successfully invoked.  Employers can reduce the risk of discriminatory employment decisions by establishing written objective criteria for evaluating candidates for hire or promotion and applying those criteria consistently to all candidates. In conducting job interviews, employers can ensure nondiscriminatory treatment by phonemic script asking the essay of divorce same questions of all applicants for a particular job or category of job and mcgraw hill answers inquiring about essay of divorce, matters directly related to the position in question. American Essay Theoretical! Employers can reduce the risk of 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 subjective judgment, employers can reduce the risk of discriminatory decisions by providing training to inexperienced managers and 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 of divorce, being served by an employee due to religious garb, the employer should consider engaging with and educating the phonemic script 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.  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 employer to reconcile its dual obligations to take prompt remedial action in response to alleged harassment and to of divorce, 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 employment (this type of “quid pro phonemic script quo” harassment may also give rise to a disparate treatment or denial of accommodation claim in essay of divorce, some circumstances),  or (2) subjected to phonemic script, unwelcome statements or conduct that is based on religion and is so severe or pervasive that the individual being harassed reasonably finds the essay work environment to how to writing, be hostile or abusive, and there is a basis for holding the essay of divorce employer liable.  1. Roman! 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 receiving a job benefit or avoiding an adverse action.  Religious Conformance Required for Promotion. Wamiq was raised as a Muslim but no longer practices Islam. Essay! His supervisor, Arif, is Ancient Roman, a very devout Muslim who tries to persuade Wamiq not to abandon Islam and advises him to essay, follow the teachings of the phonemic script Quran. Arif also says that if Wamiq expects to advance in essay of divorce, 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 for psychology class, attend the weekly prayer sessions, and was subsequently denied the promotion for which he applies even though he was the most qualified. Essay Of Divorce! Arif’s conduct indicates that the promotion would have been granted if Wamiq had participated in the prayer sessions and outdoors essay had become an of divorce observant Muslim.
Absent contrary evidence, the employer will be liable for harassment for conditioning Wamiq’s promotion on his adherence to Arif’s views of appropriate religious practice.  This would also be actionable as disparate treatment based on religion. Ancient! In addition, if the prayer sessions were made mandatory and Wamiq had asked to be excused on religious grounds, Arif would have been required to of divorce, excuse him from the prayer sessions as a reasonable accommodation. A claim of harassment based on 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. How To Writing! By contrast, an employer would not be engaging in coercion if it required an employee to participate in essay, 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 phonemic script, accommodate the employee’s request to be excused. However, the of divorce same fact pattern may give rise to claims of disparate treatment, harassment, and/or denial of accommodation. Outdoors Essay! For example, terminating rather than accommodating an employee may give rise to both denial of accommodation and discriminatory discharge claims.  For discussion of the accommodation issue, see § IV, infra . Title VII’s prohibition against religious discrimination can also be violated if the employee is of divorce, subjected to a hostile work environment because of religion. Phonemic Script!  An unlawful hostile environment based on religion might take the essay of divorce 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 “workplace is mcgraw, permeated with discriminatory intimidation, ridicule, and insult that is sufficiently severe or pervasive to of divorce, alter the conditions of the victim’s employment and create an abusive working environment.”  To establish a case of term paper for psychology class religious harassment, an employee must show that the of divorce harassment was: (1) based on his religion; (2) unwelcome; (3) sufficiently severe or pervasive to alter the conditions of employment by creating an intimidating, hostile, or offensive work environment; and, (4) that there is accounting homework answers, a basis for employer liability.  To support a religious harassment claim, the essay of divorce adverse treatment must be based on religion.  This standard can be satisfied regardless of whether the harassment is phonemic script, motivated by the religious belief or observance or lack thereof of either the harasser or the essay of divorce targeted employee.
Moreover, while verbally harassing conduct clearly is essay policy theoretical, based on essay of divorce religion if it has religious content, harassment can also be based on religion even if religion is american essay foreign policy, not explicitly mentioned.  Harassing Conduct Based on Religion Religion Mentioned. Mohammed is an Indian-born Muslim employed at of divorce a car dealership. Because he takes scheduled prayer breaks during the phonemic script 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 essay of divorce managers began making mocking comments about his religious dietary restrictions and need to pray during the workday. Term Paper For Psychology! They repeatedly referred to him as “Taliban” or “Arab” and asked him “why don’t you just go back where you came from essay 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 homework answers way things work over here. This is essay of divorce, not the Islamic country where you come from.” After this confrontation, the Roman 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 of divorce his “militant stance.” This harassment is “based on” religion and national origin.  Harassing Conduct Based on 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 phonemic script 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 essay client meetings on Friday afternoons, and phonemic script often marked Shoshanna AWOL when she was not scheduled to work.
In addition, Nicholas treated her differently than her colleagues by, for example, denying her training opportunities and of divorce loudly berating her with little or no provocation. Although Nicholas did not mention Shoshanna’s religion, the evidence shows that his conduct was because of Shoshanna’s need for religious accommodation, and hill homework therefore was “based on” religion. Of Divorce!  To be unlawful, harassing conduct must be unwelcome. Conduct is “unwelcome” when the phonemic script employee did not solicit or incite it and regards it as undesirable or offensive.  It is necessary to evaluate all of the essay surrounding circumstances to determine whether or not particular conduct or remarks are unwelcome.  For example, where an employee is upset by repeated mocking use of derogatory terms or comments  about his religious beliefs or observance by a colleague, it may be evident that the conduct is unwelcome. This would stand in outdoors essay, stark contrast to a situation where the same two employees were engaged in a consensual conversation that involves a spirited debate of religious views, and neither employee indicates that he was upset by it. The distinction between welcome and unwelcome conduct is especially important in the religious context in essay of divorce, situations involving proselytizing of employees who have not invited such conduct.  Where a religious employee attempts to persuade a non-religious employee of the correctness of his belief, or vice versa, the conduct may or may not be welcome. For Psychology Class! When an employee objects to particular religious expression, unwelcomeness is evident.  Beth’s colleague, Bill, repeatedly talked to her at work about her prospects for of divorce, 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 how to writing line” and should stop having non-work related conversations with her, the essay conduct was clearly unwelcome.  Even unwelcome religiously motivated conduct is not unlawful unless “the victim . . Phonemic Script! . Essay Of Divorce! subjectively perceive[s] the outdoors essay environment to be abusive” and the conduct is essay, “severe or pervasive enough to how to writing, create an objectively hostile or abusive work environment -- an environment that a reasonable person would find hostile or abusive.”  Whether a reasonable person would perceive the essay conduct as abusive turns on outdoors essay common sense and context, looking at of divorce the totality of the circumstances.  Relevant factors include whether the conduct was abusive, derogatory, or offensive;  whether the conduct was frequent;  and whether the conduct was humiliating or physically threatening. Term Paper For Psychology! 
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 essay 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.  To “alter the conditions of employment,” conduct need not cause economic or psychological harm. Outdoors Essay!  It need not impair work performance, discourage employees from remaining on the job, or impede their advancement.  The presence of of divorce one or more of those factors would buttress the claim, but is not required.  However, Title VII is term paper class, not a general civility code, and does not render all insensitive or offensive comments, petty slights, and annoyances illegal. Essay Of Divorce!  Offhand or isolated incidents (unless extremely serious) will not rise to the level of illegality.  Insensitive Comments Not Enough To Constitute Hostile Environment. Marvin is an Orthodox Jew who was hired as a radio show host. 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 co-worker’s comments about his yarmulke were insensitive, they were not sufficiently severe or pervasive to create a hostile work environment for Marvin.  Isolated Comments Not Enough to how to writing, Constitute Hostile Environment.
Bob, a supervisor, occasionally allowed spontaneous and voluntary prayers by essay employees during office meetings. During one meeting, he referenced Bible passages related to american foreign theoretical, “slothfulness” and essay “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. They were not severe, and because they occurred infrequently, they were not sufficiently pervasive to state a claim. Phonemic Script!  The severity and essay pervasiveness factors operate inversely. Essay Policy Theoretical! The more severe the harassment, the essay of divorce less frequently the incidents need to recur. At the same time, incidents that may not, individually, be severe may become unlawful if they occur frequently or in close proximity.  Although a single incident will seldom create an unlawfully hostile environment, it may do so if it is unusually severe, particularly if it involves physical threat.  One Instance of Physically Threatening Conduct Is Enough to Constitute Hostile Environment. Ihsaan is hill, a Muslim.
Shortly after the terrorist attacks on of divorce September 11, 2001, Ihsaan came to how to writing, work and found the essay of divorce words “You terrorists go back where you came from! We will avenge the victims!! Your life is next!” scrawled in red marker on his office door. Because of the timing of the how to writing statement and the direct physical threat, this incident, alone, is sufficiently severe to constitute hostile environment harassment based on religion and national origin.  Persistent Offensive Remarks Constitute Hostile Environment. Betty is a Mormon. During a disagreement regarding a joint project, a co-worker, Julian, tells Betty that she doesn’t know what she is of divorce, talking about and Ancient em 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 of divorce, it.” Over the how to writing 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 essay an employee can become severe or pervasive, whether or not the how to writing content is essay, intended to be insulting or abusive. Thus, for example, persistently reiterating atheist views to a religious employee who has asked that it stop can create a hostile environment. Ancient Roman Em! However, the extent to which the essay expression is directed at policy a particular employee is relevant to determining whether or when it could reasonably be perceived to be severe or pervasive by that employee.  For example, although it is essay of divorce, conceivable that one employee may allege that he is offended by a colleague’s wearing of religious garb, expressing one’s religion by 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 not objectively hostile. Nor is it directed at any particular individual. Roman Em! 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 the company cafeteria, Clarence often overhears conversations between his co-workers Dharma and Khema. Dharma, a Buddhist, is discussing meditation techniques with Khema, who is interested in of divorce, Buddhism. For Psychology! Clarence strongly believes that meditation is an occult practice that leads to devil worship and complains to their supervisor that Dharma and 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 of divorce him. Overview: An employer is always liable for a supervisor’s harassment if it results in outdoors essay, a tangible employment action. However, if it does not, the employer may be able to avoid liability or limit damages by 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 essay of divorce, take advantage of any preventive or corrective opportunities provided by the employer or to avoid harm otherwise. In cases of harassment by a co-worker or a third party over whom the employer had some control, an employer is liable if it knew or should have known about the harassment and failed to take immediate and appropriate corrective action. 1. Harassment by Supervisors or Managers. Employers are automatically liable for supervisory harassment that results in a tangible employment action such as a denial of promotion, demotion, discharge, or constructive discharge. If the phonemic script harassment does not result in a tangible employment action, the employer can attempt to prove, as an of divorce affirmative defense to liability, that: (1) the employer exercised reasonable care to prevent and promptly correct any harassing behavior, and (2) the employee unreasonably failed to take advantage of any preventive or corrective opportunities provided by the employer or to otherwise avoid harm.  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 foreign policy, a zealot with his own agenda and essay of divorce cannot be trusted to act in american foreign theoretical, the best interests of the of divorce public.
George particularly ridicules Debra, a devoutly observant Jehovah’s Witness, and consistently withholds the phonemic script most desirable assignments from her. Essay Of Divorce! He denies her request for a promotion to phonemic script, 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 its position statement that it is not liable because Debra never made a complaint under its internal anti-harassment policy and complaint procedures. Of Divorce! Because the term for psychology class harassment culminated in of divorce, a tangible employment action (failure to promote), the employer is Roman, 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 essay of divorce it, because XYZ widely and regularly publicized it. Outdoors Essay! Despite his knowledge of the 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 supervisor’s harassing conduct, the of divorce employer promptly investigated, and acted effectively to stop the supervisor’s conduct. Jennifer then filed a religious harassment charge. Because the Roman harassment of Jennifer did not culminate in essay of divorce, a tangible employment action, XYZ may assert as an affirmative defense that it is not liable because Jennifer failed to hill accounting homework answers, make a complaint under its internal anti-harassment policy and essay 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 how to writing reasonable corrective measures once it did learn of the harassment. An employer is liable for of divorce, harassment by co-workers where it: knew or should have known about the harassment, and how to writing failed to take prompt and appropriate corrective action.  Harassment by Co-Workers.
John, who is a Christian Scientist, shares an office with Rick, a Mormon. Essay Of Divorce! Rick repeatedly tells John that he is paper for psychology class, practicing a false religion, and of divorce 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 stop the behavior, John complains to how to writing, their immediate supervisor, who dismisses John’s complaint on the ground that Rick is a nice person who believes that he is just being helpful. If the essay harassment continues, the Roman em employer is liable because it knew, through the supervisor, about Rick’s harassing conduct but failed to take immediate and of divorce appropriate corrective action.  An employer is liable for harassment by non-employees where it: knew or should have known about the harassment, could control the harasser’s conduct or otherwise protect the employee, and Roman em failed to essay of divorce, take prompt and appropriate corrective action.  Harassment by a Contractor. Tristan works for XYZ, a contractor that manages Crossroads Corporation’s mail room. When Tristan delivers the outdoors essay mail to Julia, the Crossroads receptionist, he gives her religious tracts, attempts to convert her to essay of divorce, his religion, and persists even after she tells him to Roman em, stop. Julia reports Tristan’s conduct to her supervisor, who tells her that he cannot do anything because Tristan does not work for Crossroads. If the harassment continues, the of divorce supervisor’s failure to act will subject Crossroads to liability because Tristan’s conduct is pervasive and term paper for psychology class 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 of divorce 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 Employers When Balancing Anti-Harassment and Accommodation Obligations With Respect to Religious Expression. While some employees believe that religion is intensely personal and private, others are open about their religion. American Essay Foreign Policy!  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 express their religious views and share their religion with their employees. Of Divorce!  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 foreign practices can give rise to conflicts requiring employers to balance the rights of employees who wish to express their religious beliefs with the of divorce rights of other employees to be free from religious harassment under the foregoing Title VII harassment standards.  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 for psychology accommodation could potentially constitute harassment of co-workers, because that would pose an undue hardship for the employer. Therefore, while Title VII requires employers to accommodate an essay of divorce employee’s sincerely held religious belief in engaging in religious expression ( e.g. , proselytizing) in the workplace, an employer does not have to outdoors essay, allow such expression if it imposes an undue hardship on the operation of the business. Essay Of Divorce! For example, it would be an undue hardship for phonemic script, an employer to accommodate proselytizing by of divorce 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.  Because employers are responsible for maintaining a nondiscriminatory work environment, they are liable for perpetrating or tolerating religious harassment of their employees. Term Paper! An employer can reduce the chance that employees will engage in conduct that rises to essay of divorce, the level of unlawful harassment by implementing an anti-harassment policy and outdoors essay an effective procedure for essay of divorce, reporting, investigating, and correcting harassing conduct.  Even if the policy does not prevent all such conduct, it will likely limit the outdoors essay employer’s liability where the affected employee allows the conduct to of divorce, rise to the level of illegality by failing to report it. However, Title VII violations may result if an employer tries to accounting homework answers, 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 beliefs be accommodated as long as no undue hardship is posed.
Employers should have a well-publicized and of divorce consistently applied anti-harassment policy that: (1) covers religious harassment; (2) clearly explains what is prohibited; (3) describes procedures for bringing harassment to management’s attention; and, (4) contains an Roman 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. Essay! Once an employer is on notice that an em employee objects to religious conduct that is directed at him or her, the essay of divorce 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 affect the conditions of Roman em employment if allowed to persist in the face of the employee’s objection. If harassment is perpetrated by essay a non-employee assigned by a contractor, the supervisor or other appropriate individual in the chain of command should initiate a meeting with the paper contractor regarding the harassment and essay 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 escalating to the level of a Title VII violation, employers should immediately intervene when they become aware of objectively abusive or insulting conduct, even absent a complaint. Employers should encourage managers to intervene proactively and discuss with subordinates whether particular religious expression is welcome if the 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 em, 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 employer, once on notice, to reasonably accommodate an employee whose sincerely held religious belief, practice, or observance conflicts with a work requirement, unless providing the essay of divorce accommodation would create an undue hardship.  However, the american essay foreign policy Title VII “undue hardship” defense is defined very differently than the “undue hardship” defense for disability accommodation under the Americans with Disabilities Act (ADA). Essay Of Divorce! Under Title VII, the undue hardship defense to mcgraw hill homework answers, 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 a far lower standard for an employer to of divorce, meet than undue hardship under the ADA, which is defined in how to writing, that statute as “significant difficulty or expense.”  A religious accommodation claim is essay of divorce, distinct from mcgraw accounting answers a disparate treatment claim, in which the question is whether employees are treated equally. An individual alleging denial of religious accommodation is of divorce, seeking an american essay foreign policy theoretical adjustment to a neutral work rule that infringes on the employee’s ability to practice his religion. Essay Of Divorce! The accommodation requirement is term, “plainly intended to relieve individuals of the essay burden of phonemic script choosing between their jobs and their religious convictions, where such relief will not unduly burden others.” 
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 essay, subject to the limit of essay more than de minimis cost or burden. 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 essay particular requirement so that the employee or applicant will be able to answers, practice his or her religion. Essay Of Divorce! Accommodation requests often relate to work schedules, dress and phonemic script 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 accommodation and that it is being requested due to a conflict between religion and work. The employee is obligated to explain the religious nature of the of divorce belief or practice at Ancient issue, and cannot assume that the essay of divorce employer will already know or understand it.  Similarly, the employer should not assume that a request is invalid simply because it is based on religious beliefs or practices with which the employer is unfamiliar, but should ask the employee to explain the religious nature of the phonemic script 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 essay of divorce a requirement for applying for accounting homework, or performing the job. Essay!  Failure to Advise Employer That Request Is Due to Religious Practice or Belief. Jim agreed to phonemic script, 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 employer failed to accommodate his religious objection to swearing an essay of divorce oath. Until it received notice of the Ancient Roman charge, the employer did not know that Jim’s refusal to sign the of divorce form was based on his religious beliefs. Because the employer was not notified of the conflict at the time Jim refused to sign the form, or at any time prior to Jim’s termination, it did not have an opportunity to offer to accommodate him. The employer has not violated Title VII. Outdoors Essay!  While an employer is not required by Title VII to conduct a discussion with an essay of divorce employee before denying the phonemic script employee’s accommodation request, as a practical matter it can be important to of divorce, do so. Both the employer and the employee have roles to play in resolving an accommodation request. Ancient! In addition to placing the essay of divorce employer on notice of the need for accommodation, the Ancient em employee should cooperate with the of divorce employer’s efforts to 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 Roman, needed to determine whether an accommodation is available that would eliminate the religious conflict without posing an undue hardship on the operation of the employer’s business.  This typically involves the employer and essay of divorce employee mutually sharing information necessary to process the accommodation request. Employer?employee cooperation and flexibility are key to outdoors essay, the search for essay of divorce, a reasonable accommodation. If the accommodation solution is not immediately apparent, the employer should discuss the request with the employee to determine what accommodations might be effective. Essay Foreign! If the employer requests additional information reasonably needed to evaluate the request, the employee should provide it. Failure to confer with the 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 employer has made no effort to act on an accommodation request, courts have found that the employer lacked the evidence needed to essay of divorce, meet its burden of proof to establish that the phonemic script plaintiff’s proposed accommodation would actually have posed an undue hardship.  Likewise, courts have ruled against employees who refused to cooperate with an employer’s requests for reasonable information when, as a result, the of divorce employer was deprived of the information necessary to resolve the term paper for psychology accommodation request. For example, if an employee requested a schedule change to accommodate daily prayers, the employer might need to ask for information about the religious observance, such as time and essay of divorce duration of the daily prayers, in order to determine if accommodation can be granted without posing an undue hardship on the operation of the outdoors essay employer’s business.  Moreover, even if the employer does not grant the employee’s preferred accommodation but instead provides an alternative accommodation, the essay employee must cooperate by term for psychology attempting to meet his religious needs through the employer’s proposed accommodation if possible.  Where the accommodation request itself does not provide enough information to of divorce, enable the employer to make a determination, and the employer has a bona fide doubt as to how to writing, the basis for essay of divorce, the accommodation request, it is mcgraw hill accounting, entitled to make a limited inquiry into the facts and of divorce circumstances of the employee’s claim that the belief or practice at issue is religious and sincerely held, and that the belief or practice gives rise to the need for the accommodation. See “Sincerely Held” and “Employer Inquiries into Religious Nature or Sincerity of Belief,” supra §§ I-A-2 and I-A-3.  Whether an employer has a reasonable basis for seeking to verify the employee’s stated beliefs will depend on the facts of a particular case.
Sincerity of Religious Belief Questioned. Bob, who had been a dues-paying member of the outdoors essay 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 essay that he could no longer pay union dues. The union doubted whether Bob’s request was based on american policy theoretical a sincerely held religious belief, given that it appeared to be precipitated by an unrelated dispute with the union, and essay he had not sought this accommodation in his prior fourteen years of 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.  When an american essay foreign theoretical employer requests additional information, employees should provide information that addresses the employer’s reasonable doubts. Essay! 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 employer’s doubts about the sincerity or religious nature of the employee’s professed belief such that third-party verification is unnecessary. Mcgraw Hill! Further, since idiosyncratic beliefs can be sincerely held and of divorce religious, even when third-party verification is needed, it does not have to come from a church official or member, but rather could be provided by others who are aware of the hill accounting homework answers employee’s religious practice or belief.  An employee who fails to cooperate with an employer’s reasonable request for verification of the sincerity or religious nature of a professed belief risks losing any subsequent claim that the employer improperly denied an 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 essay of divorce having their actions challenged as retaliatory or as part of a pattern of harassment.
It also is important to remember that even if an phonemic script employer concludes that an 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 of divorce the conduct of its business. Clarifying a Request. Diane requests that her employer schedule her for paper for psychology class, “fewer hours” so that she can “attend church more frequently.” The employer denies the essay request because it is outdoors essay, not clear what schedule Diane is essay, requesting or whether the change is sought due to outdoors essay, 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 essay of divorce employer should have obtained the information from Diane that it needed to make a decision. The employer could have inquired of Diane precisely what schedule change was sought and for outdoors essay, what purpose, and essay of divorce how her current schedule conflicted with her religious practices or beliefs. Diane would then have had an outdoors essay 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 essay of divorce precise conflict that existed between her work schedule and church schedule, and american whether granting the accommodation would pose more than a de minimis burden on the employer’s business. 3. Essay Of Divorce! What is a “Reasonable” Accommodation?
Although an employer never has to provide an accommodation that would pose an undue hardship, see infra § IV-B, the accommodation that is provided must be a reasonable one. An accommodation is not “reasonable” if it merely lessens rather than eliminates the conflict between religion and how to writing work, provided eliminating the essay of divorce conflict would not impose an undue hardship.  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 paper for psychology employment.  Where there is more than one reasonable accommodation that would not pose an undue hardship, the employer is essay of divorce, not obliged to provide the how to writing accommodation preferred by the employee.  However, an employer’s proposed accommodation will not be “reasonable” if a more favorable accommodation is provided to other employees for non-religious purposes,  or, for example, if it requires the employee to accept a reduction in of divorce, pay rate or some other loss of a benefit or privilege of employment and phonemic script there is an essay alternative accommodation that does not do so.  Ultimately, reasonableness is a fact-specific determination. “The reasonableness of an Ancient Roman em employer’s attempt at accommodation cannot be determined in a vacuum. Instead, it must be determined on a case?by?case basis; what may be a reasonable accommodation for one employee may not be reasonable for another . . Of Divorce! . . ‘The term ‘reasonable accommodation’ is a relative term and cannot be given a hard and fast meaning; each case . . . necessarily depends upon american foreign policy theoretical its own facts and circumstances, and essay comes down to a determination of ‘reasonableness’ under the accounting unique circumstances of the individual employer-employee relationship.’”  Employer Violates Title VII if it Offers Only Partial Accommodation Where Full Accommodation Would Not Pose an essay Undue Hardship. Rachel, who worked as a ticket agent at a sports arena, asked not to be scheduled for Roman em, any Friday night or Saturday shifts, to permit her to of divorce, 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 not reasonable because it does not fully eliminate the religious conflict. The arena may deny the accommodation request only if giving Rachel every Saturday off poses an undue hardship for the arena.  Employer Not Obligated To Provide Employee’s Preferred Accommodation. Tina, a newly hired part-time store cashier whose sincerely held religious belief is outdoors essay, that she should refrain from work on Sunday as part of her Sabbath observance, asked her supervisor never to schedule her to work on Sundays. Essay Of Divorce! Tina specifically asked to how to writing, be scheduled to essay, work Saturdays instead. Ancient Roman Em! In response, her employer offered to essay of divorce, allow her to work on homework Thursday, which she found inconvenient because she takes a college class on that day. Even if Tina preferred a different schedule, the employer is of divorce, not required to grant Tina’s preferred accommodation.  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 accounting, the Labor and Delivery Unit, she advised the nurse manager that her faith forbids her from participating “directly or indirectly in of divorce, ending a life,” and phonemic script that this proscription prevents her from assisting with abortions. Essay! 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. Roman! The hospital concluded that it could not accommodate Yvonne within the Labor and 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. Essay Of Divorce! The hospital is not required to grant Yvonne’s preferred accommodation where it has offered a reasonable alternative solution that eliminates the conflict between work and how to writing a religious practice or belief under its existing policies and procedures. Essay!  If there had been no other position to which she could transfer, the employer would have been entitled to american essay foreign, terminate her since it would pose an undue hardship to essay, accommodate her in the Labor and how to writing Delivery Unit. Title VII is violated by an employer’s failure to accommodate even if to avoid adverse consequences an employee continues to essay of divorce, work after his accommodation request is denied. “An employee does not cease to be discriminated against phonemic script because he temporarily gives up his religious practice and submits to essay of divorce, the employment policy.”  Thus, the fact that an employee acquiesces to the employer’s work rule, continuing to work without an term for psychology class accommodation after the essay employer has denied the request, should not defeat the employee’s legal claim.  In addition, the obligation to provide reasonable accommodation absent undue hardship is a continuing obligation. Employers should be aware that an term for psychology employee’s religious beliefs and practices may evolve over time, and of divorce that this may result in requests for additional or different accommodations.  Similarly, the employer has the paper for psychology 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 undue hardship. Undue hardship may be shown if the accommodation would impose “more than de minimis cost” on the operation of the employer’s business.  The concept of “more than de minimis cost” is discussed below in sub-section 2. Although the essay of divorce employer’s showing of undue hardship under Title VII is easier than under the ADA, the Ancient Roman em burden of persuasion is still on essay of divorce the employer.  If an 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 phonemic script undue hardship “must be made by considering the particular factual context of each case.”  Relevant factors may include the essay of divorce type of workplace, the nature of the employee’s duties, the outdoors essay identifiable cost of the accommodation in relation to essay of divorce, the size and mcgraw operating costs of the employer, and of divorce the number of Roman em employees who will in fact need a particular accommodation.  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 of divorce, demonstrate how much cost or disruption the mcgraw hill homework answers employee’s proposed accommodation would involve.  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. Essay Of Divorce!  A mere assumption that many more people with the same religious practices as the individual being accommodated may also seek accommodation is not evidence of undue hardship. The determination of whether a proposed accommodation would pose an phonemic script undue hardship is based on concrete, fact-specific considerations. Essay!  To establish undue hardship, the employer must demonstrate that the accommodation would require more than de minimis cost.  Factors to accounting homework, 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 essay of divorce, fact need a particular accommodation.”  Generally, the payment of administrative costs necessary for an accommodation, such as costs associated with rearranging schedules and essay policy 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 regular payment of essay of divorce premium wages or the Roman hiring of additional employees to provide an of divorce accommodation will generally cause an undue hardship to the employer.  “[T]he Commission will presume that the infrequent payment of premium wages for a substitute or the payment of term for psychology class premium wages while a more permanent accommodation is being sought are costs which an employer can be required to bear as a means of providing reasonable accommodation.”  Costs to of divorce, 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,  infringes on other employees’ job rights or benefits,  impairs workplace safety, or causes co-workers to class, carry the accommodated employee’s share of potentially hazardous or burdensome work. Essay Of Divorce!  Whether the proposed accommodation conflicts with another law will also be considered.  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 how to writing position he will have to cut his hair, David explains that he keeps his hair long based on his religious beliefs, and essay offers to wear it in a pony tail or held up with a clip. The manager refuses this accommodation, and denies David the american foreign theoretical position based on his long hair. Since the evidence indicated that David could have been accommodated, without undue hardship, by wearing his hair in of divorce, 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 wearing pants, as required by the mill’s dress code, and requested as an accommodation to how to writing, be permitted to essay of divorce, wear a skirt. Management contends that the dress code is essential to Roman em, 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 essay of divorce 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. 
3. Seniority Systems and Collectively Bargained Rights. A proposed religious accommodation poses an undue hardship if it would deprive another employee of a job preference or other benefit guaranteed by a bona fide seniority system or collective bargaining agreement (CBA).  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 phonemic script question is whether an accommodation can be provided without violating the seniority system or CBA.  Allowing voluntary substitutes and of divorce swaps does not constitute an undue hardship to the extent the arrangements do not violate a bona fide seniority system or CBA. Term Paper Class!  Schedules Based on essay a Seniority System or Collectively Bargained Rights. Susan, an foreign policy theoretical employee of essay of divorce 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. Essay Policy Theoretical! If Susan can find qualified co-workers voluntarily willing to swap shifts to accommodate her sincerely held religious beliefs, the essay employer could be found liable for denial of reasonable accommodation if it refuses to Roman, permit the swap to occur. The existence of the collectively bargained system for determining weekend shifts should not result in the denial of accommodation if a voluntary swap can be arranged by the employee without violating the essay of divorce system or otherwise posing an undue hardship.
The result would be the same if QRS had a unilaterally imposed seniority system (rather than a CBA) pursuant to which weekend shifts are determined. However, if other employees were unwilling to term for psychology, swap shifts or were otherwise harmed by not requiring Susan to work on essay the shift in question, or the employer would be subject to mcgraw accounting answers, other operational costs that were more than de minimis by allowing Susan to of divorce, swap shifts, then the Ancient Roman employer can demonstrate undue hardship.  Although infringing on co-workers’ ability to perform their duties  or subjecting co-workers to a hostile work environment will generally constitute undue hardship,  the general disgruntlement, resentment, or jealousy of co-workers will not. Of Divorce!  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 accommodation would actually infringe on the rights of co-workers or cause disruption of work.  See also §§ III-C and IV-C-6 (discussing specifically complaints regarding proselytizing and 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 mcgraw hill accounting homework answers 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 essay requirement to accommodate an employee who has a religious conflict. Accommodation Implicating Security Concerns. Patrick is 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 paper class head covering. Essay! 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 a stated desire that all employees wear uniform clothing so that they can be readily identified by 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 american essay foreign policy theoretical, be worn. William will likely prevail because there is essay, no indication it would pose an undue hardship for the grocery store to modify its policy with respect to his request.  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 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 the workplace. Harvinder explained to Bill that her faith requires her to paper for psychology, wear a kirpan in order to comply with the of divorce Sikh Code of Conduct, and gave him literature explaining that the phonemic script 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 the hospital cafeteria. Of Divorce! Nevertheless, Bill told her that she would be terminated if she continued to term paper for psychology, wear the essay kirpan at work. Absent any evidence that allowing Harvinder to for psychology, wear the kirpan would pose an undue hardship in the factual circumstances of of divorce this case, the hospital is liable for denial of accommodation.  C. Common Methods of Accommodation in the Workplace. Under Title VII, an essay employer or other covered entity may use a variety of methods to provide reasonable accommodations to of divorce, 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 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 departure times, floating or optional holidays, flexible work breaks, use of lunch time in exchange for early departure, staggered work hours, and other means to enable an employee to make up time lost due to the observance of religious practices.  However, EEOC’s position is how to writing, that it will be insufficient merely to eliminate part of the conflict, unless eliminating the conflict in its entirety will pose an undue hardship by disrupting business operations or impinging on of divorce 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 pray at how to writing several prescribed times during the workday in essay, order to adhere to his religious practice of praying at five specified times each day, for several minutes, with hand washing beforehand. 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 undue hardship for his employer. Thus, Rashid is entitled to accommodation.  Blanket Policies Prohibiting Time Off for Religious Observance. A large employer operating a fleet of buses had a policy of outdoors essay refusing to essay, accept driver applications unless the foreign policy theoretical 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 the extent that it discriminates against applicants who refrain from work on certain days for religious reasons, by failing to allow for the provision of religious accommodation absent undue hardship.  2. Voluntary Substitutes and Shift Swaps. Although it would pose an essay undue hardship to require employees involuntarily to substitute for one another or swap shifts, the reasonable accommodation requirement can often be satisfied without undue hardship where a volunteer with substantially similar qualifications is available, either for a single absence or an extended period of 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 substituting for one another or trading shifts to accommodate a religious conflict.  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 do so, reasonable accommodation requires more than merely permitting the employee to swap.  Nevertheless, an employer does not have to 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 frequency of the paper for psychology arrangement will be relevant to determining if it poses an 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 essay employer can be required to bear as a means of phonemic script providing reasonable accommodation.”  An employer may have to make an exception to its scheduling policies, procedures, or practices in order to grant religious accommodation.  For example, if it does not pose an undue hardship, an employer must make an essay exception to its policy of requiring all employees, regardless of seniority, to work an “equal number of hill answers 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 the Sabbath. Of course, if allowing a swap or other accommodation would not provide the coverage the employer needs for of divorce, its business operations or otherwise pose an undue hardship, the accommodation does not have to be granted.
3. Phonemic Script! Change of of divorce Job Tasks and Lateral Transfer. When an employee’s religious belief or practice conflicts with a particular task, appropriate accommodations may include relieving the term for psychology class employee of the task or transferring the employee to a different position or location that eliminates the conflict with the employee’s religion. Whether or not such accommodations pose an of divorce undue hardship will depend on factors such as the nature or importance of the Roman duty at issue, the essay of divorce availability of others to term paper, perform the function, the availability of essay other positions, and phonemic script the applicability of a CBA or seniority system. Restaurant Server Excused from Singing Happy Birthday. Kim, a server at a restaurant, informed her manager that she would not be able to essay of divorce, join other waitresses in Ancient em, singing “Happy Birthday” to customers because she is of divorce, a Jehovah’s Witness whose religious beliefs do not allow her to celebrate holidays, including birthdays. There were enough servers on duty at em 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.  Pharmacist Excused from Providing Contraceptives. Neil, a pharmacist, was hired by a large corporation that operates numerous large pharmacies at which more than one pharmacist is on duty during all hours of of divorce operation. Neil informed his employer that he refused on religious grounds to participate in distributing contraceptives or answering any customer inquiries about contraceptives. The employer reasonably accommodated Neil by offering to allow Neil to how to writing, signal to essay of divorce, a co-worker who would take over servicing any customer who telephoned, faxed, or came to the pharmacy regarding contraceptives.  Pharmacist Not Permitted to Turn Away Customers.
In the above example, assume that instead of facilitating the assistance of hill accounting homework answers such customers by a co-worker, Neil leaves on hold indefinitely those who call on of divorce 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 term paper for psychology, not required to accommodate Neil’s request to remain in essay, 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 how to writing business operations. The employer may discipline or terminate Neil for not meeting legitimate expectations.  The employee should be accommodated in his or her current position if doing so does not pose an undue hardship.  If no such accommodation is possible, the employer needs to consider whether lateral transfer is a possible accommodation. Essay!  For example, if a pharmacist who has a religious objection to outdoors essay, dispensing contraceptives can be accommodated without undue hardship by allowing the pharmacist to signal a co-worker to assist customers with such prescriptions, the employer cannot choose instead to accommodate by transferring the of divorce pharmacist to a different position. Moreover, if the how to writing 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 unavailable or would otherwise pose an undue hardship. Lateral Transfer Versus Transfer to a Lower-Paying Position. An electrical utility lineman requests accommodation of his Sabbath observance, but because the nature of essay his position requires being available to handle emergency problems at any time, there is phonemic script, no accommodation that would permit the lineman to of divorce, remain in outdoors essay, 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 essay of divorce the same pay is readily available, then the employer could satisfy its obligation to reasonably accommodate the lineman by offering to transfer him to a different job, even at lower pay, if one is available. 
4. Modifying Workplace Practices, Policies and Procedures. When an 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.  Religious grooming practices may relate, for 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.  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 mcgraw answers, 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 essay of divorce, religious reasons, the employer offers to allow Prakash to how to writing, wear two face masks instead of trimming his beard. Essay Of Divorce! Prakash thinks that wearing two masks is unreasonable and files a Title VII charge. Essay Foreign Policy! CutX will prevail because it offered a reasonable accommodation that would eliminate Prakash’s religious conflict with the of divorce 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 customers.  While there may be circumstances in which allowing a particular exception to an employer’s dress and essay foreign theoretical grooming policy would pose an essay undue hardship, an hill homework answers employer’s reliance on the broad rubric of “image” to deny a requested religious accommodation may in a given case be tantamount to essay of divorce, reliance on customer religious bias (so-called “customer preference”) in violation of Title VII. 
Nasreen, a Muslim ticket agent for a commercial airline, wears a head scarf, or hijab, to work at phonemic script the airport ticket counter. After September 11, 2001, her manager objected, telling Nasreen that the customers might think she was sympathetic to essay, terrorist hijackers. Essay Policy! Nasreen explains to her manager that wearing the hijab is her religious practice and continues to wear it. She is essay of divorce, terminated for wearing it over her manager’s objection. Ancient! Customer fears or prejudices do not amount to undue hardship, and of divorce the refusal to american essay foreign policy theoretical, accommodate her and the termination, therefore, violate Title VII.
In addition, denying Nasreen the position due to perceptions of customer preferences about of divorce, religious attire would be disparate treatment based on religion in violation of Title VII, because it would be the same as refusing to hire Nasreen because she is a Muslim. See supra § II-B.  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.  However, even in these situations, a case-by-case determination is advisable.  If any employee needs to use a workplace facility as a reasonable accommodation, for example use of a quiet area for prayer during break time, the 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 issue for non-religious activities not related to work, it may be difficult for the employer to demonstrate that allowing the paper for psychology class facilities to be used in the same manner for religious activities is not a reasonable accommodation or poses an undue hardship. 
Use of Employer Facilities. An employee whose assigned work area is 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 work meetings at that time. However, the essay 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 how to writing, example by offering an unoccupied area of the work space rather than the conference room. c. Essay! Tests and Other Selection Procedures. An employer has an how to writing obligation to essay, accommodate an employee or prospective employee when scheduling a test or administering other selection procedures, where the applicant has informed the employer of a sincerely held religious belief that conflicts with a pre-employment testing requirement, unless undue hardship would result. Phonemic Script!  An employer may not permit an essay of divorce 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 phonemic script applicant’s religious practice without undue hardship.  d. Providing Social Security Numbers. It will typically pose an undue hardship for an employer to accommodate an applicant or employee’s asserted religious belief against providing or using a social security number.  5. 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.  Such an of divorce employee can be accommodated by mcgraw hill homework allowing the equivalent of 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 union, and the employer.  Whether a charity-substitute accommodation for payment of essay union dues would cause an undue hardship is an Ancient Roman em individualized determination based upon, among other things, the union’s size, operational costs, and the number of individuals that need the essay accommodation.  If an phonemic script employee’s religious objection is not to joining or financially supporting the union, but rather to the union’s support of certain political or social causes, the 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 donate to of divorce, a charitable organization the full amount the employee owes or that portion that is phonemic script, attributable to the union’s support of the cause to which the employee has a religious objection, or by diverting the full amount to of divorce, the national, state, or local union in how to writing, the event one of those entities does not engage in support of the cause to which the employee has a religious objection. 
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 essay, proselytize by engaging in one-on-one discussions regarding religious beliefs, distributing literature, or using a particular religious phrase when greeting others. Still others may seek to how to writing, engage in prayer at essay of divorce their work stations or to use other areas of the workplace for phonemic script, either individual or group prayer or study. Essay! 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 phonemic script other forms of of divorce religious expression do not solely raise the 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 mcgraw hill homework answers potential disruption, if any, that will be posed by permitting this expression of religious belief.  As explained below, relevant considerations may include the effect such expression has had, or can reasonably be expected to have, if permitted to continue, on essay co-workers, customers, or business operations. a. Effect on Workplace Rights of Co-Workers. Expression can create undue hardship if it disrupts the work of other employees or constitutes or threatens to constitute unlawful harassment. How To Writing! Since an employer has a duty under Title VII to protect employees from of divorce religious harassment, it would be an undue hardship to accommodate such expression.
As explained in Ancient Roman em, § III-A-2-b of this document, religious expression directed toward co-workers might constitute harassment in of divorce, some situations, for example where it is outdoors essay, facially abusive ( i.e. , demeans people of of divorce other religions), or where, even if not abusive, it persists even though the outdoors essay co-workers to whom it is of divorce, directed have made clear that it is unwelcome. It is necessary to make a case-by-case determination regarding whether the how to writing effect on co-workers actually is an undue hardship. However, this does not require waiting until the alleged harassment has become severe or pervasive.  As with harassment on 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.  The determination of 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 essay of divorce customer relations. For example, one court found that it did not impose an american foreign 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 essay, the context of brief anonymous interactions and had little demonstrable adverse impact on customers or the phonemic script business.  However, other courts have found undue hardship where religiously oriented expression was used in the context of a regular business interaction with a client.  Whether or not the essay client objects, this may be an american policy undue hardship for an employer where the expression could be mistaken as the essay of divorce employer’s message. Where the religiously oriented expression is american policy, not limited to use of a phrase or greeting, but rather is in the manner of individualized, specific proselytizing, an essay of divorce employer is far more likely to be able to demonstrate that it would constitute an outdoors essay undue hardship to accommodate an employee’s religious expression, regardless of the length or nature of the business interaction.  Display of Religious Objects By an Employee. Susan and Roger are members of the same church and essay are both employed at 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 outdoors essay other visitors must enter.
At a recent service at Susan and essay of divorce Roger’s church, the 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. Policy! XYZ orders both to remove the poster despite the of divorce fact that both explained that they felt a religious obligation to display it, and american essay foreign policy theoretical despite the of divorce 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 her personal workspace posed an undue hardship, because there was no evidence of any disruption to the business or the Roman 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.  Undue Hardship to Allow Employee to Discuss Religion with Clients. Helen, an employee in a mental health facility that served a religiously and of divorce ethnically diverse clientele, frequently spoke with clients about religious issues and phonemic script shared religious tracts with them as a way to help solve their problems, despite being instructed not to essay, do so. After clients complained, Helen’s employer issued her a letter of reprimand stating that she should not promote her religious beliefs to 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 term paper for psychology class effective and efficient services.
Clients, especially in a mental health setting, may not understand that the of divorce religious message represents Helen’s views rather than the clinic’s view of the most beneficial treatment for the patient.  Some employers have integrated their own religious beliefs or practices into the workplace, and they are entitled to do so.  However, if an employer holds religious services or programs or includes prayer in business meetings, Title VII requires that the employer accommodate an employee who asks to be excused for religious reasons, absent a showing of term paper for psychology undue hardship.  Excusing an employee from of divorce religious services normally does not create an undue hardship because it does not cost the american essay foreign theoretical employer anything and does not disrupt business operations or other workers.  Prayer at 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. He asks his supervisor to allow him to arrive at the meeting after the prayer. 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 of divorce Michael’s religion do not object to being present for term, the prayer.  Employer Holiday Decorations.
Each December, the president of XYZ corporation directs that several wreaths be placed around the office building and a tree be displayed in of divorce, 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 em same whether in a private or government workplace.  Similarly, an essay of divorce employer is required, absent undue hardship, to excuse an employee from compulsory personal or professional development training where it conflicts with the term class employee’s sincerely held religious beliefs or practices.  There may be cases, however, where an of divorce employer can show that it would pose an american theoretical undue hardship to provide an alternative training or to excuse an employee from essay any part of a particular training, even if the employee asserts it is contrary to em, his religious beliefs to attend ( e.g. , where the essay of divorce 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 Training Program Employee Must Be Excused. As part of its effort to mcgraw hill, promote employee health and productivity, the new president of a company institutes weekly mandatory on-site meditation classes led by essay of divorce a local spiritualist. Mcgraw! Angelina explains to her supervisor that the 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 essay excusing her from the weekly meditation classes, even if the company and other employees believe that this form of phonemic script 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 of divorce 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. American! The training does not tell employees to 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. Because an employer needs to make sure that its employees know about and comply with such employer workplace rules, it would be an undue hardship for XYZ to excuse Lucille from the of divorce training. While not all of the following issues will be in dispute in 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 phonemic script inquiry, considering these steps: Ascertain the nature of the essay of divorce belief or practice that CP claims R has failed to term for psychology, 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 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. , whether it was made known to R that an essay of divorce accommodation was needed and that it was for religious reasons. The investigator should seek evidence of paper class when, where, how, and to 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 of divorce, resolve the discrepancies between R’s contention and hill answers 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 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 of divorce undue hardship in 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 term paper for psychology issue may have handled payment by this religious objector in 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 essay of divorce, fact have been posed, i.e. , whether the homework alleged burden is more than de minimis . If R’s undue hardship defense is based on cost, ascertain the cost of the accommodation in relation to R’s size, nature of business operations, operating costs, and the impact, if any, of similar accommodations already being provided to other employees. If R’s undue hardship defense is essay of divorce, based on a factor other than cost ( i.e. , disruption, production or staffing levels, security, or other factor), similarly ascertain the impact of the accommodation with respect to 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 reasonable by examining: (1) whether any alternative reasonable accommodation was available; (2) whether R considered any alternatives for accommodation; (3) the alternative(s) for mcgraw hill answers, accommodation, if any, that R actually offered to CP; and (4) whether the alternative(s) the employer offered eliminated the conflict.  If R asserts CP failed to essay, cooperate with R in reaching an accommodation, obtain any available evidence regarding the 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. For Psychology Class! Employers should individually assess each request and avoid assumptions or stereotypes about what constitutes a religious belief or practice or what type of accommodation is of divorce, appropriate. Employers and employees should confer fully and promptly to phonemic script, the extent needed to share any necessary information about the employee’s religious needs and the available accommodation options. An employer is of divorce, not required to how to writing, provide an employee’s preferred accommodation if there is more than one effective alternative to essay of divorce, choose from. Term! An employer should, however, consider the employee’s proposed method of accommodation, and if it is denied, explain to the employee why his proposed accommodation is not being granted. Managers and essay of divorce supervisors should be trained to homework answers, consider alternative available accommodations if the particular accommodation requested would pose an undue hardship. When faced with a request for a religious accommodation which cannot be promptly implemented, an of divorce employer should consider offering alternative methods of accommodation on mcgraw hill homework answers a temporary basis, while a permanent accommodation is being explored. In this situation, an employer should also keep the 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 requirements of the law and should be flexible in evaluating whether or not an accommodation is feasible.
An employer should not assume that an essay accommodation will conflict with the terms of a seniority system or CBA without first checking if there are any exceptions for religious accommodation or other avenues to essay foreign policy, allow accommodation consistent with the essay seniority system or CBA. An employer should not automatically reject a request for hill accounting, religious accommodation just because the accommodation will interfere with the existing seniority system or terms of a CBA. Essay Of Divorce! 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 employee’s religious needs. Mcgraw Homework Answers! Employers should train managers to be aware that, if the requested accommodation would violate the CBA or seniority system, they should confer with the essay of divorce employee to determine if an alternative accommodation is available. Employers should ensure that managers are aware that reasonable accommodation may require making exceptions to policies or procedures that are not part of american foreign policy 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. Essay! Notwithstanding that the legal standard for hill accounting, undue hardship is “more than de minimis ,” employers may of course choose voluntarily to incur whatever additional operational or financial costs they deem appropriate to accommodate an employee’s religious need for scheduling flexibility. 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 exceptions. For example, some employers have policies allowing alternative work schedules and/or a certain number of “floating” holidays for each employee. While such policies may not cover every eventuality and some individual accommodations may still be needed, the number of essay of divorce such individual accommodations may be substantially reduced.
Voluntary Substitutes or Swaps. An employer should facilitate and how to writing encourage voluntary substitutions and 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 essay, help an employee with a religious conflict find a volunteer to 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 american essay foreign, transfer, whether lateral or otherwise, after fully exploring accommodations that would permit the employee to remain in of divorce, his position. Where a lateral transfer is Ancient, 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 essay employee to remain in phonemic script, his current position or an 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 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 essay, resolve the religious conflict by, for phonemic script, example, wearing the item of religious garb in the company uniform color(s). Managers and employees should be trained not to engage in stereotyping based on religious dress and grooming practices and essay of divorce should not assume that atypical dress will create an undue hardship. Employers should be flexible and creative regarding work schedules, work duties, and selection procedures to the extent practicable. Phonemic Script! Employers should be sensitive to the risk of unintentionally pressuring or coercing employees to attend social gatherings after the employees have indicated a religious objection to attending. Permitting Prayer, Proselytizing, and Other Forms of Religious Expression. Employers should train managers to essay, 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 identify alternative accommodations that might be offered to avoid actual disruption ( e.g. Term For Psychology Class! , designating an of divorce unused or private location in Ancient Roman, the workplace where a prayer session or Bible study meeting can occur if it is essay, disrupting other workers). 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 managers and employees. Employees should advise their supervisors or managers of the nature of the conflict between their religious needs and the work rules. How To Writing! 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. Employees who seek to essay, proselytize in mcgraw accounting, 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 religious discrimination may overlap with Title VII’s prohibitions against essay discrimination based on national origin, race, and mcgraw accounting answers color. Where a given religion is essay of divorce, strongly associated or perceived to be associated with a certain national origin, the same facts may state a claim of both religious and national origin discrimination.  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.  Title VII prohibits retaliation by an employer, employment agency, or labor organization because an individual has engaged in protected activity.  Protected activity consists of opposing a practice the employee reasonably believes is american essay, made unlawful by one of the employment discrimination statutes or of filing a charge, testifying, assisting, or participating in any manner in of divorce, an investigation, proceeding, or hearing under the outdoors essay statute. EEOC has taken the position that requesting religious accommodation is protected activity.  Retaliation for 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 offensive to her religious beliefs. She takes her request to human resources, and of divorce informs them that requiring her to attend these prayer meetings is offensive to Ancient Roman, her religious beliefs. Of Divorce! Despite her supervisor’s objections, the human resources department instructs the supervisor that in the circumstances no undue hardship is posed and he must grant the request. Motivated by reprisal, her supervisor shortly thereafter gives her an mcgraw hill homework unjustified poor performance rating, and denies her requests to attend training that is approved for similarly situated employees. This violates Title VII. Employers can reduce the of divorce risk of retaliation claims by training managers and supervisors to 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 employee. HOW APPLICANTS OR EMPLOYEES CAN FILE A CHARGE. If you believe you have been discriminated against by 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 phonemic script, an equal employment opportunity (EEO) proceeding, you may file a charge of essay discrimination with the U.S.
Equal Employment Opportunity Commission (EEOC). Roman Em! Charges against private sector and local and state government employers may be filed in person, by mail, or by telephone by essay contacting the nearest EEOC office. If there is no EEOC office in the immediate area, call toll free 1-800?669?4000 or 1?800?669?6820 (TTY) for more information. To avoid delay, call or write beforehand if you need special assistance, such as an interpreter, to file a charge. Essay Policy! Federal sector employees and applicants should contact the EEO office of the agency responsible for of divorce, the alleged discrimination to initiate EEO counseling. There are strict time frames in which charges of 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 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 300 days if the alleged discrimination arose in a state or locality that has a fair employment practices agency (FEPA) with the phonemic script authority to grant or seek relief for the alleged discrimination. Federal sector employees and of divorce applicants must initiate EEO counseling at the agency responsible for policy, the alleged discrimination within 45 days of the alleged discriminatory event. Allegations of harassment based on of divorce race, color, religion, sex, or national origin are timely if at american essay foreign policy least one incident of harassment that is part of the essay of divorce larger pattern of foreign policy harassment occurred within the filing period. If you wish to essay of divorce, remain anonymous during the period when an class 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 of divorce applicants may remain anonymous during EEO counseling, but lose the 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 american essay theoretical state and local government employers only. Essay! For information on the processing of Ancient em 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 race, color, sex, religion, national origin, age (40 or over), disability, opposition to essay of divorce, 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 term for psychology class, fact, discriminate. The EEOC has a responsibility to essay, 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. , race, religion, etc.) and issues (hiring, promotion, etc.), and the date(s) of the alleged discrimination. You also may be asked to provide a response to the charge and supporting documentation. The EEOC also may ask to phonemic script, visit your work site or to essay, interview some employees. It is important that your company retain records relating to phonemic script, 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 EEOC notice may offer mediation as a method of resolving the charge before an investigation. EEOC’s mediation program is a free service, and participation is of divorce, voluntary. The process is phonemic script, confidential, and there is of divorce, a firewall ( i.e. , total separation) between the mediation program and EEOC’s enforcement activities. Mediation provides employers and charging parties the opportunity to mcgraw hill accounting, reach mutually agreeable solutions early in of divorce, the process.
The EEOC will notify your company if a charge is paper for psychology class, eligible for of divorce, mediation. In the event that mediation does not succeed, the charge is mcgraw hill homework answers, referred for of divorce, investigation. If the EEOC finds reasonable cause to believe that your company discriminated against a charging party, it will invite you to american essay foreign theoretical, conciliate the charge ( i.e. , the EEOC will offer you a chance to resolve the essay matter informally). In some cases, where conciliation fails, the EEOC will file a civil court action. Term Paper Class! If the 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 right to sue to the charging party on request if its handling of the of divorce charge is still pending after 180 days, or earlier if the class 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 the charging party for filing the charge, even if you believe the charge is without merit. You should submit a response to the EEOC and provide the essay information requested, even if you believe the charge is mcgraw hill accounting homework, frivolous.
If the essay 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 essay an investigation is necessary. Of Divorce! You are encouraged to present any facts that you believe show the term for psychology class allegations are incorrect or do not amount to a violation of the law.  This document uses examples that refer to the practices and beliefs of various religions. These examples are intended to clarify the legal principles for 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 obtaining additional information. EEOC assumes no responsibility for their content and does not endorse their organizations or guarantee the accuracy of these sites.  This Section of the Compliance Manual replaces Section 628: Religious Accommodation , EEOC Compliance Manual, Volume II and its Appendices: Appendix A, Policy Statement on essay of divorce 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 phonemic script, 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 essay Wearing of Religious Dress ). Outdoors Essay! 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.  Use of the term “employee” in this document should be presumed to include an applicant and, as appropriate, a former employee.  42 U.S.C. § 2000e-2(a) provides that it is an unlawful employment practice for an employer: (1) to essay of divorce, fail or refuse to Ancient em, 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 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. § 2000e(j) provides that: The term “religion” includes all aspects of religious observance and of divorce practice, as well as belief, unless an employer demonstrates that he is unable to reasonably accommodate an Roman em employee’s or prospective employee’s religious observance or practice without undue hardship on essay of divorce the conduct of the employer’s business.  Federal legislation known as the Workplace Religious Freedom Act (“WRFA”), that has been proposed since the 1990s, would amend Title VII to change the american foreign current “ de minimis ” standard for establishing undue hardship to require employers to show that the accommodation would cause significant difficulty or expense. Essay! See H.R. Ancient Em! 1431, 110th Cong. Essay Of Divorce! (2007). This compliance manual chapter interprets and applies the current federal law, and takes no position on WRFA. Note: Various state and american essay foreign theoretical local laws extend beyond Title VII in essay of divorce, terms of the protected bases covered, the discrimination prohibited or accommodation required, and the legal standards and defenses that apply.  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 Roman em Secular Humanism); Young v. Southwestern Sav. Loan Ass’n, 509 F.2d 140 (5th Cir.
1975) (Title VII violated by requiring atheist employee to essay, attend prayer portion of em business meeting).  Society for Human Resource Management (SHRM) and the Tanenbaum Center for Interreligious Understanding, Religion in essay of divorce, the Workplace Survey, at 6 (Society for Human Resource Management, 2001) (executive summary and information on Ancient Roman em obtaining report available at essay of divorce http://www.tanenbaum.org/research.html (last visited July 2, 2008); Pew Forum on term paper Religion and Public Life, U.S. Religious Landscape Survey (2008), available at http://religions.pewforum.org/reports (last visited July 2, 2008).  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 all charges filed with the essay of divorce Commission that year. Statistics regarding the outdoors essay number of religious discrimination charges filed with the Commission can be found at essay http://eeoc.gov/eeoc/statistics/enforcement/charges.cfm.  “Religion in Ancient em, the Workplace is a Diversity Issue for U.S. Companies,” U.S. Department of State’s Bureau of of divorce International Information Programs (Nov. 28, 2007), available at http://www.america.gov/st/ washfile-english/2007/November/20071128173019xlrennef0.1781427.html (last visited July 2, 2008).  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. How To Writing! , 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 essay 201-203. Theoretical! As explained in n.5, supra , claims under various state or local laws may be analyzed under different standards.  The First Amendment religion and essay speech clauses (“Congress shall make no law respecting an establishment of Ancient Roman em religion, or prohibiting the free exercise thereof; or abridging the essay freedom of speech”) protect individuals against restrictions imposed by 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 government interference with their free exercise and speech rights. Moreover, government employees’ religious expression is how to writing, 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. 1995); Guidelines on essay 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 how to writing http://clinton2.nara.gov/WH/New/html/19970819-3275.html (last visited July 2, 2008)).
Although the Federal Workplace Guidelines are directed at federal employers, they provide useful guidance for private employers as well. Of Divorce! In addition, the U.S. Department of Justice maintains a website, www.firstfreedom.gov, which provides information on outdoors essay a variety of constitutional and essay of divorce statutory religious discrimination issues, including a section on Title VII employment protections based on religion.  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 requested accommodation would have posed an undue hardship because allowing the officer to outdoors essay, 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. 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 of divorce religious grounds , it would not have posed an mcgraw undue hardship under Title VII, or violated the essay of divorce First Amendment Establishment Clause, to accommodate supervisor’s occasional affirmations of Christianity and spontaneous voluntary prayers during meetings).  See, e.g., EEOC v. Townley Eng’g Mfg.
Co. Outdoors Essay! , 859 F.2d 610, 621 (9th Cir. 1988) (court must balance the application of Title VII to essay of divorce, 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).  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 how to writing accommodation); Fraternal Order of 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 of divorce, make a religious exception to its “no beard” policy to accommodate his beliefs, while exempting other officers for medical reasons); Draper v. Logan County Pub. Library , 403 F. Supp. American Essay Foreign! 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 wearing a necklace with a cross ornament).  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 the Federal Workplace Guidelines , supra n.11 ; see also Brown , 61 F.3d at 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 essay of divorce violation of First Amendment Free Exercise Clause).  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. How To Writing! Although this document concerns Title VII, employers and employees should note that there may be state and local laws in essay of divorce, their jurisdiction prohibiting religious discrimination in employment, some of which may be parallel to Title VII and some of which may afford narrower or broader coverage.
 “Theistic” is phonemic script, defined as “believing in a god or gods.” The American Heritage Dictionary of the essay English Language , Fourth Ed , Houghton Mifflin Co. (2004), available at http://dictionary.reference.com/browse/theistic (last visited July 2, 2008).  42 U.S.C. § 2000e(j). Redmond v. GAF Corp. , 574 F.2d 897, 900 (7th Cir. 1978) (the statutory language “all aspects of religious practice and belief” is interpreted broadly; “to restrict the act to essay policy theoretical, those practices which are mandated or prohibited by a tenet of the religion, would involve the court in determining not only what are the tenets of of divorce a particular religion, which by mcgraw homework 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 not required by the tenets of the religion”); s ee also Employment Div., Dep’t of Human Res. of Oregon v. Essay Of Divorce! Smith , 494 U.S. 872, 887 (1990) (in holding that the Free Exercise Clause did not prohibit application of Oregon drug laws to ceremonial ingestion of peyote, Court noted that “[r]epeatedly and in outdoors essay, many different contexts, we have warned that courts must not presume to determine the place of of divorce a particular belief in how to writing, a religion or the plausibility of of divorce a religious claim”).  Thomas v. Review Bd. Term Paper For Psychology! of the essay of divorce 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 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 nature and is protected by the First Amendment); U.S. v. Roman Em! Meyers , 906 F. Supp. 1494, 1499 (D. Wyo.
1995) (“one man’s religion will always be another man’s heresy”).  Thomas , 450 U.S. at 716 (“[I]t is not within the judicial function and of divorce judicial competence to inquire whether the petitioner or [another practitioner] . . . more correctly perceived the commands of their common faith. Courts are not arbiters of outdoors essay scriptural interpretation.”).  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. Essay Of Divorce! 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 their Title VII holdings.
 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.  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 phonemic script, 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 essay 343 (petitioner’s beliefs were religious in nature although the church to which he belonged did not teach those beliefs); accord Africa v. How To Writing! 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. , 164 F. Of Divorce! Supp. 2d 1066, 1076 n.15 (N.D. Ind. 2001) (“Title VII’s intention is to provide protection and accommodation for Ancient em, a broad spectrum of essay religious practices and belief not merely those beliefs based upon organized or recognized teachings of a particular sect”).  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 homework the First Amendment, a belief system need not have a concept of 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 of divorce compelling its atheist employees to attend religious services); Young , 509 F.2d 140 (same).  United States v. Paper Class! Meyers, 906 F. Supp. 1494, 1499 (D. Essay Of Divorce! Wyo. 1995) (the threshold for establishing the religious nature of beliefs is low; under the how to writing First Amendment, “if there is any doubt about of divorce, whether a particular set of how to writing beliefs constitutes a religion, the Court will err on essay the side of freedom and find that the beliefs are a religion. . . . [because the paper country’s] founders were animated in large part by essay of divorce 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 Oregon drug laws to ceremonial ingestion of peyote, Court noted that “[r]epeatedly and in Roman, 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”).  Meyers, 906 F. Supp. at 1502 (religions address “ultimate ideas,” i.e. Essay! , “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 1483; accord Africa, 662 F.2d at Ancient em 1032 (“a religion [protected by the First Amendment] addresses fundamental and ultimate questions having to essay, do with deep and imponderable matters [and] . . . is essay, comprehensive in nature; it consists of essay a belief-system as opposed to an isolated teaching”); Dettmer v. Landon , 617 F. Supp. 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 phonemic script reflects a broad concern for improving the quality of life for essay, 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. Phonemic Script! Am. Panarchate) v. Of Divorce! 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. Essay! Supp. 1382, 1385 (S.D.
Fla. Of Divorce! 1977) (“religious” belief under Title VII “is based on outdoors essay a theory of essay of divorce ‘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). Mcgraw Accounting Homework! Although “religion” is often marked by external manifestations such as ceremonies, rituals or clergy, such manifestations are not required for a belief to be “religious.” E.g., Malnak v. Yogi, 592 F.2d 197, 209-10 (3d Cir. 1979).  For example, EEOC and of divorce courts have found that the Ku Klux Klan is not a religion within the outdoors essay meaning of Title VII because its philosophy has a narrow, temporal, and political character. Commission Decision No. Essay! 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. King Soopers , 809 F. Ancient! Supp. Of Divorce! 809, 810 (D. Colo. 1992) (dismissing religious discrimination claim by a member of the Ku Klux Klan who allegedly was fired for Ancient em, participating in a Hitler rally because the Ku Klux Klan is “political and 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 of divorce, a personal preference and how to writing not a religion). In an analogous case, Peterson v. Wilmur Communications, Inc ., 205 F. Supp. 2d 1014, 1022 (E.D. Wis. 2002), the court held that an employee’s membership in essay of divorce, 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 phonemic script, more than three years, worked to essay, put the term for psychology church’s teachings into practice, and actively proselytizes. However, the 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.”  Compare Tiano v. Dillard Dep’t Stores, Inc ., 139 F.3d 679 (9th Cir. Essay Of Divorce! 1998) (employer not liable for denying employee’s request to how to writing, be absent from work on particular dates to attend a religious pilgrimage where the essay evidence showed that her religious needs could be met by going on the pilgrimage at another time and that the how to writing particular dates she requested were simply a personal preference), with Heller v. EBB Auto Co. , 8 F.3d 1433 (9th Cir. 1993) (employer liable for essay, failing to accommodate Jewish employee’s attendance of spouse’s conversion ceremony); see also Wessling v. Kroger Co. Theoretical! , 554 F. Supp. 548 (E.D.
Mich. 1982) (employer not liable for denial of accommodation where employee requested leave to help children get into their costumes and practice before performance of church play; employee’s own testimony revealed her participation in this instance was more in the nature of of divorce a parental and social obligation); Redmond , 574 F.2d at 901 (employer liable for failing to 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 constituted a “religious obligation”); Weitkenaut v. Goodyear Tire Rubber Co. , 381 F. Supp. 1284, 1288?89 (D. Vt. 1974) (employer liable for failing to protect minister’s attendance at outdoors essay monthly church organizational meetings where it was considered necessary to preparing for his pastoral duties and thus essential to his ability to lead his congregation).  Cf. Essay Of Divorce! LaFevers v. Saffle , 936 F.2d 1117 (10th Cir. American Essay Foreign Theoretical! 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).  See, e.g., Wessling v. Essay Of Divorce! Kroger Co. , 554 F. Supp. Ancient! 548 (E.D.
Mich. Of Divorce! 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 a play during Christmas Mass, was engaging in a social and family obligation rather than a religious belief, practice, or observance).  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 Columbia , 249 F.2d 127, 128 (D.C. Cir. 1957) (Ethical Society qualifies as a “religious corporation or society” and its building is paper for psychology, entitled to essay of divorce, tax exemption; belief in a Supreme Being or supernatural power is not essential to outdoors essay, qualify for essay of divorce, tax exemption accorded to “religious corporations,” “churches” or “religious societies”); Fellowship of Humanity v. How To Writing! County of Alameda , 315 P.2d 394 (Cal. App. 1957) (same holding with respect to essay, Secular Humanists).  EEOC v. Red Robin Gourmet Burgers, Inc. How To Writing! , 2005 WL 2090677 (W.D. Wash.
Aug. 29, 2005) (denying employer’s motion for of divorce, summary judgment on phonemic script accommodation claim arising from employee’s refusal to cover his Kemetic religious tattoos in order to of divorce, comply with employer’s dress code).  These facts are similar to those in Cloutier v. Costco Wholesale Corp. American Foreign Policy! , 390 F.3d 126 (1st Cir. Essay Of Divorce! 2004). However, the court in em, 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 the beliefs of the Church of 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 undue hardship.  Seeger , 380 U.S. at 185 (“[w]hile the ‘truth’ of essay a belief is not open to question, there remains the significant question of whether it is ‘truly held’”).  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 american essay policy his religion, for essay of divorce, example that he worked five days a week rather than the required six, had lied on Ancient em an employment application, and took an of divorce oath before a notary upon becoming a public employee, can be relevant to the evaluation of paper for psychology class sincerity but is not dispositive); Hansard v. Of Divorce! Johns-Manville Prods. Corp ., 1973 WL 129 (E.D.
Tex. Feb. 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. Waldorf-Astoria , 134 F. Supp. Hill Accounting Homework Answers! 2d 591 (S.D.N.Y. Essay! 2001) (employer had a good faith basis to doubt sincerity of american essay foreign policy employee’s professed religious need to essay of divorce, wear a beard because he had not worn a beard at any time in his fourteen years of outdoors essay employment, had never mentioned his religious beliefs to anyone at essay of divorce the hotel, and simply showed up for work one night and asked for an on-the-spot exception to the no?beard policy), aff’d , 2002 WL 390437 (2d Cir. Mar. 13, 2002) (unpublished).  EEOC v. Ilona of Hungary, Inc ., 108 F.3d 1569 (7th Cir. 1997) (en banc) (Jewish employee proved her request for leave to how to writing, observe Yom Kippur was based on a sincerely held religious belief even though she had never in essay of divorce, her prior eight-year tenure sought leave from outdoors essay work for a religious observance, and conceded that she generally was not a very religious person; the essay evidence showed that certain events in her life, including the term paper for psychology birth of her son and the death of her father, had strengthened her religious beliefs over essay, the years); Cooper v. Oak Rubber Co ., 15 F.3d 1375 (6th Cir.
1994) (that employee had worked the Friday night shift at plant for approximately seven months after her baptism did not establish that she did not hold sincere religious belief against working on term for psychology Saturdays, considering that 17 months intervened before employee was next required to essay of divorce, work on term for psychology 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. Of Divorce! Supp. 147 (C.D. Ill. 1993) (Seventh-day Adventist employee’s previous absence of faith and subsequent loss of term faith did not prove that his religious beliefs were insincere at essay of divorce the time that he refused to work on outdoors essay the Sabbath); s ee also Union Independiente, 279 F.3d at 57 n.8 (the fact that the alleged conflict between plaintiff’s beliefs and union membership kept changing might call into essay of divorce, question the sincerity of the beliefs or “might simply reflect an evolution in plaintiff’s religious views toward a more steadfast opposition to union membership”).  Commission Guidelines , 29 C.F.R. § 1605.1; Anderson v. Phonemic Script! U.S.F. Logistics (IMC), Inc. Essay Of Divorce! , 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 phrase was not a requirement of phonemic script 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”).  For the text of 42 U.S.C. Essay Of Divorce! § 2000e-2(a), which applies to employers, see supra n.4. Under 42 U.S.C. § 2000e-2(b), it is paper, unlawful for employment agencies to “fail or refuse to refer for employment, or otherwise to essay of divorce, discriminate against, any individual because of his . . . religion . . . Phonemic Script! or to classify or refer for employment any individual on essay of divorce the basis of paper class his . . . religion . . . .” Under 42 U.S.C. Essay Of Divorce! § 2000e-2(c), it is for psychology, unlawful for unions to “(1) to exclude or expel from membership, or otherwise to discriminate against, any individual because of his . . . religion . . . Essay Of Divorce! ; (2) to limit, segregate or classify its membership or applicants . . . or to refuse to how to writing, refer for employment any individual . . Essay! . because of such individual’s . . . religion . Mcgraw Hill Homework Answers! . . ; or (3) to cause or attempt to cause an employer to discriminate . . . in violation of this section.”  See, e.g., Union Independiente, 279 F.3d 49; Bushouse , 164 F. Supp. Of Divorce! 2d 1066. See infra §§ II, III, and IV; see also § IV-C-5.  Goodman v. Term Class! 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 expel from its membership, or otherwise to discriminate against, any individual’” when they “ignored [racial] discrimination claims . Essay! . . How To Writing! , knowing that the employer was discriminating in violation of the contract”). See, e.g., Perugini v. Safeway Stores, 935 F. 2d 1083 (9th Cir. 1991) (remand to determine whether union discriminatorily failed to challenge employer’s refusal to give pregnant worker light duty); Rainey v. Town of Warren , 80 F. Essay! Supp. 2d 5, 17 (D.R.I. 2000) (“[i]t is axiomatic that a union’s failure to essay foreign, adequately represent union members in the face of employer discrimination may subject the union to liability under either Title VII or its duty of fair representation”). To the of divorce extent it has been held that a union cannot be held liable where it knowingly acquiesces in discrimination, the EEOC disagrees.
See EEOC v. Pipefitters Ass’n Local Union 597 , 334 F.3d 656 (7th Cir. 2003).  Section 702(a) of Title VII, 42 U.S.C. § 2000e-1(a), provides: This subchapter shall not apply to for psychology class, . . Essay! . Essay! 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 essay of divorce 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 phonemic script a particular religion or by 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 essay propagation of 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 mcgraw accounting legislative history indicates that Congress intended “the § 703(e)(2) exemption to require a lesser degree of association between an entity and a religious sect than what would be required under § 702(a).” See LeBoon v. Lancaster Jewish Cmty. Ctr. , 503 F.3d 217, 237 (3d Cir. 2007) (Rendell, J., dissenting). Executive Order 13279, Equal Protection of the Laws for Faith-Based and essay 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 the basis of their religious beliefs even if they receive federal funding. See 67 Fed. Reg.
77,141 (12/16/02). The Guidance to how to writing, Faith-Based and Community Organizations on Partnering with the essay 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 outdoors essay same religion, they are also subject to federal, state, and local employment and of divorce anti-discrimination laws, such as Title VII.  Townley , 859 F.2d at essay 618; accord Hall v. Baptist Mem. Of Divorce! Health Care Corp. , 215 F.3d 618, 624-25 (6th Cir. 2000) (college of health sciences qualified as a religious institution under Title VII because it was an affiliated institution of hill accounting answers a church-affiliated hospital, had direct relationship with the Baptist church, and the college atmosphere was permeated with religious overtones).  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 Baptist State Board of Missions, university was member of Association of essay Baptist Colleges and Schools, university charter designated its chief purpose as “the promotion of the Ancient Christian Religion throughout the world by maintaining and operating institutions dedicated to the development of Christian character in high scholastic standing,” and both Internal Revenue Service (IRS) and Department of essay of divorce Education recognized university as religious educational institution).
 Townley , 859 F.2d at 619 (manufacturer of american essay foreign policy mining equipment, whose owners asserted that they made a covenant with God that their business “would be a Christian, faith?operated business,” is essay, 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 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 schools are either essentially secular, or neutral as far as religion is concerned).  See Corp. of the Presiding Bishop of the Church of Jesus Christ of phonemic script Latter-Day Saints v. Amos , 483 U.S. Essay Of Divorce! 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).  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. Outdoors Essay! 24, 2001) (seminary operated by Unification Church cannot be sued for religious discrimination by Greek Orthodox employee who was allegedly terminated for refusing to of divorce, accept the teachings of the Unification Church).  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. How To Writing! Holy Cross High Sch. , 4 F.3d 166 (2d Cir. 1993) (religious institutions may not engage in age discrimination).  EEOC v. Fremont Christian Sch. Essay! , 781 F.2d 1362 (9th Cir. 1986) (religious school violated Title VII and the Equal Pay Act when it provided “head of household” health insurance benefits only to phonemic script, single persons and married men).  McClure v. Essay Of Divorce! Salvation Army , 460 F.2d 553, 558-60 (5th Cir. 1972); s ee also Hollins v. How To Writing! Methodist Healthcare, Inc. , 474 F.3d 223 (6th Cir.
2007) (applying ministerial exception to bar claim by resident in hospital’s pastoral care program who alleged disability discrimination); Tomic v. Catholic Diocese of Peoria , 442 F.3d 1036 (7th Cir. 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 play during the Easter Mass); Hankins v. Lyght , 441 F.3d 96 (2d Cir. 2006) (applying ministerial exception to of divorce, bar age discrimination claim); Combs v. Central Texas Annual Conf. of hill accounting homework answers 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 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 essay of divorce tenured member of Catholic University’s department of outdoors essay religious canon law); DeMarco v. Holy Cross High School , 4 F.3d 166 (2d Cir. Of Divorce! 1993) (ministerial exception inapplicable to parochial school teacher’s age discrimination claim because employer’s contention that teacher was terminated specifically for outdoors essay, failing to essay, attend Mass and to lead his students in prayers could be evaluated without risk of excessive entanglement between government and religious institution); Guianan v. Roman Catholic Archdiocese of Indianapolis, 42 F. Supp. How To Writing! 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 religion per term, and organized one worship service per month, since vast majority of teacher’s duties involved teaching math, science, and other secular courses).  Rayburn v. Gen. Conference of Seventh?Day Adventists , 772 F.2d 1164, 1169 (4th Cir. 1985).  Rweyemamu v. Cote , 520 F.3d 198 (2d Cir. 2008) (Title VII race discrimination claim by African-American Catholic priest challenging denial of promotion and subsequent termination was barred by of divorce 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 school, alleging that she was forced out as chaplain after she advocated on mcgraw behalf of alleged victims of of divorce sexual harassment and spoke out against the school’s president regarding alleged sexual harassment and mcgraw accounting homework answers discrimination against female employees); Werft v. Desert Southwest Annual Conf. of the essay of divorce United Methodist Church , 377 F.3d 1099 (9th Cir. 2004) (ministerial exception barred minister’s claim against how to writing church for failure to of divorce, accommodate his disabilities). Essay Foreign Theoretical! However, some courts have ruled that the ministerial exception does not bar harassment claims by ministers, but rather only applies to claims involving matters such as hiring, promotion, and essay of divorce termination. 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. Policy Theoretical! 2005) (two concurring and essay of divorce three dissenting opinions); Bollard v. 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. Heartland Presbytery, 342 F. Policy Theoretical! Supp. 2d 996 (D. Kan. 2004) (First Amendment Establishment and of divorce 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 outdoors essay 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 essay “church autonomy” doctrine; the doctrine is broader than the essay policy ministerial exception and bars civil court review of internal church disputes involving matters of doctrine and essay of divorce church governance).  Geary v. Visitation of Blessed Virgin Mary Parish Sch. , 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. American Policy Theoretical! 1996) (ministerial exception barred Title VII sex discrimination claim brought by tenured member of Catholic university’s department of religious canon law).  Alicea?Hernandez v. Catholic Bishop of Chicago, 320 F.3d 698 (7th Cir.
2003) (ministerial exception applied to Communications Director who was responsible for of divorce, crafting the Church’s message to the Hispanic community); EEOC v. Roman Catholic Diocese of essay foreign policy Raleigh, 213 F.3d 795 (4th Cir. 2000) (ministerial exception applies to cathedral’s director of of divorce music ministry and part-time music teacher); Rayburn , 772 F.2d at 1168 (ministerial exception applies to 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).  EEOC v. 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 any governmental interference, bestowal of how to writing such a designation does not control their extra?religious legal status”).  Abramson v. Of Divorce! William Paterson Coll. of how to writing N.J. , 260 F.3d 265, 281 (3d Cir. 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 the religion context, particularly in the area of of divorce recruitment and outdoors essay hiring. See, e.g., Barrow v. Greenville Indep. Sch. Dist. , 480 F.3d 377 (5th Cir. 2007) (affirming summary judgment, citing lack of of divorce 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.  42 U.S.C. § 2000e-2(e)(1); see also §§ I-C and II-D of this document.  See, e.g., EEOC v. Preferred Mgmt .Corp., 216 F. Supp. Class! 2d 763, 813 (S.D. Ind. 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 hire her was unlawfully based on religion).
 In Noyes v. Kelly Servs. Inc ., 488 F.3d 1163 (9th Cir. Essay Of Divorce! 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 term a small religious group and favored and promoted other members of the essay of divorce religious group. The court ruled that while the outdoors essay employee did not adhere to a particular religion, the fact that she did not share the employer’s religious beliefs was the basis for the alleged discrimination against essay her, and the evidence was sufficient to create an issue for trial on whether the employer’s decision to promote another employee was a pretext for religious discrimination.  Tincher v. Wal-Mart Stores , 118 F.3d 1125, 1131 (7th Cir. Outdoors Essay! 1997) (reasonable jury could conclude that employer’s articulated reason for the discharge of a Seventh-day Adventist was pretextual and essay of divorce that the real reason was religious discrimination because of the inconvenience caused by employee’s inability to Roman em, work on Saturdays); s ee also Campos v. City of Blue Springs, 289 F.3d 546 (8th Cir. Essay! 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 how to writing, proceed to trial in case brought on behalf of recruiter alleging constructive discharge based on her evangelical religious beliefs); Dachman v. Of Divorce! 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. Dep’t of Corr. Outdoors Essay! , 251 F.3d 1199, 1203 (8th Cir. 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 religious beliefs). However, not all employer decisions affect a term, condition, or privilege of employment as required to essay, be actionable as disparate treatment. See, e.g. Phonemic Script! , Goldmeier v. Allstate Ins. Co. , 337 F.3d 629 (6th Cir.
2003) (resignation 53 days prior to 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).  See infra § IV, Reasonable Accommodation.  42 U.S.C. § 2000e-2(a)(1) (discriminating in hiring, discharge, or otherwise with respect to compensation, terms, conditions, or privileges of employment); see also 42 U.S.C. § 2000e-2(a)(2) (discriminating by limiting, segregating, or classifying employees or applicants in essay, a way which would deprive or tend to deprive employment opportunities or otherwise adversely affect employment status); cf. Term For Psychology Class! Ansonia Bd. of of divorce Educ. v. Philbrook , 479 U.S. 60, 71 (1986) (a benefit “that is part and term for psychology parcel of the essay of divorce employment relationship may not be doled out in american policy, a discriminatory fashion, even if the employer would be free . Essay! . Roman! . not to provide the benefit at all”) (quoting Hishon v. King Spalding , 467 U.S. 69, 75 (1984)). However, at essay of divorce least one court has held that a private employer providing company resources to recognized employee “affinity groups” does not violate Title VII by 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).  Delelegne v. Kinney Sys., Inc., 2004 WL 1281071 (D. Mass. June 10, 2004) (Ethiopian Christian parking garage cashier could proceed to trial on claims of outdoors essay religious harassment and discriminatory termination where he was not allowed to 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 display religious materials in essay of divorce, their booths).  This fact pattern may also give rise to a denial of accommodation claim. See infra § IV-C-6.
 Determining whether religious expression disrupts co-workers or customers is discussed in §§ III-C and american essay foreign policy theoretical 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. Essay Of Divorce! 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 neutral rules that burden religion in phonemic script, the federal workplace.  42 U.S.C. § 2000e-2(g) (permitting covered entities to discharge or refuse to “hire and employ” or refer an individual who does not meet federal security requirements). Of Divorce! 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 phonemic script security requirements and Title VII’s accommodation obligation).  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 essay rotation at a Saudi Arabian hospital when the 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 demonstrate that Protestant religious affiliation was a BFOQ for outdoors essay, position as prison chaplain because chaplains were recruited and hired on a facility-wide basis and were entrusted with the job of essay of divorce planning, directing, and Ancient Roman em maintaining a total religious program for all inmates, whatever their respective denominations), with Kern v. Dynalectron Corp ., 577 F. Essay! 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 the fact that non?Muslim employees caught flying into american, Mecca would, under Saudi Arabian law, be beheaded), aff’d , 746 F.2d 810 (5th Cir. 1984), and Pime v. Loyola Univ. of of divorce Chicago , 803 F.2d 351 (7th Cir. 1986) (although university was not a religious organization under Title VII, the hill accounting answers court held that having some Jesuit presence in of divorce, philosophy department was a BFOQ since university was founded by Jesuits, continues to have Jesuit tradition, and requires all of its undergraduates to take philosophy).
 Faragher v. Homework! Boca Raton , 524 U.S. Of Divorce! 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. , 242 F. Supp. American Essay Foreign! 2d 1051, 1063 (N.D. Ala. Essay Of Divorce! 2003), aff’d , 97 Fed.
Appx. Accounting Answers! 906 (11th Cir. 2004) (Table).  See Venters v. City of Delphi , 123 F.3d 956 (7th Cir. 1997) (employee who was terminated after she disagreed with supervisor’s religious beliefs raised a triable Title VII harassment claim based on essay of divorce two separate theories of harassment liability: that a “tangible employment benefit” was conditioned upon phonemic script acquiescing to essay, her supervisor’s religious beliefs, and also that a hostile work environment was created).  Meritor Sav. American Policy Theoretical! Bank, 477 U.S. at 66 (1986) (prohibition on discrimination “in the terms, conditions, or privileges of of divorce employment” requires employers to term for psychology, maintain a workplace free from harassment based upon protected status).
 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 stated that she had to share his Christian beliefs in order to be a good employee).  Many of the example’s facts are taken from essay Sattar v. Phonemic Script! Motorola, Inc ., 138 F.3d 1164 (7th Cir. 1998). However, in Sattar the essay of divorce plaintiff did not prevail because the plaintiff failed to prove that his discharge was linked to the harassment by his former supervisor.  Pederson v. Casey’s Gen. Term Class! Stores, Inc. Essay Of Divorce! , 978 F. Supp.
926 (D. Neb. 1997) (employer’s refusal to accommodate employee’s need to american policy, 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 essay of divorce, constructive discharge in violation of Title VII).  Venters , 123 F.3d at 972 (“the accommodation framework . Phonemic Script! . . has no application when the employee alleges that he was fired because he did not share or follow his employer’s religious beliefs”).  Faragher , 524 U.S. at 788 (environmental harassment claims are actionable on essay of divorce 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 Unlawful Harassment by how to writing Supervisors (1999), available at essay of divorce https://www.eeoc.gov/policy/docs/harassment.html.  Harris v. Forklift Sys., Inc. , 510 U.S. 17, 21 (1993).  Meritor Sav. Bank, 477 U.S. at 67.  Marcus v. West , 2002 WL 1263999, *11 (N.D.
Ill. June 3, 2002) (mistreatment of how to writing Sanctified Pentecostal Christian employee was not because of religion; supervisor mistreated all of her employees and had poor management and interpersonal skills).  Turner v. Essay Of Divorce! Barr , 811 F. Supp. 1, 2 (D.D.C. For Psychology Class! 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 latter two incidents did not refer to religion, the facts showed that he was singled out for such treatment because of essay of divorce his religion).  See EEOC v. Sunbelt Rentals, Inc. , 521 F.3d 306 (4th Cir. 2008) (reversing summary judgment for the employer and remanding the case for trial, the how to writing 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 essay, hostile work environment religious harassment when fellow employees repeatedly called him “Taliban” and “towel head,” made fun of 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. 2007) (reversing summary judgment for outdoors essay, the employer and remanding the case for essay of divorce, 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 is a practicing Muslim was severe or pervasive and american theoretical motivated by his national origin and religion). In Sunbelt , the Fourth Circuit Court of Appeals held: “we cannot regard as ‘merely offensive,’ and essay of divorce 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 outdoors essay the United States, that all Muslims support jihad, that all Muslims were sympathetic to the 9/11 attack, and of divorce that all Muslims are proponents of radical Islam.” 521 F.3d at 318.  See Abramson, 260 F.3d at 279 (supervisor’s criticism of professor’s refusal to work on her Sabbath, scheduling meetings on Jewish holidays, and charging her for leave on those holidays could be found to phonemic script, have “infected [professor’s] work experience” because of essay of divorce her religion).  Henson v. City of Dundee , 682 F.2d 897, 903 (11th Cir.
1982).  See WCM Enter. , 496 F.3d at 400-01 (plaintiff’s religious and national origin harassment claim was based on having been referred to as a “Muslim extremist,” and constantly called “Taliban” among other terms); Khan v. How To Writing! United Recovery Sys., Inc., 2005 WL 469603 (S.D. Tex. 2005) (plaintiff’s religious harassment claim was based on alleged comments by co-worker that court characterized as “malicious and of divorce 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 how to writing, 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 of divorce, his office and justify such activity).  Human resources professionals who responded to a survey by the Society for how to writing, Human Resource Management (SHRM) and the Tanenbaum Center for Interreligious Understanding reported that 19% of the employees in their organizations engaged in proselytizing to co-workers. While 32% of the employees perceived increased cooperation and communication within their organizations due to acceptance of religious diversity, 9% of the employees felt harassed by essay co-workers who expressed their religious beliefs.
Religion in accounting homework, the Workplace Survey, at essay 24 (Society for Ancient Roman em, Human Resource Management, 2001) (executive summary and information on obtaining report available at http://www.tanenbaum.org/research.html (last visited July 2, 2008)).  Venters , 123 F.3d at 976 (because the employee made clear her objection to the comments by essay of divorce telling her supervisor he had “crossed the line,” she established that the comments were unwelcome).  Id. (“whatever questions there might have been as to how to writing, whether Venters welcomed these discussions were answered as of th[e] date [that she told him he had crossed the line]”).  Harris , 510 U.S. at 21-22; Faragher , 524 U.S. at 788 (“We have made it clear that conduct must be extreme to amount to essay, a change in the terms and conditions of Roman em employment.”).  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 essay of divorce workplace behavior often depends on a constellation of surrounding circumstances, expectations, and relationships which are not fully captured by foreign a simple recitation of the words used or the of divorce physical acts performed”); Harris , 510 U.S. at 23.
 Bains LLC v. Arco Prods. How To Writing! 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 “towel-heads,” and were asked to clean up fuel spills with their turbans).  Williams v. Gen. Motors Corp ., 187 F.3d 553, 564 (6th Cir. 1999) (“a work environment viewed as a whole may satisfy the legal definition of an abusive work environment, for essay, purposes of a hostile environment claim, even though no single episode crosses the Title VII threshold”).  Jones v. United Space Alliance , 2006 WL 250761 (11th Cir. Feb. Paper Class! 3, 2006) (unpublished) (plaintiff, a member of the essay of divorce 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 community bulletin board a flyer describing events at the plaintiff’s church, the plaintiff’s manager told him to remove the lanyard for his identification badge because it had “Jesus” on em it, his manager told him not to leave his Bible on his desk, he was asked to turn down the of divorce religious music that he played at em work, and he was accused of 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 plaintiff’s job performance).
 EEOC v. Essay! AKZ Mgmt., Inc. , Civil Action No. 07-8356 (S.D.N.Y. consent decree filed Sept. Phonemic Script! 26, 2007) (settlement of religious harassment and disparate treatment claims on behalf of employees who were pressured by management to practice or conform to Scientology). Of Divorce! See Johnson v. Phonemic Script! 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 essay threatened him with violence); Sattar , 138 F.3d at 1167 (employee harassed with a barrage of hill homework answers e-mails with dire warnings of the essay divine punishments that awaited those who refuse to follow Islam) ; Preferred Mgmt. Corp ., 216 F. Supp. 2d 763 (Christian employer violated Title VII by requiring employees to conform to her views).  Harris , 510 U.S. at 21; Meritor , 477 U.S. at 64.
 Harris , 510 U.S. at 22 (“even without regard to these tangible effects, the for psychology class very fact that the essay of divorce discriminatory conduct was so severe or pervasive that it created a work environment abusive to employees because of american essay policy their race, gender, religion, or national origin offends Title VII’s broad rule of workplace equality . Essay Of Divorce! . Paper For Psychology! . . Certainly Title VII bars conduct that would seriously affect a reasonable person’s psychological well?being, but the statute is not limited to such conduct”); s ee Dey v. Colt Const. Dev. Co ., 28 F.3d 1446, 1454-55 (7th Cir. Essay! 1994) (“The mention in Harris of an unreasonable interference with work performance was not intended to penalize the employee who possesses the dedication and for psychology fortitude to complete her assigned tasks even in the face of offensive and abusive [conduct] . . . . As Justice Scalia separately explained in Harris , the of divorce test under Title VII ‘is not whether work has been impaired, but whether working conditions have been discriminatorily altered.’”) (citation omitted).  See Harris , 510 U.S. at 23 (“whether an environment is Ancient, ‘hostile’ or ‘abusive’ can be determined only by looking at all the circumstances . . . ; no single factor is required”).  Faragher , 524 U.S. at 788 (citing Oncale , 523 U.S. at 80); Sheikh v. Indep.
Sch. Dist. 535 , 2001 WL 1636504 (D. Minn. Oct. 18, 2001) (a Muslim employee who was ostracized by essay of divorce colleagues because he refused to shake hands with female colleagues did not suffer a materially adverse change in the terms and conditions of employment).  See Marcus , 2002 WL 1263999 at *11 (asking very religious employee to how to writing, swear on a Bible to essay of divorce, 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. Outdoors Essay! , 194 F. Supp. Essay Of Divorce! 2d 692, 703 (S.D. Accounting Answers! 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).  Cf.
Tessler v. KHOW Radio, Inc. Of Divorce! , 1997 WL 458489 at term paper class *8 (D. Colo. Apr. 21, 1997).  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).  Williams , 187 F.3d at 563 (in determining whether the alleged conduct rises to 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 essay of divorce impact of the separate incidents may accumulate, and that the work environment created thereby may exceed the sum of the individual episodes”).  Cf . Johnson v. Spencer Press of american Maine, Inc. , 364 F.3d 368 (1st Cir.
2004) (affirming jury verdict for essay, plaintiff on religious harassment claim, court noted that plaintiff testified supervisor who made ongoing derogatory remarks about theoretical, plaintiff’s religion also once put the point of a knife under plaintiff’s chin, in addition to threatening to kill him with a hand grenade, run him over with a car, and shoot him with a bow and arrow).  As with any harassment claim, employer liability will depend on whether the employee can show, in a case of co-worker harassment, that the essay of divorce employer knew or should have known of the misconduct and failed to take prompt and appropriate corrective action. Term Paper For Psychology Class! Additionally, in of divorce, 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.  See Peters v. How To Writing! Renaissance Hotel Operating Co. , 307 F.3d 535 (7th Cir. 2002) (the impact of actions not directed at a complaining employee is not as great as the impact of harassment directed at him and the combined impact of essay of divorce all the comments was not severe or pervasive enough to how to writing, create an unlawful hostile environment).  Burlington Indus., Inc. v. Essay Of Divorce! Ellerth , 524 U.S. 742, 762 (1998); Faragher , 524 U.S. at 788; Preferred Mgmt. Corp. Mcgraw Accounting Homework Answers! , 216 F. Supp. 2d at of divorce 839 n.25 (employer’s anti-harassment policy was inadequate because it did not include a prohibition on religious harassment, employer did not provide training on for psychology class religious harassment, and managers responded to complaints of religious harassment by essay requiring employees to participate in theoretical, 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 a tangible employment action if “the agent’s high rank in 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 of divorce organization’s proxy,” which would include officials such as a company president, owner, partner, or corporate officer, the outdoors essay 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 Unlawful Harassment by Supervisors (1999), https://www.eeoc.gov/policy/docs/harassment.html.  Sheikh , 2001 WL 1636504 at essay of divorce *5 (employer not liable because it took steps to stop alleged harassment of Muslim employee by his co-workers); see Guidelines on term paper for psychology class Discrimination Because of National Origin , 29 C.F.R. § 1606.8(d) (employer liable for co-worker harassment about which it knew or should have known and failed to act).  Cf. Powell v. Yellow Book USA, Inc. , 445 F.3d 1074 (8th Cir. 2006) (employer not liable for religious harassment of plaintiff because upon learning of her complaints about a co-worker’s proselytizing, the employer promptly held a meeting and essay of divorce told the co-worker to stop discussing religion matters with plaintiff, and there was evidence that the company continued to monitor the situation to ensure that the co-worker did not resume her proselytizing).  29 C.F.R. § 1606.8(e). Berry v. Delta Airlines, Inc. , 260 F.3d 803 (7th Cir.
2001) (employer not liable for alleged sexual harassment of 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 employee, and hill accounting answers asked that all contractors be required to view sexual harassment training video).  When asked whether they had discussed religion in essay, the workplace in Roman em, the past twenty-four hours, 48% of Americans answered yes. Essay! See George Gallup, Jr. How To Writing! Timothy Jones, The Next American Spirituality: Finding God in the Twenty-First Century , at 72 (Cook Communication Ministries 2000).  Employers are permitted to exercise their religion to the extent that such exercise does not infringe on their employees’ religious beliefs. Townley , 859 F.2d at 621 (“Where the religious practices of employers . . . and employees conflict, Title VII does not, and of divorce could not, require individual employers to abandon their religion. Rather, Title VII attempts to reach a mutual accommodation of the outdoors essay conflicting religious practices.”).  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 essay http://www.tanenbaum.org/research_1999.html ) (last visited July 2, 2008).
 See Examples 15, 18-19, 27-28, 49-50. For a further discussion of the circumstances under which reasonable accommodation of religious expression in 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.  Cf. Bodett v. CoxCom, Inc. , 366 F.3d 736 (9th Cir. For Psychology Class! 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 essay of divorce violations were motivated by the employee’s religious beliefs).  42 U.S.C. § 2000e(j); Commission Guidelines , 29 C.F.R. § 1605.2(b).  Compare Trans World Airlines, Inc. v. Hardison, 432 U.S. 63, 84 (1977) (interpreting Title VII “undue hardship” standard, with 42 U.S.C. Phonemic Script! § 12111(10)(A) (defining ADA “undue hardship” standard); see infra n.139.  Protos v. Volkswagen of Am., Inc., 797 F.2d 129, 136 (3d Cir.
1986) (“[t]his is . . Of Divorce! . Outdoors Essay! part of of divorce our ‘happy tradition’ of avoiding unnecessary clashes with the how to writing dictates of conscience”) (citation omitted).  See Seshadri v. 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 essay of divorce, whether he has a religion); Chrysler Corp. Essay Foreign Policy Theoretical! v. Mann , 561 F.2d 1282, 1285 (8th Cir. 1977) (observing that the plaintiff “did little to essay, acquaint Chrysler with his religion and outdoors essay its potential impact upon his ability to of divorce, perform his job”); s ee also Redmond , 574 F.2d at 902 (relying on Mann , concluding that “an employee who is disinterested in outdoors essay, informing his employer of his religious needs ‘may forego the right to have his beliefs accommodated by essay his employer’”).  See Heller , 8 F.3d at 1439 (employee’s request for leave to participate in religious conversion ceremony of Ancient Roman em his wife and children was sufficient to place employer on notice that this was pursuant to a religious practice or belief; an employer need have “only enough information about an employee's religious needs to permit the employer to understand the existence of 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 a religious accommodation, court held employer was on notice of the need for accommodation given that it reprimanded employee for engaging in known religious activities); Hellinger v. Eckerd Corp., 67 F. Supp. 2d 1359 (S.D. Fla. 1999) (although applicant did not himself inform employer about his religious conflict on his job application, employer had learned when he contacted applicant’s former supervisor for a reference that the applicant had refused to of divorce, sell condoms at prior job due to phonemic script, a religious objection, and was therefore on notice); cf. Wessling , 554 F. Supp. at 552 (employee’s request to essay of divorce, leave work early in order to outdoors essay, arrive early for a Christmas play at her church in order to decorate and receive children was insufficient to place her employer on essay of divorce notice of a religious practice; it was more in the nature of a social activity or family obligation that happened to essay foreign, be associated with the church).  Cary v. Carmichael, 908 F. Supp.
1334 (E.D. Essay! 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. Policy! Sept. 20, 2001) (employer not liable for essay, disciplining employee for tardiness where employee failed until after his discharge to american essay policy, explain that tardiness was because he attended a prayer service), aff’d on other grounds , 318 F.3d 130 (2d Cir. 2003).  Notwithstanding the different legal standards for essay of divorce, 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 equally applicable to outdoors essay, the obligation to offer a reasonable accommodation to an individual whose religious beliefs conflict with an employment requirement”); Elmenayer , 2001 WL 1152815, at *5 (same), aff’d on other grounds , 318 F.3d 130 ; Kenner v. Domtar Indus., Inc ., 2006 WL 662466 (W.D.
Ark. 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 essay of divorce, be an interactive process in phonemic script, which both the employer and essay of divorce employee participate”), aff’d , 287 F.3d 152 (3d Cir. 2002); cf. Mcgraw Hill Homework! 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 of divorce employee’s religion and the exigencies of the employer’s business’”) (quoting Brener v. Diagnostic Ctr. Hosp. , 671 F.2d 141, 145-46 (5th Cir. 1982)).  EEOC v. How To Writing! 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 its business”); EEOC v. Ithaca Indus., Inc. , 849 F.2d 116 (4th Cir. 1988) (employer’s failure to essay of divorce, attempt to accommodate violated Title VII).  Shelton v. Univ. of Ancient Roman em Med. Dentistry of N.J. , 223 F.3d 220, 227 (3d Cir. Of Divorce! 2000) (by refusing to meet with employer’s human resources department, employee failed to satisfy her duty to cooperate in finding a reasonable accommodation).  Ansonia Bd. of Educ. , 479 U.S. at Roman 69 (employer could satisfy its obligation by essay 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 for psychology showing that it suggested possible accommodations but that the essay of divorce employee short-circuited the process by how to writing 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 essay of divorce, its conciliatory efforts, he may forego the outdoors essay right to have his beliefs accommodated”), cert. denied , 434 U.S. 1039 (1978).  See also Bushouse , 164 F. Supp. 2d 1066.  Id. at 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 essay of divorce present case” and 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”).
 EEOC v. Tyson Foods, Inc ., Civil Action No. 99-5126 (W.D. Ark. consent decree entered Aug. 14, 2000) (settlement of Title VII challenge to employer’s policy of requiring a letter from a church in support of all accommodation requests).  See EEOC v. 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 mcgraw homework Educ ., 479 U.S. at 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. Of Divorce! N. Phonemic Script! 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 of divorce, her current position thirty days and the assistance of its in-house employment counselor to find another position where the conflict between the outdoors essay 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 essay five working days off or alternatively seven days off if employee worked one shift within that seven days, did not satisfy obligation to offer reasonable accommodation of her religious practice of Ancient em refraining from essay work during seven-day religious festival, where employer did not show undue hardship).  See infra nn.131-133. Under the Commission’s approach, a reasonable accommodation must eliminate the american essay conflict between work and religion unless such accommodation would impose an undue hardship, i.e. , more than de minimis cost or disruption on essay of divorce the employer’s business. Some courts have approached the issue of what is a reasonable accommodation in a manner that conflicts with longstanding Commission and judicial precedent. See, e.g., EEOC v. Firestone Fibers Textiles Co. , 515 F.3d 307 (4th Cir. 2008) (analyzing reasonableness of proposed accommodation based on facts typically considered as part of undue hardship analysis); Sturgill v. 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 determined as a matter of law without regard to the facts of an individual case, or that an for psychology employer is not permitted to choose among alternative accommodations, or that even accommodations which conflict with a CBA or otherwise pose an undue hardship must be granted). Essay Of Divorce! The Commission’s approach is more straightforward and more in keeping with the purpose of Title VII’s accommodation requirement. Concerns about phonemic script, 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 undue hardship.
Moreover, the employer need not grant an employee’s requested reasonable accommodation if the employer wishes instead to offer an alternative accommodation of its own choosing that also would eliminate the work-religion conflict and does not adversely affect the employee’s terms, conditions, or privileges of employment.  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 of divorce 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 american policy theoretical, other equally undesirable shifts and adopting a system of essay voluntary or mandatory shift trades, the employer had to accept one of the employee’s proposals unless doing so would create an Ancient Roman em undue hardship). This section addresses only of divorce, 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 undue hardship. Undue hardship is addressed below in § IV.B.  Ansonia Bd. of mcgraw accounting homework answers Educ. Of Divorce! , 479 U.S. at hill accounting answers 70-71 (“requiring [an employee] to take unpaid leave for 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 essay, not a reasonable accommodation when paid leave is provided for all purposes except religious ones . . . [s]uch an arrangement would display a discrimination against religious practices that is the how to writing 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 accommodation if it would not pose an undue hardship.  Commission Guidelines , 29 C.F.R. Of Divorce! § 1605.2(c)(2)(ii) (“when there is more than one means of phonemic script 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 of divorce limitation in the Commission’s guidelines that alternatives must be considered if they will not “disadvantage an individual’s employment opportunities” distinguished the Ancient Roman Commission’s position from the position of the Second Circuit that was rejected in Ansonia . 470 U.S. at 69 n.6. Appellate courts in the wake of Ansonia have, as the Commission’s guidelines instruct, evaluated whether employer accommodations had a negative impact on essay of divorce the individual’s employment opportunities. Homework Answers! See Cosme v. Henderson , 287 F.3d 152, 160 (2d Cir. 2002) (an accommodation might be unreasonable if it imposes a “significant work-related burden on essay of divorce 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 employee, “in order to accommodate his religious practices, had to accept a reduction in pay or some other loss of benefits”).  Smith v. Paper Class! Pyro Mining Co. Of Divorce! , 827 F.2d 1081, 1085 (6th Cir. Outdoors Essay! 1987) (quoting Redmond , 574 F.2d at 902-03).  Baker v. Home Depot , 445 F.3d 541 (2d Cir.
2006) (employer’s offer to schedule employee to of divorce, work in outdoors essay, the afternoon or evenings on Sundays, rather than the mornings, was not a “reasonable” accommodation under Title VII where employee’s religious views required not only attending Sunday church services but also refraining from work on Sundays).  Wilshin v. Allstate Ins. Co., 212 F. Supp. 2d 1360 (M.D. Ga. 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).  Shelton , 223 F.3d at 226 (state hospital’s offer to of divorce, transfer nurse to 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 accounting homework, 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 guard such facilities; Title VII did not compel employer to instead grant his preferred accommodation of of divorce remaining in his district but being relieved of such assignments); Wright , 2 F.3d at 217 (7th Cir. 1993) (employer reasonably accommodated employee by suggesting he exercise his rights under CBA to bid on hill homework answers jobs that would have eliminated the conflict between work and religion).  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 of divorce Chicago, 1996 WL 22964, at *3 (N.D. Ill. How To Writing! Jan. 12, 1996) (rejecting employer’s argument that a threat of adverse action is not enough to state a claim; “it is nonsensical to suggest that an 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 essay religious discrimination”).
Moreover, a denial of term class 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. Of Divorce! For example, if a Muslim employee is mcgraw hill accounting homework answers, transferred to non-customer service position because she refuses to stop wearing a religiously mandated headscarf, she states a claim for essay, denial of accommodation under Title VII. Draper v. U.S. Outdoors Essay! Pipe Foundry Co. , 527 F.2d 515 (6th Cir. 1975) (resorting to transfer where accommodation was possible in employee’s current position is actionable as denial of reasonable accommodation). However, an of divorce employer need not accommodate an how to writing employee who chooses to resign before notifying the employer of the need for essay of divorce, accommodation or fails to cooperate with the employer in the accommodation process. See, e.g., Goldmeier v. Allstate Ins. Co. , 337 F.3d 629 (6th Cir. 2003) (resignation 53 days prior to effective date of employer’s policy that would have posed conflict with employees’ religious beliefs did not constitute constructive discharge); Lawson v. 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 outdoors essay 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. Univ. of Med.
Dentistry of N.J. , 223 F.3d 220, 227 (3d Cir. Essay Of Divorce! 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).  Townley , 859 F.2d at 614 n.5 ; Rodriguez, 1996 WL 22964.  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 hill accounting a Friday night or Saturday; her “undisputed testimony was that her faith and commitment to her religion grew during this time”).  See, e.g., Hardison, 432 U.S. at 84. Essay Of Divorce! 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.”  Both the mcgraw answers statute, at 42 U.S.C. § 2000e(j), and the Commission Guidelines , at 29 C.F.R. § 1605.2(b), require an employer to reasonably accommodate an of divorce employee’s or applicant’s religious beliefs and practices “unless the employer demonstrates” that doing so would pose an undue hardship. Hill Homework! Even under the Fourth Circuit’s decision in EEOC v. Firestone , and of divorce 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 burden of persuasion. Firestone , 515 F.3d at 315; Sturgill , 512 F.3d at 1033 n.4.  Tooley v. Phonemic Script! Martin Marietta Corp. , 648 F.2d 1239, 1243 (9th Cir. 1981).
 Commission Guidelines , 29 C.F.R. § 1605.2(e).  Compare Cooper , 15 F.3d at 1380(employee’s request not to be scheduled for Saturday work due to Sabbath observance posed undue hardship for employer because it would have required hiring an additional worker), and of divorce Beadle v. Essay Policy! Tampa , 42 F.3d 633 (11th Cir. Essay! 1995) (requiring police department to em, alter training program schedule involving more than 900 employees to accommodate one employee’s religious needs amounts to more than de minimis cost and thus undue hardship), with Protos , 797 F.2d 129 (employee’s request not to be scheduled for 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).  See Brown v. Gen. 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 which [employee] was accommodated”); EEOC v. Alamo Rent-A-Car, LLC , 432 F. Of Divorce! Supp. 2d 1006 (D. Ariz. 2006) (employer incorrectly believed that if it allowed plaintiff to essay, wear her religious headscarf it could not enforce its uniform policy with respect to other employees, and failed to show undue hardship based on its fear that allowing the accommodation would open “the floodgates to others violating the uniform policy”).
 Tooley , 648 F.2d at 1243 (“undue hardship cannot be supported by merely conceivable or hypothetical hardships . . Essay! . . The magnitude as well as the fact of hardship must be determined by phonemic script ‘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. Essay Of Divorce! 1978)); EEOC v. Alamo Rent-A-Car, LLC , 432 F. Supp. 2d at 1016 (“‘hypothetical hardships’” based on assumptions or “pure speculation” about accommodations which have never been put into practice are insufficient to show undue hardship”).  Id. Compare EEOC and Electrolux Reach Voluntary Resolution in 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 religious request of 165 Somali workers who, pursuant to the tenets of the Islamic faith, must offer at 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. How To Writing! Oct. Of Divorce! 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 american foreign, their sunset prayers at the same time would result in an undue hardship because as a result of their absence, the line would have to essay, be shut down).  Commission Guidelines , 29 C.F.R. § 1605.2(e)(1). Policy! Under Title VII, for example, in 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. 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 pay two other workers overtime wages of approximately $220 each to fill in, where the essay of divorce facility routinely paid technicians overtime, the 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 paper for psychology, plaintiffs subsequently entered), appeal docketed , Case No.
08-1096 (8th Cir. Of Divorce! filed Jan. Class! 10, 2008); Brown v. Gen. Of Divorce! Motors Corp. , 601 F.2d at 959-60 (no more than de minimis cost imposed by allowing employee to leave work at mcgraw accounting 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 all times available to replace unscheduled absences of regular employees); Burns v. S. Of Divorce! Pac. Transp. Co. , 589 F.2d 403, 407 (9th Cir. 1978) (excusing employee from paying his monthly $19 union dues due to religious objection did not pose an how to writing 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 essay of divorce Local’s 300 members at outdoors essay a rate of 2 cents each per month; an accommodation that would only result in an increase of other union members dues in amount of essay of divorce 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. IBP, Inc. , 824 F. Ancient! Supp. 147 (C.D. Ill. 1993) (adopting EEOC’s interpretation in the Commission Guidelines that undue hardship means, with respect to costs for a substitute, “costs similar to the regular payment of 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 relation to the size and operating cost of the employer.’ 29 C.F.R. § 1605.2(e)(1)).”  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 essay issue).  Protos , 797 F.2d at how to writing 134-35; Brown v. Essay Of Divorce! 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).  “[A]n employer need not accommodate an employee’s religious beliefs if doing so would result in outdoors essay, discrimination against essay of divorce 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 harass co-workers, or the company deleting sexual orientation from its voluntarily adopted diversity and non-discrimination policy, would have posed an undue hardship on the employer); EEOC v. BJ Servs. Co. , 921 F. Supp. Outdoors Essay! 1509 (N.D. Essay! Tex. 1995) (employer was unable to accommodate employee’s religious request for how to writing, certain day off because no other employees were available to of divorce, 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 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 essay policy, this manner would have violated collective bargaining agreement).  BJ Servs. Co., 921 F. Supp. at of divorce 1509; Balint v. American Essay Policy Theoretical! 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 essay of divorce, assume plaintiff’s share of the phonemic script hazardous work)); Bruff 244 F.3d at 501 (requiring co-workers of plaintiff mental health counselor to assume disproportionate workload to accommodate plaintiff’s request not to counsel certain clients on essay religious grounds would constitute undue hardship).  See, e.g., Sutton v. Providence St.
Joseph Med. American Essay Foreign Policy! Ctr. , 192 F.3d 826 (9th Cir. Of Divorce! 1999) (employer not required to accommodate job applicant’s religiously based refusal to provide his social security number where employer sought it to comply with Internal Revenue Service and Immigration and american essay foreign policy theoretical Naturalization Service requirements). However, an employer should not assume that it would pose an undue hardship to 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 the government enforcement procedures of essay of divorce some safety requirements.
See, e.g. , U.S. Department of Labor, Occupational Safety and Ancient Roman em Health Administration STD 1-6.5 (“Exemption for Religious Reason from essay of divorce Wearing Hard Hats”) (June 20, 1994) (exempting employers from outdoors essay citations for of divorce, certain violations based on religious objection of american employee, but providing for various reporting requirements).  See EEOC v. Oak-Rite Mfg. Corp. , 2001 WL 1168156 (S.D. Essay Of Divorce! Ind. Aug. 21, 2001) (manufacturing employee’s proposed accommodation of accounting homework answers 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 essay of divorce employer by requiring it to experiment with employee safety, given the absence of evidence demonstrating safety of proposed accommodation in a comparable work setting); EEOC v. Term Paper Class! 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 required trousers, because her Pentecostal Christian beliefs precluded her from wearing pants); c f. Webb v. Of Divorce! City of essay foreign theoretical Philadelphia, 2007 WL 1866763 (E.D.
Pa. June 27, 2007) (undue hardship to essay, accommodate the 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 hierarchical nature of the police force, and how to writing portrays a sense of authority as well as public and religious neutrality to the public).  Hardison, 432 U.S. at 80; Stolley v. Lockheed Martin Aeronautics Co. , 2007 WL 1010418 (5th Cir. 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 essay of divorce 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 this case); see also Balint , 180 F.3d at 1054.  Balint, 180 F.3d at 1054; Killebrew v. Local Union 1683 of Am. Fed’n of State, County, Mun. Employees, AFL-CIO, 651 F. Supp. For Psychology! 95 (W.D. Ky. 1986) (union not required to negotiate a change in the CBA to allow an employee to essay, bump another employee to obtain an accommodation because bumping would have been detrimental to those bumped); see also Virts v. Consol. 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 how to writing, only male driving partners, where making assignments in essay of divorce, 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 employer to grant employee’s accommodation request not to be scheduled to work on Saturdays); Mann v. Phonemic Script! 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 of divorce, assign another worker to take plaintiff’s Saturday shift, which would have violated CBA’s provisions governing overtime).  Commission Guidelines , 29 C.F.R. § 1605.2(e)(2); Stolley , 2007 WL 1010418.  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 union contract prior to 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 additional costs; or his request to transfer with no loss of how to writing seniority, which would violate its CBA, where the employer had sought but could not obtain a waiver from the union).  See Wilson v. Of Divorce! 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 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 outdoors essay, productivity and some employees threatened to walk off their jobs).  Opuku-Boateng , 95 F.3d at 1473 (mere complaints by of divorce 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).
 Burns, 589 F.2d at 407 (“Undue hardship requires more than proof of some fellow-workers’ grumbling or unhappiness with a particular accommodation to phonemic script, a religious belief. An employer or union would have to show . . . actual imposition on co-workers or disruption of the 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 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 of divorce harass his co-workers; it also would have posed an undue hardship for employer to how to writing, eliminate a portion of its diversity program to which plaintiff had religious objections).  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 uniform and essay of divorce grooming requirements, and 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).
 For example, Title 18 U.S.C. Section 930 generally prohibits the possession of knives, including kirpans, with blades longer than 2.5 inches, in federal facilities, unless otherwise authorized.  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 Ancient Roman em hour laws may provide certain limitations that impact an employer’s potential flexibility.  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 undue hardship, because she was the only greeter in the department; the essay of divorce 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 the evidence the employer provided regarding the need for the position); Brener , 671 F.2d 141 (requiring hospital to hire a substitute pharmacist for days employee sought not to work due to religious observance involved more than a de minimis cost, and operating without him or having the pharmacy director substitute for phonemic script, him would have had an unacceptable adverse impact on functions of the pharmacy).  See U.S. v. Los Angeles County Metropolitan Transit Authority , Case No.
CV 04-07699 JFW (JTLx) (C.D. Of Divorce! Cal. consent decree filed Oct. 2005) (lawsuit filed by Civil Rights Division of the U.S. Department of term for psychology class Justice and essay of divorce resolved by foreign policy consent decree prior to ruling by court on merits; the settlement provided that the employer would accept the applications of 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 absence; and essay of divorce provide information about religious accommodation in marketing literature and in its training programs for supervisors).  EEOC v. Robert Bosch Corp. Term Paper! , 2006 WL 406296 (6th Cir.
Feb. 21, 2006) (unpublished) (in case involving request for shift swap and 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 swap shifts); Beadle v. Of Divorce! 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 essay foreign policy bulletin board and at employee meeting to seek out of divorce co-workers willing to swap); McGuire v. Gen. Motors Corp ., 956 F.2d 607 (6th Cir. 1992) (summary judgment for how to writing, employer reversed where genuine issue of essay 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 Roman em issuing a survey to employees regarding whether they would be willing to swap shifts in order to of divorce, accommodate plaintiff); see also Beadle v. 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. Term For Psychology! Mobile Infirmary Med. Ctr. , 2006 WL 1999133 (S.D. Ala. Essay Of Divorce! 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 arrange a shift swap with co-workers, and making available the schedules of other employees).  See, e.g., Pyro Mining Co. How To Writing! , 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. 2:06-cv-161 (E.D. Tenn.
April 16, 2008) (employer's proposal that employee find another qualified candidate to of divorce, take his Saturday shift was not a reasonable accommodation because the for psychology employer was on notice that the employee considers it a sin for 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 that it is a sin to of divorce, try to induce another to work in his stead, then an employer's attempt at accommodation that requires the how to writing employee to seek his own replacement is not reasonable ”) (emphasis in original) (citing Pyro Mining Co. , 827 F.2d at 1088).  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 essay of divorce, the hours at issue); EEOC v. How To Writing! Southwestern Bell Tel. LP, 2007 WL 2891379 (E.D. Ark. Oct. 3, 2007) (payment of essay of divorce 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 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).  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).  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).  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 how to writing, 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 uncompleted data work).
The reasonable accommodation that the employer was able to provide in Noesen might pose an essay of divorce 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 employer’s business.  Draper , 527 F.2d at 519-20 (transfer that involved substantial reduction in american essay policy theoretical, 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).  Commission Guidelines , 29 C.F.R. Essay! § 1605.2(d)(iii) (“When an employee cannot be accommodated either as to his or her entire job or an assignment within the job, employers and outdoors essay labor organizations should consider whether or not it is possible to of divorce, change the job assignment or give the employee a lateral transfer.”); Rivera v. Choice Courier , 2004 WL 1444852 (S.D.N.Y. June 25, 2004) (employer’s failure to outdoors essay, consider transferring employee to essay of divorce, 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).  See supra n.138; Rodriguez , 156 F.3d at 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. 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 Ancient Roman transfer to lower-paying non-counselor job could satisfy Title VII if plaintiff could not be accommodated in her current position or an equivalent position).  Shelton , 223 F.3d at essay 227 (offering transfer to nurse who had religious objection to abortion procedure sometimes performed in paper for psychology, her department was a reasonable accommodation); EEOC v. Dresser-Rand Co. , 2006 WL 1994792 (W.D.N.Y. Of Divorce! July 14, 2006) (summary judgment for employer denied in case on behalf of american essay theoretical a Jehovah’s Witness who allegedly was denied transfer to different assignment as an accommodation of essay of divorce his religious objection to working on hill accounting homework answers military projects). But cf. supra n.138 (discussing when a lateral transfer might be an adverse employment action). At least one court has ruled that it is essay, 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 how to writing, be assigned to essay, full-time, permanent work at a casino was unreasonable; police and phonemic script fire departments “need the cooperation of all members” and need them to perform their duties “without favoritism”), cert. Essay! denied , 541 U.S. 989 (2004). Because public protectors, such as police officers and firefighters, are obliged to american policy theoretical, serve and protect all under their care, and their public responsibilities must take precedence over their religious and other personal scruples, in some cases conflicts between the requirements of their job and essay of divorce their religious beliefs may not be able to be resolved. However, it is how to writing, not per se unreasonable for public protectors to obtain changes in essay of divorce, job assignments, schedule changes, or transfers in 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.  See, e.g., EEOC v. United Parcel Serv. , 94 F.3d 314 (7th Cir. 1996) (genuine issue of material fact regarding whether the employer reasonably accommodated the employee’s religious practice of wearing a beard precluded summary judgment for the employer); EEOC v. Comair, Inc. , Civil Action No. 1:05-cv-0601 (W.D. Outdoors Essay! Mich. Essay Of Divorce! consent decree filed Nov. 22, 2006) (settlement prior to ruling on merits of case on behalf of 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. Mcgraw Hill! Tenn. Essay Of Divorce! consent decree filed April 9, 2004) (settlement prior to phonemic script, 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 refusing to of divorce, shave in compliance with employer’s no-beard policy).  United Parcel Serv ., 94 F.3d at 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 department’s constitutional obligations, and therefore would pose an undue hardship under Title VII), cert. denied , 534 U.S. 951 (2001), with Draper v. American Essay Policy! Logan County Pub.
Library , 403 F. Supp. Of Divorce! 2d 608 (W.D. Ky. Em! 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).  See, e.g., Cloutier v. Costco Wholesale Corp. , 390 F.3d 126 (1st Cir.
2004) (holding that it would pose “an undue hardship to essay, require Costco to outdoors essay, 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 professional image” that it aims to cultivate).  Denying the essay of divorce employer’s motion for summary judgment in EEOC v. Red Robin Gourmet Burgers, Inc. , 2005 WL 2090677 (W.D. Wash. Paper Class! Aug. 29, 2005), the court ruled that notwithstanding the employer’s purported reliance on a company profile and essay of divorce customer study suggesting that it seeks to present a family-oriented and mcgraw homework answers kid-friendly image, the company failed to demonstrate that allowing an employee to have visible religious tattoos was inconsistent with these goals. “Hypothetical hardships based on unproven assumptions typically fail to constitute undue hardship . . . Of Divorce! . Red Robin must provide evidence of ‘actual imposition on co-workers or disruption of the work routine’ to demonstrate undue hardship.” S ee also Brown v. F.L. Roberts , 419 F. Supp. 2d 7, 17 (D. Mass. Phonemic Script! 2006) (district court held no Title VII violation occurred when employer transferred lube technician whose Rastafarian religious beliefs prohibited him from essay 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 follow Cloutier as the paper class law of the circuit, the court nevertheless observed in essay, dicta: “If Cloutier’s language approving employer prerogatives regarding ‘public image’ is mcgraw hill answers, read broadly, the implications for 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 essay, terminate or restrict from term paper class customer contact, on of divorce image grounds, an employee wearing a yarmulke, a veil, or the Roman em mark on the forehead that denotes Ash Wednesday for many Catholics. More likely, and more ominously, considerations of ‘public image’ might persuade an employer to tolerate the of divorce 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 Muslim employee who was terminated pursuant to restaurant appearance code requiring male employees to how to writing, be clean-shaven notwithstanding that employer’s written policy had exception permitting beards required for religious reasons).  See generally EEOC v. American Airlines , Civil Action No. Essay Of Divorce! 02-C-6172 (N.D. Ill.) (Order of Resolution filed September 3, 2002) (resolving claim on 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).  Webb v. Outdoors Essay! City of Philadelphia, 2007 WL 1866763 (E.D.
Pa. Essay Of Divorce! June 27, 2007) (granting summary judgment to the employer, the court ruled that the essay theoretical City of 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 essay of divorce a Muslim police officer while in american essay foreign policy theoretical, uniform, in essay of divorce, contravention of the department’s dress code directive).  See U.S. Phonemic Script! v. New York State Dep’t of Corr. Servs. , Civil Action No. 07-2243 (S.D.N.Y. settlement approved Jan. 18, 2008) (settlement of essay of divorce case brought on behalf of Muslim correctional officers by U.S. How To Writing! Department of Justice providing that employee requests for religious exemptions from uniform and grooming requirements of of divorce state prison system would be determined on a case-by-case basis, and allowing employees to wear religious skullcaps such as kufis or yarmulkes if close fitting and american foreign theoretical solid dark blue or black in color, provided no undue hardship was posed).  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 essay, use facilities for non-work related secular activities generally are required to allow the term for psychology privilege on equal terms for essay of divorce, employee religious activities).  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 foreign policy his religious objection to signing consent form for a drug test).  Minkus , 600 F.2d 80 (employer must demonstrate it would pose undue hardship to allow applicant to take exam at different time than others as a religious accommodation).  Sutton v. Providence St.
Joseph Med. Ctr. , 192 F.3d 826 (9th Cir. Of Divorce! 1999) (hospital not liable for refusing to hire applicant who declined to provide social security number on 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 undue hardship), aff’d , 101 F.3d 708 (11th Cir. 1996) (Table) (unpublished).  Commission Guidelines , 29 C.F.R. Phonemic Script! § 1605.2(d)(2); Tooley , 648 F.2d at 1242-44 (union cannot force an employer, under a contractual union security clause, to terminate three Seventh-day Adventists who offered to essay of divorce, pay an amount equivalent to dues to a nonreligious charity because the union failed to show that such an accommodation would deprive it of funds needed for its maintenance and term class operation); EEOC v. Essay! Univ. of Detroit , 904 F.2d 331 (6th Cir. 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. Boeing , 833 F.2d 165, 169 (9th Cir. 1987) (an employer may be required to phonemic script, accommodate an employee who has a sincerely held religious opposition to of divorce, unionism by outdoors essay allowing an of divorce equivalent contribution to Ancient em, a mutually agreeable charity in lieu of essay of divorce dues payment); Burns , 589 F.2d at 406-07 (allowing equivalent charitable contribution in outdoors essay, lieu of dues did not constitute undue hardship notwithstanding administrative cost to union and of divorce “grumblings” by other employees); Cooper v. General Dynamics, 533 F.2d 163 (5th Cir. 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. Mich.
Oct. Outdoors Essay! 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 essay requiring the employee to pay to essay foreign theoretical, a charity of his choice an amount equal to full union dues).  See McDaniel v. Essex Int’l, Inc. , 696 F.2d 34 (6th Cir. 1982) (finding employee’s proposal to donate amount equivalent to dues to a “mutually agreeable” charity was a reasonable accommodation that would not have posed an undue hardship) and EEOC v. Am. 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). Some CBAs have charities listed in essay, them, pursuant to the requirements of section 19 of the National Labor Relations Act. See 20 U.S.C. § 169.  Commission Guidelines, 29 C.F.R. § 1605.2(e); Nottelson v. Phonemic Script! 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 essay, union where loss of plaintiff’s dues represented only term paper for psychology class, .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 essay 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 how to writing all” and essay of divorce union’s asserted fear of many religious objectors was based on mere speculation; the Ancient em court noted, however, that if “in the future, the expressed fear of essay of divorce 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. Ass’n , 319 F. Supp. 2d 90 (D. Term Class! Mass.
2003) (not a reasonable accommodation to essay, 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). Phonemic Script! Cf. Madsen v. Essay Of Divorce! 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 pay full amount of how to writing dues to essay, charity where non-religious objectors were only paying agency fee to union).  See EEOC v. Univ. of Detroit , 904 F.2d at 335; see also U.S. v. Ohio and EEOC v. Em! Ohio Civil Service Employees Association , Case No. 2:05-CV-799 (S.D.
Ohio consent decree filed Sept. Of Divorce! 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 Ancient Roman court on merits, the consent decree provides that a state employee is permitted to pay an amount equal to the union service fee to essay, a mutually agreeable charity if he has sincerely held religious objections to supporting the union, even if he does not belong to such a church); Int’l Assoc. of Machinists , 833 F.2d 165, 169 (9th Cir. Phonemic Script! 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 of divorce employee who has a sincerely held religious opposition to unionism by allowing equivalent contribution to mutually agreeable charity in hill homework answers, lieu of dues payment, even if he “is not a member of an organized religious group that opposes unions”).  Wilson, 58 F.3d at 1341-42 (given disruption among co-workers actually caused in workplace, employee’s request to wear at essay all times a button containing a graphic photograph of term for psychology class 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 photograph portion when she left her work cubicle); cf . Red Robin Gourmet Burgers , 2005 WL 2090677 (denying employer’s motion for summary judgment because issue of whether employee’s Kemetic religious wrist tattoos would disrupt work or otherwise pose an undue hardship raised a disputed factual question to be decided by essay of divorce jury).  Wilson, 58 F.3d at 1341-42 (employer denied certain accommodation options because of demonstrated disruption to american essay foreign policy theoretical, 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 of divorce undue hardship because, although the employer asserted that the supervisor’s conduct had polarized employees along religious lines, it adduced no supporting evidence).
 EEOC Enforcement Guidance: Vicarious Employer Liability for Unlawful Harassment by Ancient Supervisors (1999), https://www.eeoc.gov/policy/docs/harassment.html.  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 use the of divorce phrase with co-workers and supervisors who did not object, but prohibited her from outdoors essay using the essay phrase with customers where at least one regular client objected; allowing her to use the how to writing phrase with customers who objected would have posed an undue hardship); Banks v. Serv. Am. Of Divorce! 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 hill accounting homework answers “Praise the Lord,” presented a triable issue of fact regarding whether they could have been accommodated without undue hardship; in 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 .01923%; and the employer produced no evidence of decreased use of the cafeteria or religious polarization among customers).
 See infra nn.201-203; see also Johnson v. Halls Merch. Essay Of Divorce! , 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 paper beliefs of some customers and therefore cost the company business).  See Knight , 275 F.3d at 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 essay would have violated the First Amendment Establishment Clause, to permit chaplain to remain employed given his intention to minister to patients), with Rivera v. Choice Courier Sys., Inc., 2004 WL 1444852 (S.D.N.Y. June 25, 2004) (genuine issue of material fact existed as to 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”).  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 phonemic script private employer involuntarily to 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 essay First Amendment Establishment Clause would likely justify its refusal to display a religious message. Essay Policy! 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 essay of divorce 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 paper Social Servs. , 447 F.3d 642 (9th Cir. 2006) (accommodating social worker’s request to display religious items in of divorce, 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. How To Writing! Capistrano Unified Sch. Of Divorce! Dist. , 37 F.3d 517 (9th Cir.
1994) (school district’s restriction on teacher’s First Amendment right of free speech in prohibiting teacher from talking with students about religion during school day was justified by how to writing school district’s interest in avoiding Establishment Clause violation); Draper v. Logan County Pub. Library , 403 F. Essay Of Divorce! Supp. 2d 608 (W.D. Ky. 2005) (public library’s decision to bar employee from wearing necklace with cross was not justified by library’s purported interest in american policy, 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 be hung from the rafters”).  Knight , 275 F.3d 156; Grant v. Fairview Hosp. Healthcare Serv., 2004 WL 326694 (D. Of Divorce! Minn. 2004) (ultrasound technician was offered a reasonable accommodation of his religious beliefs when hospital excused him from how to writing performing ultrasounds on women contemplating abortions; hospital did not have to allow technician to of divorce, provide pastoral counseling, as that accommodation would have posed an term paper for psychology undue hardship); see also Grossman v. Of Divorce! South Shore Pub.
Sch. Dist. , 507 F.3d 1097 (7th Cir. 2007) (affirming summary judgment for school district on terminated guidance counselor’s First Amendment free exercise and paper Title VII claims, the court ruled that the school district was permitted to of divorce, terminate counselor for her conduct, even if her actions of phonemic script praying with students who approached her for essay of divorce, guidance and throwing away school contraceptive education materials were motivated by for psychology class her religious beliefs; there was insufficient evidence that her termination was based on her religious views alone as opposed to these actions, which the essay school district was entitled to prohibit).  See Townley, 859 F.2d at 619-21 (private employer has First Amendment free exercise right to express its religion in the workplace).  Young , 509 F.2d 140; see, e.g., EEOC v. Phonemic Script! Native Angels Homecare Agency , Civil Action No. 7:06-cv-83 (E.D.N.C. Essay! consent decree filed March 22, 2007) (settlement prior to decision by court on 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 refused to attend).  Townley, 859 F.2d at 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 avoid religious discrimination in violation of Title VII).  Young , 509 F.2d 140 (employee was constructively discharged based on her religion in violation of 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).  Although it is paper for psychology, beyond the scope of essay 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 First Amendment. See County of Allegheny v. Phonemic Script! ACLU , 492 U.S.
573 (1989) (stand-alone crèche on county courthouse steps violated establishment clause, but display elsewhere of Christmas tree next to essay of divorce, a menorah and a sign proclaiming “liberty” did not); Lynch v. Donnelly , 465 U.S. 668 (1984) (holding that government-sponsored display of crèche did not violate establishment clause because it was surrounded by various secularizing symbols, thus precluding a perception of foreign policy government endorsement of religion); Federal Workplace Guidelines , supra n.11 at Section D (example (b)). Essay! 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. How To Writing! West , 2000 WL 1459981 (S.D.N.Y. Oct. 2, 2000). In the private sector, establishment clause constraints would not apply. Of Divorce! As a best practice, however, all employers may find that sensitivity to hill accounting homework answers, the diversity of essay of divorce their workplace promotes positive employee relations.  An employer may accommodate the employee’s religious belief by hill homework answers substituting an essay alternative technique or method that does not conflict with the employee’s religious belief or by excusing the employee from mcgraw accounting answers that part of the essay of divorce training program that poses a conflict, if doing so would not pose an undue hardship.
 Many employers have policies that require employees to treat each other with “courtesy, dignity and how to writing respect.” This terminology fits within the ambit of “professionally” as used in the example. See also Peterson v. Hewlett-Packard Co. , 358 F.3d 599 (9th Cir. 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 of divorce, do so would have “infringed upon the company’s right to promote diversity and encourage tolerance and good will among its workforce”). Outdoors Essay! If training conflicts with an employee’s religious beliefs, the content of the training materials may be determinative in deciding whether it would pose an essay undue hardship to accommodate an paper for psychology class employee by excusing him from the training or a portion thereof. If the training required or encouraged employees to essay of divorce, value certain lifestyles or dimensions of diversity, it might be more difficult for an employer to establish that it would pose an undue hardship to how to writing, accommodate an essay of divorce 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 mcgraw accounting homework answers instruct employees to treat co-workers with respect in essay, accordance with corporate diversity policy, but violation of Roman em Title VII occurred where company did not accommodate employee’s refusal on religious grounds to sign diversity policy asking him to of divorce, “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).  Commission Guidelines , 29 C.F.R. Phonemic Script! § 1605.2.  EEOC v. WCM Enter., Inc. Essay! , 496 F.3d 393 (5th Cir.
2007) (evidence was sufficient for employee to proceed to term paper class, trial on claim that he was subjected to hostile work environment harassment based on both religion and essay national origin where harassment motivated both by american essay theoretical his being a practicing Muslim and by having been born in India); Vitug v. Multistate Tax Comm’n , 88 F.3d 506, 515 (7th Cir. Of Divorce! 1996) (Catholic Filipino employee made out a prima facie case of accounting answers national origin and religious discrimination, although he did not prevail on essay the merits).