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A Sociological Analysis of the Movie Crash Justin Aptaker graduated from the University of high school graduation day Tennessee with a major in psychology and a minor in comparative religious studies. Crash , a 2005 film by director Paul Haggis, begins by denise levertov, saying, It's the sense of touch . . .we miss . . . so much that we crash into each other just so we can feel something. The use of the word touch suggests human connection. High Day? Feel conjures a sense of emotion. We want to be moved by one another; to feel our common human existence. Our search for this sort of literary analysis essays human connection persists despite many peripheral issues which divide us, but it is the search itself, not the high school graduation day, issues, which provides the movie's main theme. I will explore this theme from the perspective of sociology, by examining how the denise levertov essay, movie deals with race and gender issues. Social Constructs vs. Inborn Characteristics. Essay About High School Day? Race and gender are not physical attributes.
They are social constructions. The movie portrays the district attorney of L.A., struggling to salvage his public image among black voters via finding an African American whom he can reward publicly. He considers a certain black firefighter who had recently performed his job heroically, but someone mentions that the firefighter is actually Iraqi. The D.A. responds, He's Iraqi? Well, he looks black. Do My Math For Me? This scene illustrates clearly that racial categories are created and employed by people, although these categories often say little about essay about high school graduation, a person's actual cultural or national heritage. In another scene, a detective refers to his lover as Mexican. She responds, My father's from Puerto Rico, my mother's from El Salvador.
Neither one of those is Mexico. Crash also beautifully illustrates how rigid gender roles can hinder connection between people. Good Engines? The traditionally male roles of provider and protector are especially examined. Essay About High School Graduation Day? In one scene, a black film director named Cameron is pulled over by a racist police officer named John Ryan. Cameron's wife is with him, and special essay soon begins antagonizing the officer and refusing to comply, even at Cameron's repeated request. About Graduation Day? So they are checked for math, weapons.
When Cameron responds without aggression as John frisks his wife in a sexually suggestive way, she perceives him as failing to protect her. She later accuses him of essay high school graduation day allowing her humiliation so the comparative essays, people he works with wouldn't read about [him in graduation the paper] . . . and realize that . . My Sisters Keeper? . he's actually black. In a scene at the film studio where Cameron directs, this does seem to high school graduation day be a fear of his, as he quietly agrees to analysis make a scene more racially stereotypical. So perhaps fear of essay school job loss did factor into his failure in keeper his protector role. However, if Cameron had become unemployed due to losing his public reputation, he'd eventually fail in his provider role. So he is torn between two equally demanding roles, and this role strain is precipitated by the racial discrimination he encounters. A rift results between him and his wife.
She is hurt that he didn't protect her somehow. He is essay about school graduation, angry about her initial hostility towards the police officer, which he perceived as reckless. Then after her recklessness caused them trouble, she wounds his pride by levertov essay line, making him feel inadequate. Their marriage seems in school graduation danger of falling apart. Crash shows that we should reanalyze the distinctions between male traits, such as decisiveness and aggression, and female traits, like submissiveness, non-aggression, and intuition. According To The Davis Thesis? The movie portrays a Persian American shop owner who buys a handgun to protect his wife and his daughter, Dorri. High School Graduation? Dori's intuition gives her a bad feeling about this. According To The Thesis? Since her father has a limited grasp of English, she purchases a box of ammunition labeled Blanks for the new gun. After the family's shop is vandalized and destroyed, threatening his means of providing for about school day, his family, he pursues a locksmith whom he mistakenly holds responsible for comparative literary, the situation.
He holds the locksmith at gun-point, demanding money for compensation. The locksmith's little girl, who is wearing an essay about graduation day, imaginary impenetrable cloak her father had given her, throws herself in front of the gun. The gun goes off, pointed at the girl, but she is unharmed. Tragedy has been averted because Dorri circumvented her father's wishes by getting blanks for ammunition. Her behavior represents traits of action and decisiveness, rather than passivity or submission. However, her behavior also shows traits of intuition and special non-aggression.
This illustrates that people must utilize traits for their situational appropriateness, negating the very idea of gender appropriateness. This negation of gender is shown by the symbolic qualities which, in this scene, prevent the tragedy: non-penetration and impenetrability. Penetrating and being penetrated form the most basic symbolism of about high male and female roles. Bullets are made for the sole purpose of penetrating, unless they are blanks. That impenetrability is represented by according to the moore thesis, an impenetrable cloak needs no further explanation.
Symbolically, the locksmith's little girl became the protector of about school graduation both her father--she tells him, I'll protect you--and her father's assailant, who later says, She came to protect me. This symbolism reveals more than just a reversal of gender roles. The girl's imaginary cloak is literary analysis, impenetrable, which indicates the best possible defense. The cloak represents faith, as it operates solely by about graduation, the girl's belief in it. It also symbolizes hope, since her father could only hope that nothing would harm her in spite of her faith. Also, the men were protected by the girl's loving self-sacrifice: she threw her very self into the line of fire. Since she protected both men, the symbolic mechanisms of her protective act represent forces that shield against moore thesis both our ability to destroy others and our ability to be destroyed by others. Since her protection was symbolic, not physical, the mechanisms protect against psychological/spiritual damage, not physical harm. Essay About High Day? So faith, hope, and self-sacrifice must be present if we are to avoid the mutual damage of crash-like interactions, and instead find human connection. It is possible to examine faith, hope, and self-sacrifice without resorting to a religious perspective. Faith can be simply believing that an unseen goodness exists within people, even behind destructive behaviors.
Officer John Ryan's racism is literary, intertwined with a deep capacity for about graduation, compassion. His love for his sickly old father results in self-sacrificing efforts to help him, but his grief over search for research, his father's misfortunes misleads him to find a scapegoat to blame (black people). Perhaps otherwise, such suffering would have simply seemed too senseless for John. Essay About Day? Hope is a willingness to wait for our faith to be outwardly justified, that is, for math for me, the unseen goodness within people to essay about high day manifest in their behavior. My Sisters Essays? John's compassion, which had never really left him, manifests when he refuses to leave Cameron's wife trapped in a burning car until he has saved her. He had humiliated her earlier, but in her dire need, he finally recognized her as a fellow human being. And looking at John Ryan after he risked his life to about high graduation save hers, Cameron's wife couldn't help but have the same recognition. Comparative Analysis Essays? Self-sacrifice made the essay high, way for their connection. Facing Our Shadow and Finding the levertov line, Light. School Graduation? Cameron, tired of feeling spineless, almost dies when he violently threatens a group of police officers. Good For Research Papers? This reckless action ends up doing more than soothing his wounded pride, however.
He can no longer pass judgment on his wife for her capacity to behave recklessly, but must forgive her, because he's discovered his own capacity to behave even more recklessly. Additionally, the common trigger for both his and his wife's recklessness--they share the predicament of about high school graduation day living as a racial minority--shows him that he and his wife are in this together. They must act as comrades, not enemies. So any fault or evil that we notice in another is likely to lead us to our common ground, but only denise essay if we are willing to fully face the corresponding shadows within our own nature. Facing the darkness within also puts us on guard against its potential for harm. In the film, a white police officer repeatedly takes a stand against essay graduation day racism. However, in comparative essays one of the last scenes, he gives a black hitchhiker a ride while off-duty.
While his passenger makes friendly conversation about country music and ice-skating, this strongly anti-racist police officer simply doesn't believe anything he says. He can't picture a hitchhiking black man being interested in those things. He misreads his passenger as being antagonistic. When the black man reaches into high graduation, his pocket, the rookie officer feels threatened and quickly shoots him, killing him. If even someone so genuinely appalled by racism can fail so tragically to connect with another person due to special education race differences, it is clear that everyone has at least some tendencies toward racial prejudice. The anti-racist policeman who killed the black hitchhiker might have acted differently if he had ever acknowledged and worked on the prejudice buried deeply in the shadow of his personality. But in accord with the eerily prophetic words of John Ryan, he had no idea who he really was. Essay About High? So the literary analysis essays, dark side of about high school day human nature may either destroy us or lead us to mutual understanding and forgiveness of others. The dark side of life, similarly, may be either a cause for utter despair or the holy ground on which we hold all things common. Regardless of our social class or physical characteristics, we all suffer feelings of helplessness, loneliness, alienation, and fear. Do My Math For Me? We all must endure pain, sadness, uncertainty, loss, and about high day death.
It is these things that we most loathe which form the soil where we might grow the my sisters keeper, human connections that we so desperately need. In this soil, beautiful connections can grow quickly between people who otherwise would spend a lifetime only crashing destructively into each other. An example already given was John Ryan and Cameron's wife, who were enemies until he saw her visited by terror, pain, and imminent death, and felt the kinship that can only be felt by another being who shares the knowledge of those terrible things. And in about school graduation the few seconds between the moment the gun goes off in moore thesis the Persian American shop owner's hand and about high graduation day the moment the locksmith realizes his little girl is not hurt, the locksmith is good for research, transformed before the essay about day, shop owner's eyes. Where he once saw just a thing that creates trouble, he now sees a reflection of himself. In those seconds, the helpless girl clutched by her father becomes his own daughter, Dori.
The howls and sobs coming from the essay, locksmith echo in the shop owners very core, where he feels the essay school graduation day, gravity of such loss and comparative analysis grief. The locksmith, like him, fears nothing more than that harm or death should touch his daughter. Simultaneously, the shop owner sees his own potential for essay about school graduation, evil, a darkness so black that the sight of it makes his mind reel. Dazed, he stares at the loathsome thing in his hand, as if wondering how it got there. Seeing that the little girl is unharmed, he stumbles toward his car. Life will be wonderfully different. by Daniela Frendo 1. Literary Analysis? James Cameron's Blade Runner: Strange Days (1995) Movie Review. About High Day? 13 Twisted Movies Like Shutter Island You Must Watch. by Rahul Parashar 19.
12 Thrilling Movies With Big Twists Like Gone Girl by Rahul Parashar 3. 12 Mind-Bending Movies Like Inception by Rahul Parashar 28. you very briefly touched on the racial tensions displayed throughout the movie, which was the main premise behind the movie. Regarding your analysis on my sisters essays, the scene where Cameron and Christine are pulled over by the cops, I feel that you unjustly described the situation. Christine was not, as you say, antagonizing the officers. Essay About School? She was antagonized by the police and unjustly pulled over.
Cameron and Christine are put into comparative, this situation because they are black, and they are being antagonized by the police. About Day? Also you say that Officer Ryan frisks [Christine] in a sexually suggestive way. No. He molested her and he sexually assaults her. Please don't normalize his actions by not calling it what it is.
You invalidate women's experiences in do my math the process. Harry F Banks 15 months ago. Dorri did not know the gun shop owner sold her blanks. At that point she was more interested in leaving the about high school day, shop, especially because of his sexual hints relative to size, etc., and getting to her father. She was just as much in the dark at purchasing the keeper essays, gun and bullets as her father was. I suggest you give the film another viewing. Did this person openly admit to about high graduation plagiarizing this. ^ This is brilliant.
I submitted this for my sociology assignment and analysis got a B+ . Your analysis is beautiful. I hope one day I can write with as much confidence as you wrote here. Loved it. I got an A in essay about high school graduation day my exam because of moore this. Essay Graduation Day? Thank you. Love your analysis (and the movie)! Dorri knew they were blanks and also knew her father couldn't read English on the box nor would he have knowledge of what a blank was if he could. thanks a lot for this valuable info, your the best god bless. Just my take, I think Dori knew they were blanks.
She is a Pathologist that works with people who die from gun wounds everyday. It seems natural she is worried about her father, who can be aggressive, having a gun in his possession. When she sees the store was vandalized, the first thing she thought of was the literary analysis essays, gun because it's registered to essay school her father. At the end when she's putting them in grad school essay her purse, she glances over at her father as if she's trying to hide the box of ammo from him so that he doesn't see that they are actually blanks. It's a debatable topic, but given all the about high school day, subtle hints it seems to me that she knew from the beginning. Justin Aptaker 5 years ago from United States. Thank you, Jools!
Jools99 5 years ago from North-East UK. Excellent, interesting hub. Do My Math For Me? Your level of analysis is admirable, it must have taken you a long time to about school graduation day get this all down on the page, well done. Crash is one of my favourite films and it is good search engines papers, certainly a film which is meant to make you think - yes, entertaining but it has a stronger meanings and Haggis manages to essay about graduation day make his points but also keep the story rattling along at good engines for research papers a strong pace. Voted up. Fantastic! Thanks so much! Really helped with a paper I am writing for class.
New 2011 Mom 6 years ago from Pennsylvania, USA. Honestly this has helped me a lot with trying to analyze a movie in a sociological way for a class. Justin Aptaker 6 years ago from United States. Thank you, Twilight Lawns! I'm glad you liked it.
I'll have to look at that part where Dori buys the ammunition again. I wonder. Twilight Lawns 6 years ago from Norbury-sur-Mer, Surrey, England. U.K. What a brilliant analysis. School Graduation? I just love the way you attacked this subject. 'Crash' is a movie I have seen many times. I bought it and watched it and then watched it again and comparative literary analysis essays again because it's an Oh so that's what that's about movie. I can't say that I agree with your complete interpretation, but that has nothing to essay high graduation day do with my complete admiration of your writing skills. My only objection (if that is not too harsh a word) is that I feel that Tragedy has been averted because Dorri circumvented her father's wishes by getting blanks for ammunition.
I don't think it was a deliberate act one her behalf; there was a lot of line anger and frustration in the gun shop at that time, and I think that she picked up the blanks now knowing what they were. He actually points to them on the shelf and graduation superciliously says something like, So these are the ones you want? My interpretation, I admit, but thank you again. Comparative Analysis? Copyright 2017 HubPages Inc. and 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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All rights reserved. Resume Rabbit is a trademark of eDirect Publishing, Inc. Contents are protected by international copyright laws. Essay About High School. Unauthorized copying or duplication in search engines, any form is strictly prohibited without prior written consent. This page outlines the about school Terms of levertov essay Service (hereafter the Agreement) under which the Services provided by essay about high school graduation, eDirect Publishing, Inc. in association with Resume Rabbit (hereafter the Services) and literary analysis essays the Resume Rabbit Resume Promotion Web Site (hereafter the Site) are provided to you. Please read this page carefully. By using the essay Site and/or paying for denise essay the Services, you are indicating your acceptance to high graduation, be bound by this Agreement. If you're unwilling to be bound this Agreement, do not use this Site or pay for levertov line Services. For purposes of this Agreement, the about school term Resume Rabbit shall include eDirect Publishing Inc., their officers, agents, vendors, employees and affiliates. Please note that Resume Rabbit may revise the Agreement at any time by denise levertov essay, updating this posting. Day. You should visit this page periodically to review the Agreement, as it is binding upon good you.
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The Site and its Services are intended solely for individuals seeking employment. The Site may be used only for lawful purposes within this stated context of about graduation Resume Rabbit's intended and acceptable use. Resume Rabbit holds the sole and according moore exclusive right to interpret the meaning and definition of acceptable use. As one of the essay about high graduation conditions of your use of the Site and Service, you represent, warrant and analysis essays agree that you will not use (or plan, encourage or help others to about high graduation day, use) the good engines for research papers Site for any purpose or in any manner that is prohibited by this Agreement or by applicable law. It is your responsibility to ensure that your use of the high day Site complies with This Agreement. Users are prohibited from violating or attempting to violate the math for me security of the Site, including, without limitation: accessing data not intended for such user or logging into essay high a server or account which the user is not authorized to search for research, access; attempting to essay about graduation, probe, scan or test the vulnerability of a system or network or to breach security or authentication measures without proper authorization; attempting to my sisters keeper essays, interfere with service to essay about high graduation, any user, host or network, including, without limitation, via means of submitting a virus to special education grad school essay, the Site, overloading, flooding, mail bombing or crashing; sending unsolicited e-mail, including promotions and/or advertising of products or services; forging any TCP/IP packet header or any part of the graduation header information in any e-mail or newsgroup posting. Use of any device, software or routine to levertov essay, interfere or attempt to interfere with the about day proper working of the Site or services of to the davis moore thesis Resume Rabbit, or taking any action which imposes an unreasonable or disproportionately large load on the Site's infrastructure or the infrastructure of Resume Rabbit is expressly prohibited. Violations of these Security Rules may result in civil or criminal liability.
Resume Rabbit will investigate occurrences that may involve such violations and may involve, and cooperate with, law enforcement authorities in prosecuting users who are involved in essay about high school graduation day, such violations. You are responsible for maintaining the keeper essays confidentiality of your information, username and essay graduation password. You shall be responsible for all uses of your registration, whether or not authorized by you. You agree to immediately notify Resume Rabbit of any unauthorized use of your registration, information, username or password. By using the education grad essay Site and Service you acknowledge that you have pro-actively hired Resume Rabbit to act on your behalf, as your Agent (hereafter Agency Relationship), to create accounts and post your Personal Information on the Career Sites and about high school graduation web portals, subject to the terms, conditions, rules and regulations governing the services provided by each of analysis essays these sites. You hereby further convey to about school, Resume Rabbit power of attorney to sign on your behalf (whether on paper or digitally) specifically indicating to each of these Career Sites that you have read, understood and agree to abide by their terms, conditions, rules and regulations. Click here to review the current list of Career Sites Resume Rabbit posts to, and to access links where their terms of service may be found. You additionally acknowledge your understanding that Resume Rabbit has standardized its web based information gathering forms (hereafter Forms) in order to comparative literary essays, make easy the re-posting of your Personal Information on high school day, the various web forms and in the various formats required by the various Career Sites. With this understanding you further authorize Resume Rabbit to make its best efforts to interpret some of your answers to questions provided on do my for me, the Forms in order to re-post whatever information Resume Rabbit believes, in essay, its sole discretion, are substantially similar answers amongst the available choices on the various Career Sites. By entering into this Agreement you're accepting full and total responsibility for levertov essay the actions Resume Rabbit performs on essay school graduation, your behalf and at for me, your request, as if you had performed those actions yourself. About Graduation. Your further acknowledge and agree that you will take full responsibility and are personally liable for according any consequences arising from the use of the Site and Services and from this Agreement.
Once your resume has been posted, Resume Rabbit will provide you access to essay about, a Resume Posting Service Center where you can access your Real-Time Posting Report and your web-based Job Mail. This access is available for math one year from the date you sign up with the service. Once the year has expired you will no longer be able to view your Real-Time Posting Report or your Job Mail. If you select Keep My Identity Confidential during an Online Order Interaction with Resume Rabbit, Resume Rabbit will select the confidentiality option on the Career Sites offering that feature. For sites that do not offer a confidentiality feature, Resume Rabbit will replace your personally identifiable information as follows: First Name Last Name are replaced with Confidential User Street Address is replaced with Address Withheld Phone Number is about school graduation day replaced with A/C-555-1212 Most Recent Company is replaced with Confidential. Additionally, it is recommended you remove all unwanted personal information from the moore cut and about paste version of your resume and cover letter, as these will be posted exactly as you provide them via the Forms. Job Agents are automated search engines at Career Sites that search for job openings matching criteria given them and then email leads of matching jobs to the email address provided to according, the Career Site. For Non-Paid Customers. Resume Rabbit may set up Job Agents, also known as Job Alerts, as a courtesy to customers who create accounts on Resume Rabbit but do not pay for Resume Posting Services.
These Job Agents can be edited, modified or deleted at essay about school graduation day, any time. For Paid Customers. Resume Rabbit has selected some Career Sites with Job Agent services and math for me has set up Job Agents to essay about day, automatically be part of the do my math Resume Posting Service. Resume Rabbit does not setup Job Agents at every Career Site that has Job Agents or related services. Resume Rabbit uses its best efforts to match the high school graduation information given us via its Forms to make sure that the Job Agents setup match the type of position(s) desired. Resume Rabbit makes no guarantees that the Job Agents setup will match job leads you desire.
This is where you'll go to pick up job opportunities and other Managed Email. The Job Mail email service helps keep your job related email in one place and separate from your personal email box. The Job Mail web interface allows you to keeper, read, write, reply and organize your job related email messages online. Essay About Graduation Day. It has an online calendar for scheduling interviews and a simple address book to store job opportunity contacts. Special Grad. To access Job Mail, simply log into the Service Center and click on the Job Mail link. Emails sent to your Managed Email Address will automatically go through our Spam Filtering servers before being delivered to your Job Mail Inbox. While no Spam filtering technique is 100% foolproof, our service should eliminate most non job-search related email. This keeps the essay about school graduation day email address you provide during registration private, secure and keeper essays eliminates Spam that would have otherwise been sent to essay about high graduation, you. Privacy of Your Communications. Resume Rabbit considers email transmitted via the Managed Email Services to be the private correspondence of the sender and literary essays recipient. Graduation. Resume Rabbit generally will not monitor, review or disclose the contents of your Managed Email correspondence, except: (a) as required by law; (b) if necessary to enforce this Agreement; (c) to respond to claims that such contents violate the rights of third parties; (d) as necessary for levertov the maintenance, monitoring and quality assurance of the operations of the Site or Services; or (e) to protect the rights, or property of Resume Rabbit, its third party service providers, or others.
Limitations on Use of essay about graduation day Email Services. Managed Email and related Services are made available to you for math your personal use only and about high graduation day solely for the purpose of search engines papers facilitating job search related correspondence resulting from the use of the Resume Rabbit Resume Promotion Services. You hereby agree not to use Managed Email and related Services for any other communications or emailing activities other than as outlined herein. You agree: (a) not to essay about high school, use the Services for illegal purposes; (b) not to interfere with or disrupt the Services or servers or networks connected to the Services; (c) to comply with all requirements, procedures, policies, and regulations of networks connected to levertov line, the Services; and high (e) to essay line, comply with all applicable laws regarding the transmission of technical data exported from the about high school day United States. You further agree not to upload, post, email, or otherwise transmit through the Services: (a) any unlawful, harassing, libelous, privacy invading, abusive, threatening, harmful, vulgar, obscene, indecent, tortuous, or otherwise objectionable material of any kind; (b) any material that violates the according thesis rights of essay high school graduation day another, including, but not limited to, the intellectual property rights of my sisters another; (c) any material that violates any applicable local, state, national, or international law or regulation; or (d) unsolicited or unauthorized advertisements, promotional materials, junk mail, spam, chain letters, or other forms of solicitation. (e) any material that contains software viruses or any other computer code, files or programs designed to essay about day, interrupt, destroy or limit the functionality of any computer software or hardware or telecommunications equipment; General Email Services Provisions.
Please be advised that there is a risk involved whenever downloading email and/or associated attachments to your computer. Resume Rabbit Email Services may not be able to according to the moore thesis, detect or repair viruses, or control or foresee any potential damages of high graduation day using this Service. Resume Rabbit assumes no responsibility for the deletion or failure to search papers, store, deliver or deliver in a timely manner email messages. Additionally, Resume Rabbit, in its sole discretion, and essay day without prior notice may place limits on the amount of email a user may send, receive and/or store on or through its servers within in special grad school, any period of high time for according davis any reason whatsoever. Any notice provided by Resume Rabbit to you in connection with such limit(s) shall not create any obligation to provide future notification regarding any change(s) to such limit(s). Resume Rabbit additionally retains the high graduation right to deactivate any Managed Email Address account or related service, with or without prior notice, for any reason without any liability whatsoever and you hereby release Resume Rabbit from any such liability. You acknowledge that Resume Rabbit makes no guarantees or warrantees of any kind related to Resume Rabbit Email Services, and that your election to utilize this Service is completely at your own risk. Resume Rabbit shall not accept any responsibility whatsoever or be held liable for any damages caused by your decision to use these services. You further acknowledge and agree that you are solely responsible for all acts or omissions that occur under your Resume Rabbit account or password, including the content of your transmissions through Job Mail and related Services, and that Resume Rabbit may recover damages from you if you violate any of the education school essay terms of this Agreement. By using the Services you agree to defend, indemnify and hold harmless Resume Rabbit from and against school day any claims, actions or demands, including without limitation reasonable legal and literary essays accounting fees, alleging or resulting from this Agreement, your breach of this Agreement, your use of the Site and Services, the about school day provision by you of do my any Content to the Site or other Career Sites, or the about school Agency Relationship.
Resume Rabbit shall provide notice to you promptly of good engines for research any such claim, suit, or proceeding and shall assist you at your expense in their defense. You further agree to release Resume Rabbit from any claims, demands and damages (actual, consequential, direct and indirect) of every kind and nature, known and about graduation day unknown, suspected and unsuspected, disclosed and to the thesis undisclosed, arising out of or in any way connected with this Agreement or the Agency Relationship. If you are a California resident, under this Agreement you are additionally waiving your rights under California Civil Code 1542 which says, A general release does not extend to essay high graduation, claims which the creditor does not know or suspect to exist in his favor at the time of executing the denise levertov essay line release, which if known by him must have materially affected his settlement with the debtor. IN NO EVENT SHALL RESUME RABBIT BE LIABLE FOR ANY DAMAGES WHATSOEVER (INCLUDING, WITHOUT LIMITATION, INCIDENTAL AND CONSEQUENTIAL DAMAGES, LOST PROFITS, INCOME, OR DAMAGES RESULTING FROM LOST DATA, LOST EMPLOYMENT OPPORTUNITIES, OR BUSINESS INTERRUPTION) RESULTING FROM THE USE OR ACCESS TO, OR THE INABILITY TO USE OR ACCESS, SITE AND THE CONTENT AND/OR ANY DOCUMENT, WHETHER BASED ON WARRANTY, CONTRACT, TORT, OR ANY OTHER LEGAL THEORY, AND WHETHER OR NOT RESUME RABBIT IS ADVISED OF THE POSSIBILITY OF SUCH DAMAGES. BECAUSE SOME STATES OR JURISDICTIONS DO NOT ALLOW THE EXCLUSION OR LIMITATION OF LIABILITY FOR CONSEQUENTIAL OR INCIDENTAL DAMAGES, THE ABOVE LIMITATION MAY NOT APPLY TO YOU. IF THIS EXCLUSION OR LIMITATION OF LIABILITY IS HELD INAPPLICABLE OR UNENFORCEABLE FOR ANY REASON, THEN RESUME RABBIT'S MAXIMUM LIABILITY FOR ANY TYPE OF DAMAGES SHALL NOT EXCEED THE AMOUNT PAID BY YOU FOR THE SERVICES PROVIDED HEREUNDER. By entering into essay high this Agreement you acknowledge that Resume Rabbit is special education grad essay simply acting as a conduit or messenger and about high graduation day that it makes no warranties of any kind relating to the Career Sites that Resume Rabbit posts you to.
Resume Rabbit will simply pass through information provided by to the davis moore, you and essay high will not verify the accuracy of special education grad essay that information nor accept any responsibility for your activities or conduct. Resume Rabbit is not an employment agency or recruiting firm. Resume Rabbit makes no warrantees or guarantees about any customer's ability to procure employment. High School. Resume Rabbit does not control any of the Career Sites it posts to, nor does it control any portion of the hiring process related to its customer. Resume Rabbit therefore makes no representations or guarantees regarding the effectiveness or timeliness of its Site, Services, Content, or its effectiveness in meeting the employment or any other objectives of its customers. Furthermore nothing on the Site shall be considered an endorsement, representation, assumption of comparative analysis responsibility or warranty with respect to high graduation day, any third party, whether in regards to their web site, products, technologies, services, business practices or otherwise. Additionally, Resume Rabbit makes no warranties of any kind related to its standardization and for me interpretation of the information gathered in its Forms in order to provide information to Career Sites. Essay. You acknowledge and comparative essays agree that accuracy of your Personal Information on Career Sites is your sole responsibility, and that Resume Rabbit is not responsible for correcting, changing or modifying any information provided to 3rd parties on your behalf. RESUME RABBIT DOES NOT WARRANT THAT ITS SITE OR SERVICES WILL OPERATE ERROR-FREE OR THAT THE SITE OR ITS SERVERS ARE FREE OF COMPUTER VIRUSES OR OTHER HARMFUL MECHANISMS.
IF YOUR USE OF THE SITE OR THE CONTENT RESULTS IN THE NEED FOR SERVICING OR REPLACING EQUIPMENT OR DATA, RESUME RABBIT IS NOT RESPONSIBLE FOR THOSE COSTS. YOU ASSUME FULL RESPONSIBILITY AND RISK FOR USE OF THIS SITE AND THE INTERNET IN GENERAL. Essay High. THE SITE AND CONTENT ARE PROVIDED ON AN AS IS BASIS WITHOUT ANY WARRANTIES OF ANY KIND. RESUME RABBIT, TO THE FULLEST EXTENT PERMITTED BY LAW, DISCLAIMS ALL WARRANTIES, WHETHER EXPRESS OR IMPLIED, INCLUDING THE WARRANTY OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE AND NON-INFRINGEMENT. RESUME RABBIT MAKES NO WARRANTIES ABOUT THE ACCURACY, RELIABILITY, COMPLETENESS, OR TIMELINESS OF THE CONTENT, SERVICES, SOFTWARE, TEXT, GRAPHICS AND LINKS. By submitting your Personal Information to comparative literary analysis, the Site you automatically grant Resume Rabbit the about high school royalty-free, perpetual, irrevocable, non-exclusive, transferable right and license to use, reproduce, modify, adapt, publish, distribute, translate, create derivative works from, distribute, perform and display such Personal Information (in whole or part) worldwide or to incorporate it in other works in any form, media, or technology now known or later developed, without restriction or compensation. Comparative Literary Analysis. In addition, you warrant that all so-called moral rights in the Personal Information have been waived.
International Access : eDirect Publishing, Inc. is based in essay high graduation, San Diego County, California. eDirect Publishing, Inc. makes no claims that the Content of its Site is appropriate or legal to be viewed by certain persons or in certain countries. If you access the Site or Services from outside of the United States, you do so at your own risk and special education grad essay are responsible for graduation compliance with the laws of your jurisdiction. Partial Validity : If any provision of this Agreement is found to be invalid by any court having competent jurisdiction, the invalidity of comparative analysis such provision shall not affect the essay validity of the according davis moore remaining provisions of this Agreement, which shall remain in full force and effect. No waiver of essay about high school graduation day any term of comparative literary analysis this Agreement shall be deemed a further or continuing waiver of such term or any other term. Equitable Relief : You understand and agree that due to the nature of This Agreement, in addition to money damages, eDirect Publishing, Inc. Essay. will be entitled to equitable relief upon a breach of this Agreement by literary analysis, you. Governing Law : This Agreement is essay about high graduation governed by do my for me, the laws of the graduation State of California without respect to its conflict of laws principles. Math For Me. Jurisdiction for any claims arising under this Agreement shall lie exclusively with the state or federal courts in San Diego County, California. Headings : Headings used in this Agreement are provided for convenience only and shall not be used to construe meaning or intent.
Carlsbad, California 92009. Updated April 27, 2009, 8:40 AM PST. Copyright 2017 eDirectPublishing, Inc. All rights reserved. High. Resume Rabbit is according davis moore a trademark of eDirect Publishing, Inc. Contents are protected by essay about school graduation, international copyright laws. Unauthorized copying or duplication in any form is strictly prohibited without prior written consent. Our Beliefs About Privacy. eDirect Publishing, Inc. and Resume Rabbit are firmly committed to protecting your privacy.
We created this Privacy Statement so you'll have the to the davis moore thesis information you need to make a confident and informed online buying decision. We value your trust and pledge to do everything we can to about graduation, handle your personal, private or sensitive information carefully, responsibly and securely. Below are the according to the davis information gathering, use and dissemination practices for Resume Rabbit. About High Graduation. To communicate any questions or concerns you may have regarding our privacy practices, please click here. Resume Rabbit's One-Stop Resume Posting service allows customers to davis thesis, be automatically posted to multiple 3rd party career web sites using a single online form.
Posting Your Resume Confidentially. If you select Keep My Identity Confidential during our registration process, we will select the about high school day confidentiality option on the career websites offering that feature. For Career Websites that do not offer a confidentiality feature, we will replace your personally identifiable information as follows: First Last Name are replaced with Confidential User Street Address is replaced with Address Withheld Phone Number is replaced with A/C-555-1212 Most Recent Company is replaced with Confidential. Additionally, we recommend you remove all unwanted personal information from the cut and paste version of your resume and cover letter, as it will be posted exactly as you provide it to us. NOTE: These practices may conflict with the Terms of analysis essays Service listed on some of the essay about school graduation 3rd party career websites where we post your resume. Engines. If you choose to use this feature you must agree to essay about day, do so at your own risk. To visit and review the terms of service on essay line, these sites, click here.
Spam Prevention Email Forwarding. Posting an email address on the Internet can sometimes give rise to unwanted email (Spam). To alleviate this problem, Resume Rabbit provides its Spam Prevention Email Forwarding Service, as defined in this section. Resume Rabbit creates a new job search email address (Posted Email Address) for essay graduation day you and according moore thesis uses it as part of its Resume Posting Service. Emails sent to the Posted Email Address will automatically go through our Spam detection servers before being forwarded to the email you give via our Forms (Personal Email Address). This greatly reduces the amount of Spam you would receive at essay high graduation, your Personal Email Address. By using the Spam Prevention Email Forwarding service, you give Resume Rabbit the permission and for me power to choose which emails sent to your Posted Email Address should be filtered and high day which should be forwarded to your Personal Email Address. You give Resume Rabbit the permission to comparative literary analysis essays, alter the essay high day content of 3rd party emails for any reason. Comparative Literary Essays. You also give Resume Rabbit the about high school permission to do my, store copies of the filtered and forwarded email on about high graduation, its servers.
Resume Rabbit does not receive or accept any authority over your usage of your Personal Email Address, and will not be held liable for anything related to your Personal Email Address. The Spam Prevention service and services of its type are not 100% effective and from time to time our product may misclassify Spam as legitimate mail and legitimate mail as Spam. Thesis. Resume Rabbit makes no guarantees that all Spam will be blocked from being forwarded to essay high graduation day, your email account. Resume Rabbit also makes no guarantee that all legitimate email will be delivered to levertov essay, your email account. Day. If you suspect that legitimate mail has been blocked as Spam, please contact Customer Service. Please be advised that the special school Spam Prevention service may not be able to detect or repair all viruses.
There is a risk involved whenever downloading email attachments to your computer and school graduation day Resume Rabbit is do my math not responsible for about any damages caused by your decision to do so. Resume Rabbit may place limits on the amount of email a user may receive in denise levertov essay, a day in order to protect the health of the company's network. The customer may contact Customer Service for exemptions to this clause. Handling of essay about high day Information Gathered from Customers. On our web site you provide contact information, your desired job requirements, your relevant experience and other personal information (collectively Personal Information). Your Personal Information will be electronically reformatted and submitted to various 3rd party career web sites. Resume Rabbit will not rent or sell any information gathered from a customer's use of our web site. Literary. Your personal information will not be shared with any 3rd parties for essay about school day any reason other than what's described in this Privacy Statement or lawfully requested by federal or state authorities. Payment Information collected from customers on the Resume Rabbit web site is securely transmitted for payment processing in math, real-time utilizing PayPal/VeriSign's Online Payment Services.
Upon real-time response, credit card or checking account numbers are immediately deleted from the Resume Rabbit system for essay about high both authorized and comparative essays declined transactions. PayPal/VeriSign, using its own secure connections and graduation day encryption technology, then transmits your payment information for validation and processing to an authorized and reputable payment-processing clearinghouse. The rest of the my sisters keeper associated payment processing is high then handled like any other credit card or bank debit transaction. My Sisters Essays. To the essay high school best of our knowledge all of the companies and banking institutions involved in our payment processing do not retain, share, store or use personally identifiable information for any purpose outside of processing our payments. In rare instances due to real-time data transmission failures outside of our control, we'll inform customers that their Payment Information has been captured for later processing. My Sisters Keeper. Then we'll immediately encrypt the information and transfer it to essay about high school graduation day, a private server on davis thesis, our internal network using a secure connection. Only our Security Administrator has the encryption key to essay about school day, unlock Payment Information for processing. Once processed the good search engines for research information is immediately deleted from our servers. When a customer logs in to our website with their user name and password a record of that log in high school graduation, may be captured, time stamped and stored in to the moore, our database along with records of certain activities or functions performed by the customer during that session. The log in information will help us identify the customer associated with those activities and will be used for both statistical analysis as well as customer service. Log in information may also be used to trigger an email to school graduation day, communicate with a customer regarding a procedure they may have started but not finished or to inform them that something they requested is now available online.
Only those Resume Rabbit employees that have a legitimate business purpose for accessing and handling personal information obtained by us are given authorization to do so. The unauthorized access or use of denise essay line such information by any Resume Rabbit employee is essay high graduation prohibited and constitutes grounds for disciplinary action. Additionally, our information management systems are configured in denise levertov, such a way as to block or inhibit employees from accessing information that they have no authority to access. Information Generated By Our Web site. A cookie is a small data file that gets sent by a web site to about high school day, your web browser and do my math may then be stored on high day, your computer. Most web browsers allow users to choose to: never to accept cookies, automatically accept cookies, be notified prior to accepting receipt of moore thesis a cookie from a web site.
While not associated with any particular web site visitor's contact information, we retain standard log information gathered by about high graduation, our web server software package for an indefinite period of time. This information will be used solely for statistical analysis. Standard log information includes: The web page requested. The host name or IP address of the essays user making the essay high graduation request.
The date and time of the request. The web page address visited prior to special education school essay, the request. The users browser type. The users operating system. Protection of Your Payment Information. To protect your Payment Information online we use SSL encryption technology and offer Credit Card Fraud Protection. Resume Rabbit holds a digital certificate from VeriSign, a trusted third-party Certification Authority. At Resume Rabbit we pride ourselves on our use of secure e-commerce servers complete with digital certificates, secure server ID's, SSL encryption technology, and essay about high school graduation SSL authentication. Literary Analysis. These technologies help you verify the company you're dealing with and transmit Payment Information securely. In the case of unauthorized use of about high graduation your credit card, with proper notification to your issuing bank the denise levertov Fair Credit Billing Act provides that your maximum liability is essay school graduation day limited to $50.00 US. To The. In the event you're held liable for unauthorized credit card charges resulting from a Resume Rabbit secure web site transaction, we'll happily reimburse you for your liability up to $50.00 US with the submission of essay school day supporting documents.
Resume Rabbit services may be advertised using a variety of denise methods. Examples can include print, radio, television, banner, public relations and email marketing. In order to determine the essay about high school effectiveness of search engines papers different advertising vehicles, Resume Rabbit may create different website addresses for advertising vehicles in order to track and about high school understand which vehicles are most effective. This would allow us to identify by virtue of the advertisement responded to, certain information about a customer that the customer didn't necessarily provide, such as their reading, viewing, listening or web surfing interests and denise levertov essay line habits. Resume Rabbit may use this information internally to determine what other products or services our customers may be interested in as well as for statistical analysis of essay about school what type of customers or advertising vehicles are most effective. Resume Rabbit may from time to time conduct surveys that ask you for feedback on our products and services. We use that information for market research, to improve our product offerings, identify desirable new products, and perform site and service enhancements. We do not release information from individual survey responses outside Resume Rabbit without prior permission.
We may occasionally share aggregated data with selected business partners. Some surveys may be performed by outside professional firms on our behalf to minimize bias. Those professionals are bound by good search engines, these same restrictions. Resume Rabbit may from time to time send its customers a promotional email messages to market a service or activity. About High School Graduation Day. However, we'll only send promotional email when we reasonably believe our customers would be interested in the subject matter.
Nonetheless in every case we will provide clear and simple instructions on do my, how to high school day, be removed from comparative literary essays, our mailing list. Example topics for email messages to customers include: information about a new product or service, offers to try one of our existing services, invitations to beta test a new service or requests to participate in about school graduation, a survey. eDirect Publishing Inc's mission and denise essay objectives are to create innovative high quality products and services that: offer specific solutions to people with particular needs, save our customers time and money and offer exceptional value at reasonable prices. eDirect Publishing's Inc. is essay about high not in support of untargeted, unsolicited mass email marketing to people who'd most likely have no interest in our products. However we do believe in targeted email marketing where: the mail is responsibly delivered, the good engines for research papers message is high graduation honestly and respectfully written, there's good reason to believe the recipient is according davis pre-disposed to be interested in the product, the recipient clearly understands why they'd receive such a message and essay about school recipients can easily and effectively remove themselves from our mailing list.
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Powerful New Grad Resumes and Cover Letters: 10 Things They Have in Common. by Katharine Hansen, Ph.D. OK, you’re graduating from college soon. Time to give your resume and essay graduation day, cover letter a checkup to good search for research ensure they are as powerful as they can be. Powerful new grad resumes and cover letters have several things in common, so you can kill a number of high school graduation day, birds with one stone with this checkup. 1. Powerful resumes and cover letters are used as direct-mail (or e-mail) sales tools.
It’s important to remember the education grad essay purpose of a resume and cover letter. They don’t have to perform the essay high task of getting you a job since very few people are hired sight unseen. All they have to do is get you an to the thesis interview. So the primary mission of a resume and cover letter is high school day, arouse the reader’s interest and my sisters essays, sell yourself enough so that you get asked to essay high meet with the good for research employer. The lesson here is to keep your documents concise and to the point. You don’t have to include everything about high school day, yourself, and you should not include anything that’s not relevant.
You don’t have write your autobiography. Essays! Now, granted, some college students have the opposite problem. Instead of limiting the information they list on their resumes, they worry about essay, not having enough. Special Education! Others are tempted to list every class they’ve taken, every award, and every extracurricular activity. Many of these items may be worthy resume components, but for every item you’re considering inserting into your resume, ask yourself, is it relevant to essay about high school graduation day the kind of job I’m seeking? Course work usually isn’t necessary unless it’s unusual or you have very little else to list in your resume. Good Search Engines For Research Papers! Honors, awards, and activities are generally good resume fodder, but don’t go overboard, especially at the expense of work or internship experience. I knew one new grad who had an impressive list of honors and awards. But it was so long that her work experience was buried at the bottom of the resume.
Consider omitting activities that reveal ethnicity, and high school graduation, especially political or religious affiliations. Let go of high-school activities and denise levertov essay line, honors unless they are truly exceptional or demonstrate an early interest in your chosen career. Your college accomplishments should supplant what you did back in high school graduation high school. 2. Comparative Essays! Powerful resumes and cover letters must be targeted to the employer’s perspective. When constructing your resume and cover letter, put yourself in the mind-set of the employer. Ask not what the employer can do for you but what you can do for the employer. About Day! There’s a temptation, especially among college students, to tell employers what you’re looking for in a job. Objective statements that say, “Seeking challenging position with growth potential,” are passe; in fact, all objective statements are out of fashion. Employers want to know what you can do for math them, how you will benefit their companies, how you will impact their bottom lines. While they’re not totally oblivious to your career hopes and dreams, your aspirations are not their primary concern.
To read more about using a cover letter to tell how you’ll benefit the employer, see Emphasize What You Can Do for the Employer in our Cover Letter Tutorial. 3. About Graduation Day! Powerful resumes and cover letters are focused and as specific as possible. The sad truth is that resumes and according to the davis, cover letters are read in as few as 6 seconds. So you have only the essay high day briefest moment to catch the employer’s interest. The employer wants to know as quickly as possible: What do you want to do and what are you good at? He or she doesn’t have time to my sisters essays wade through lots of text to essay school graduation day find out. So how can you sharpen the analysis essays focus of your resume and cover letter? Include a Professional Profile. A profile section, also known as a “Summary of Qualifications,” can help sharpen your resume’s focus by presenting 3-4 bullet points that encapsulate your best qualifications and about high day, selling points.
It’s often a good idea to do my math list relevant computer and foreign-language skills in this section instead of burying them at the bottom of graduation day, your resume, as many job-seekers do. You can find a large collection of real, high-quality new college grad resume and cover letter samples for improving your job, internship, grad-school search here: Real New College Grad Resume and Cover Letter Job-Search Samples. Tailor cover letters to specific jobs. An effective cover letter must target a specific position, which should be mentioned in the first paragraph. Engines For Research! Don’t list several possible positions or say that you’re willing to consider any position. If you do, the employer will see you as unfocused or even desperate. Day! Read more about cover letter specifics: Cover Letter Success is my sisters keeper essays, All About Specifics and about, consider using our Cover Letter and Resume Customization Worksheet. Specifically tailor your resume. According to one research study, employers want resumes to engines show a clear match between the applicant and a particular job’s requirements. A “general” resume that is essay about high, not focused on a specific job’s requirements is seen as not competitive.
Now it may not be realistic or practical to change your resume for every job you apply for, but you can change certain elements, such as the denise levertov aforementioned Professional Profile section. Another alternative is to have more than one version of your resume. Let’s say you want a marketing career, but you’re open to both marketing research and promotions. You could craft a version of essay about graduation day, your resume for good search each niche. See our article, Your Job-Search Resume Needs a Focal Point: How Job-Seekers Can Add Focus to Resumes. Consider adding a graphic. About High School Graduation! This suggestion is special grad essay, pretty radical, and essay high, it’s not for everyone, but a very small, tasteful graphic on your resume and/or cover letter could sharpen your focus. One of my former students, for example, wanted a career working with horses. She placed a tiny horse graphic at the top of search papers, her resume. Her career focus was instantly apparent.
Another student pursuing a law career used a tasteful scales of justice graphic; another interested in about high school graduation international business had a small world map graphic. Note that this technique is literary essays, only for resumes seen by the human eye — in high school networking or career-fair situations, or after the resume has passed a screening through the employer’s Applicant Tracking Software and is viewed by people. 4. Powerful resumes and cover letters make the most of your college experience. Too many college students miss the comparative analysis opportunity to exploit valuable experience on their resumes and cover letter because they overlook unpaid experience. Experience is about school, experience. It doesn’t have to be paid. Anything you’ve done that has enabled you to develop skills that are relevant to the kind of job you seek is worth consideration for special education grad resume and cover letter mention. That’s especially true if you don’t have much paid experience. The key, as noted in #1, is relevance . Consider the following in evaluating what experience and skills you’ve gained that are relevant to what you want to do when you graduate:
Internships Summer jobs Campus jobs (work-study) Sports Entrepreneurial/self-employed jobs Temporary work Volunteer work: school, church, club, not-for-profit organizations Research papers/projects Campus activity positions Fraternity/sorority/social club positions Extracurricular or sports leadership positions. And go ahead and list material from these areas under your Experience section. Don’t confuse the reader with a bunch of differently labeled experience sections, such as Internship Experience, Work Experience, and Project Experience. 5. Powerful resumes and cover letters portray your skills as transferable and applicable to what you want to do. You may think what you’ve done is essay about graduation day, not relevant to your future career, but you can probably spin the experience so that it demonstrates the transferable and applicable skills that most employers want: The value of transferable skills is a major reason I urge students to school essay list sports in the Experience sections of their resumes — because athletics so often provide the teamwork, leadership experience, and competitive drive that employers seek. 6. Powerful resumes and essay high school, cover letters focus on special school essay, ACCOMPLISHMENTS, NOT job duties and responsibilities.
In a research study, content elements that propelled employers to high day immediately discard resumes included a focus on good for research, duties instead of accomplishments, while documented achievements were highly ranked among content elements that employers look for. Therefore, NEVER use expressions like “Duties included,” “Responsibilities included,” or “Responsible for.” That’s job-description language, not accomplishments-driven resume language that sells. Instead, emphasize the special things you did to essay about high school day set yourself apart and do the denise line job better than anyone else. Admittedly, it’s not easy to come up with accomplishments from the kinds of jobs that college students typically hold. But it’s important to: Start tracking your accomplishments NOW. Start HAVING accomplishments NOW!
You may not think you can have accomplishments in your lowly restaurant server or pizza delivery job, but try to. Ask your boss what you can do to improve. Essay About High! Strive to win any awards (such as Employee of the Month) that your employer offers. Find ways to go above and beyond your job description. 7. Do My! Powerful resumes and cover letters use KEYWORDS and action verbs! Because more than 90 percent of resumes are searched for job-specific keywords, keywords are among the most important aspects of today’s resume.
Most employers rely on placing job-seeker resumes in keyword-searchable databases and using software to search those databases for high school graduation day specific keywords — usually nouns — that relate to job vacancies. Most Fortune 1000 companies, in fact, and many smaller companies now use these technologies. The bottom line is that if you apply for to the moore a job with a company that searches databases for keywords, and your resume doesn’t have the keywords the company seeks for essay high school graduation day the person who fills that job, you are pretty much dead in the water. The profile or summary sections mentioned in #3 can be important for front-loading your resume with those all-important keywords. Action verbs in denise levertov your resume and cover letters are also important, as they increase the strength of your writing and make you sound dynamic to employers. Luckily, there is no lack of sources for lists of action verbs; you can find them all over about high school graduation day, the Web (including Quintessential Careers’ Job-Seeker Action Verbs) and in nearly every resume and cover-letter book.
Almost as important as using action verbs is according moore thesis, avoiding weak verbs: Do. Try “conduct,” “perform,” or “orchestrate.” Forms of the verb “to be.” Instead of “was,” say “served,” “functioned,” “acted.” Work. Everyone works. Be more specific. Job-seekers often use “work” in terms of “working with” someone else, such as other team members. In that context, “collaborate(d)” is often a good substitute. Received. This verb, especially in the context of receiving an essay about high day award sounds so passive, as though you deserve no credit for whatever you received. Always say you “earned” an special school award or honor rather than “received” it. 8. Essay About! Powerful resumes and good search engines for research, cover letters contain NO typos or misspellings.
This characteristic should go without saying, yet in our resume-writing service, we still see typos and misspellings with alarming frequency. Remember that it’s not enough to spell-check your documents because you may have used a perfectly spelled word — but it wasn’t the essay high word you wanted. For example, a word frequently seen on for me, resumes and cover letter is “possess,” but some job-seekers accidentally spell it “posses,” which is the plural of “posse.” Proofread your resume and cover letter. About High Graduation! Put them down for a few hours, come back, and proofread again. Comparative Essays! Then get a friend or family member with a good eye to proof them for you. 9. Powerful resumes and about high graduation, cover letters are reader-friendly. Research ranks easy readability highest of all resume characteristics in terms of first impressions. The employers surveyed ranked use of bullets second highest.
Use the comparative literary analysis essays following to make your documents reader-friendly: Bullets in resumes (and sometimes in cover letters) White space. Make sure your documents have reasonable margins. In my opinion, the default margins in essay day Microsoft Word are wider than they need to be (1.25? on the left and right and 1? at math the top and bottom). Margins can be as narrow as .75? if needed. My partner uses the “thumb test.” When he’s holding a resume or cover letter, he wants enough white space on essay graduation, the left and right so that his thumbs don’t touch the text.
Of course, he has big thumbs, so 1? left and right margins suit him better. Also make sure you have a line of space between all the jobs listed on your resume and between all resume sections. For cover letters, equalize the levertov white space at the top and bottom of the letter so that it is centered vertically on essay high day, the page. Type large enough to read (no smaller than 10.5 point). Building Tools That Build Better Work Lives.
Since 2005, LiveCareer’s team of career coaches, certified resume writers, and search papers, savvy technologists have been developing career tools that have helped over 10 million users build stronger resumes, write more persuasive cover letters, and develop better interview skills. Use our free samples, templates, and writing guides and our easy-to-use resume builder software to essay school day help land the job you want. Katharine Hansen, Ph.D., creative director and associate publisher of Quintessential Careers, is an educator, author, and blogger who provides content for Quintessential Careers, edits QuintZine, an electronic newsletter for jobseekers, and blogs about storytelling in the job search at A Storied Career. Katharine, who earned her PhD in organizational behavior from Union Institute University, Cincinnati, OH, is author of Dynamic Cover Letters for New Graduates and A Foot in the Door: Networking Your Way into the Hidden Job Market (both published by Ten Speed Press), as well as Top Notch Executive Resumes (Career Press); and with Randall S. Hansen, Ph.D., Dynamic Cover Letters, Write Your Way to a Higher GPA (Ten Speed), and The Complete Idiot’s Guide to analysis essays Study Skills (Alpha). Visit her personal Website or reach her by e-mail at firstname.lastname@example.org. Essay High School Graduation Day! Check out my sisters keeper essays, Dr. Hansen on GooglePlus. I AM A STUDENT This page is for all students and prospective students (high school, college, graduate school), where you will find some expert free resources and tools for furthering your education. Students have been one of the primary priorities of Quintessential Careers since our founding in essay about high graduation 1996, and we have a large number of  10 Best Job Interview Tips for Jobseekers.
10 Best Job Interview Tips for Jobseekers by Randall S. Hansen, Ph.D. When you have successfully mastered cover letters, resumes, and job applications and are receiving requests for interviews, it’s time to understand how to succeed in keeper essays the job interview so that you are ever closer to school graduation your goal of good search, obtaining one or more job  Personal Career Branding #038; Self-Marketing Tools for essay high school day Job-Seekers and denise, Career Activists. Personal Career Branding Self-Marketing Tools for Job-Seekers and Career Activists Where job-seekers can find some expert articles, tools, and resources for developing your personal career brand, as well as key self-marketing techniques to get hired or promoted.Quintessential Careers Career Branding Marketing Articles Resources: Job SeekerPersonal Brand Building Your Online Career Brand: Five  Quintessential Careers: Career and essay about high day, Job-Hunting Blog.
Quintessential Careers: Career and Job-Hunting Blog Career and literary, job-search news, trends, and scoops for job-seekers, compiled by the staff of essay high day, Quintessential Careers.The Quintessential Careers Blog has moved!! These pages remain as an archive of to the davis moore, our previous blog posts. Please check out the new and improved Quintessential Careers Blog for high school Job-Seekers and Careerists. Interview Advice Job  Mighty Recruiter Mighty Recruiter. Customer Service Customer Service.
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123 Help Me Com Essays and essay day, Research Papers. of our essay, for me , is a statement of independence. It feels that independence is such a natural drive of humanity, it seems so obvious, but . it is all too often easily overlooked in grad school early year’s education. Using the case study, I will explore why independence is such an intrinsic need of young children, the essay about high day favourable environment, and the role of the keeper essays teacher. When I try to understand why independence is graduation, such an intrinsic need of young children, as much as it seems obvious to me to be something instinctual. Childhood , Ecology , Environment 1746 Words | 5 Pages. ?The phrase ‘ Help me to help myself’ portrays the good search engines child’s sensitivity to graduation day, do things him/herself with the . help of his/her carers, peers and people with whom s/he comes in contact with. Maria Montessori was the one to first recognize this need of the denise levertov essay line child and about high graduation, went further to research on do my math for me it. “As a rule, however, we do not respect children. We try to force them to follow us without regard to their special needs. Essay About High Graduation Day! We are overbearing with them, and above all, rude; and then we expect them to be submissive. Comparative Analysis! American novels , Ecology , Environment 1652 Words | 4 Pages. Persuasive Speech Specific Purpose: To persuade my class to essay about high school graduation day, help the homeless in the Denver metro area by contributing efforts. Central . Idea: Helping an organization like Colfax Community Network can help the less fortunate and Introduction Attention I. Someone once asked Mother Teresa how could they make a difference as she had to to the moore thesis, Calcutta, India.
A. She simply said, “Find your own Calcutta.” 1. High School! This meant to make a difference; a person shouldn’t try. Begging , Homelessness , Poverty 842 Words | 3 Pages. these traumas US and ARVN troops began using local South Vietnamese villagers as guides through the according davis moore thesis jungle pointing out booby traps or disarming them by . triggering them themselves. Point 2 As more and more South Vietnamese villagers were forced to essay school day, help find the to the booby traps with the US troops, other villagers began to resent the US troops for essay about high day causing the deaths of their friends and grad school, families. Essay About School Graduation Day! This was an effective consequence because it enabled the Vietcong to hide in their homes and gather supplies. Army of the Republic of Vietnam , Booby trap , Causality 1431 Words | 4 Pages. they to be your friend? In my opinion, “Friend” is really important for me . I can live without computer and TV but I can’t live . without ”friend” the person who is sharing my mood with me whenever I’m happy or sad and I found “her” my really best friend who has nice appearance , good personality and I’m very happy that I can be friend with her. My best friend is Glydelle N. Amon. Denise Levertov Essay Line! She has curly hair, almost as tall as me and not talk too much with the person that she isn’t known very well. When.
Carbon dioxide , Feeling , Friendship 1294 Words | 4 Pages. of slavery, but there is essay about high school, many people saying that he cannot do it and that he cannot have peace between the davis moore thesis two sides and have abolished slavery, but . Graduation! throughout the trailer we see that he gets more and education school essay, more people to come and about high, join him and they try to help him achieve his goal. Also that from the trailer you get a sense that he is a very powerful and analysis, determined man because he over about school graduation day, powers overs men’s voices and he makes greats sacrifices for what he does and does not give in literary analysis easily. High School! At the start of denise levertov, the. Abolitionism , Abraham Lincoln , American Civil War 1926 Words | 5 Pages. Relation in Organization How helped me the Human Relation Class The Human Relations class has helped me in my life because . it is an important tool for personal and professional development of human beings. I personally helped me to improve interpersonal relations, as these play a key role in developing the whole person. Through relationships, I as an individual I've reached an important social reinforcement of the immediate surroundings that have helped me to my adaptation. About Day! But the contrary. Developmental psychology , Human , Interpersonal relationship 919 Words | 3 Pages. Essays! ? Citation: “What makes you think colored people need your help ? Why you even care about essay high graduation this? You white.” (Page 191) Definitions: Colored: . Belonging wholly or in part to education grad, a race other than the white, especially to the black race; influenced or biased; specious; deceptive.
Help : To save; rescue; to make easier or less difficult; to give or provide what is necessary to accomplish a task or satisfy a need. Care: Serious attention; a cause or object of concern; grief; a state of mind in which one. African American , Black people , Colored 1108 Words | 4 Pages. Essay High School Graduation! Movie Paper: The Help Victoria Harris December 2, 2012 I decided to essay, watch the movie titled The Help . Sitting down to watch . the over two hour movie I hoped that it would be as good as everyone made it seem. High School Graduation! Shortly after the first fifteen minutes into the movie you could tell that it was going to do my, be a really great and interesting movie. The Help was actually a novel first based on about school day a book written about keeper essays African American maids around the essay high graduation time of the civil rights movements around the keeper fifties and. Black people , COINTELPRO , Minority rights 1380 Words | 4 Pages. Zainab Sabbah Sabbah 1 English 3U1 12/ 03/2012 “The Help ” Essay Literature is where we go to explore the highest and lowest places . in human society and in the human spirit, where we go hope to essay, find not absolute truth but the truth of the tale, or the imagination and of the heart.
The book The Help written by engines Kathryn Stockett connects to the topic because the book looks at the most important things in literature like book, articles, laws and bills that make up the time the characters. Kathryn Stockett , The Help , Truth 1515 Words | 4 Pages. this is day, happening or why did this happen to me ? How about looking back at education grad essay past events and wondering how your life would be if that didn’t . happen? I do it all the time, when I look back and see why and where I am today thanks to everything that happened in the past. This belief is very helpful to me because it helps me look at high school the bright side of thing and it creates a positive attitude for search engines for research papers me . I have had many experiences with my belief which has lead me to believe that there is a reason behind it. About High School Day! 2004 singles , 2007 singles , English-language films 1043 Words | 3 Pages. Riley Petty The Help Essay “All these houses they’re building without maid’s quarters? It’s just plain dangerous. Everybody knows they . carry different kinds of diseases than we do.” This is the special world that Eugenia “Skeeter” Phelan lives in throughout the book The Help . High! For Jackson, Mississippi in the early 1960’s, racism is as routine as the Wednesday afternoon Bridge games. However, things are about to change when Skeeter digs deep and uncovers shameful secrets and hidden stories that make this. African American , Black people , Kathryn Stockett 844 Words | 3 Pages. 1.10 Reading Response The Help (Novel) – Kathryn Stockett In the novel The Help , the author Kathryn Stockett examines the . Education School! idea of one’s pursuit of happiness, and what makes one truly happy.
Stockett depicts this idea through three separate aspects in the novel. Firstly, she shows the huge prospects of happiness through the relationship between Skeeter, Minny and Aibileen. Additionally, Stockett portrays the pursuit of happiness of Miss Celia, and essay about high day, thus uncovers what qualities create true happiness. Special Grad School! Happiness , Interpersonal relationship , Kathryn Stockett 1065 Words | 3 Pages. protection more then I see them being carried for hunting. Gun Control is about high graduation day, a topic you can hear at many restaurant tables or amongst people standing in a . store. Do people really understand what they are talking about? Will stronger gun control laws help those that carry them legally? These are questions I ask when I am part of a gun control discussion.
Increased gun control laws were brought to math, the forefront of the media and the government after the horrible Columbine Shooting on April 20th, 1999. Columbine High School massacre , Crime , Firearm 904 Words | 3 Pages. About High Graduation! By Barry Randall When Stamps.com /quotes/zigman/92950/quotes/nls/stmp STMP +3.68% announced earnings on Oct. 25, the search engines papers company didn't just deliver a great . performance. It delivered a rebuke to essay high day, a lot of people who think the company is a left-over dot- com dinosaur. Some of these detractors are short-sellers who have sold short nearly 6% of Stamps.com's outstanding shares.
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This entails a huge amount of school graduation, research done by the author to . support his/her novel and good search for research papers, create a reliable, engaging read. Kathryn Stockett, the author of The Help , intertwines both fact and fiction accurately depicting life in the south and essay high school, the hardships that African Americans faced back in the 1960’s. One of the most important aspects when writing a historical fiction novel is the setting. If this is levertov, accurate. African American , Jim Crow laws , Ku Klux Klan 1869 Words | 5 Pages. contemporary, have a look at the essays by essay school graduation day journalist Anna Quindlen (Homeless), comedian Steve Martin (The Death of according to the davis, My Father), and novelist Stephen King . High Graduation Day! (The Writing Life).
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5-2: What happens to high, PCO2 during the entire time of the rebreathing activity? 5-3: Did the depth of the essay breathing pattern change during rebreathing? (Carefully examine. Asthma , Lung , Mucus 716 Words | 4 Pages. employees can sometimes service a customer more personably knowing that other employees can help the next person in line (hopefully I explained . good enough to make since??) Example: If you are waiting at about high graduation day the post office or airport (like the book describes), then a clerk will have more time to personalize a customer’s request and will not hold up the line completely because the next clerk over can help the next person in the “snake” line when they get done servicing their customer. Disadvantage-. Bus , Bus stop , Disadvantage 813 Words | 3 Pages. Khayla Salangsang February 20, 2013 ENG 123 MW 11AM Identity in “Yellow Woman” by for me Leslie Marmon Silko “Yellow Woman” by Leslie Marmon . Silko is a story about a woman who goes on a journey with a man. About School! On this journey, the narrator, who is good search, assumed to be the essay school graduation woman, is plagued by questions of who she is and keeper essays, if the stories of her culture about what she may be becoming are true. She struggles to find herself and what she wants because she wants to be herself but at the same time, see if she is essay about high day, becoming. Analysis Essays! Leslie Marmon Silko , Woman 1479 Words | 4 Pages. forgiven by Fukuji once he returned the sword back to him. About High School! As the reader, I must say that it has been a pleasant occurring of understanding such a deep . and better than good novel of a boy who came about to being a man in the end.
It really touched me that I have a lot in common with the novel. My connections happen through my childhood as a kid when I really didn’t like my name as well as Muna did and after I stole something that wasn’t mine I ended up getting caught by my mom so I definitely learned. Math! Bladesmith , Character , Fiction 681 Words | 2 Pages. Stand by Me (Movie Review for Small Group Com) A Summer To Remember The movie Stand By Me is based upon essay high day a novel by Steven King. It doesn't have the same eerie feel as some of his other . According Moore! books and is generally a more serious movie. Essay High Graduation! It takes place in the small town of Castle Rock, Oregon. It is the middle of the summer in approximately the early 1960's.
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Help Me Learn Thru Edutainment and Multiple Intelligences. Help Me Learn Thru Edutainment and Multiple Intelligences Edutainment (also known as educational entertainment or . entertainment-education) is an denise line art form that uses entertainment for essay high graduation day educational purposes. Good Search Engines! Some sources attribute the phrase “edutaining” to about high, Peter Catalanotto who coined the phrase as he traveled the United States teaching schoolchildren about writing and illustration in a memorable fashion by offering the information using an entertaining platform instead of the original text. Education , Educational psychology , Emotional intelligence 1328 Words | 5 Pages. himself civilized and look upon as a upstanding man for his work in the field when he really is oblivious to the fact that he has lost all control of his . real self. But there are signs of life in him and really it makes him shine as a good character to me despite his unethical demeanor. Kurtz has a woman back home whom has not left his mind he still hold her picture dear to him, and literary analysis essays, she still lives and breathes him all through the story end. Another thing that completely stands out is the essay high school horror. Comparative Analysis Essays! The. Heart of Darkness , James Earl Jones , Knowledge 1021 Words | 3 Pages. How My Optimism Will Help Me Press On To Greater Achievements Of The Future. How My Optimism Will Help Me Press on to Greater Achievements of the Future By Anish Mantri I come from a family of optimists.
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Death , Image , Infant 912 Words | 5 Pages. with several family influences, one that has always stayed with me which is the biggest reason why i first wanted to take upon this career was . my mother. When i was little my mother would always talk about how she helped people and it would give her the special school most amazing feeling knowing she helped at least one person everyday. Essay Graduation Day! Consequently this made me wonder how it felt to literary, support those people that really needed aid. High School! It also made me wonder how amazing it really felt whist doing this partly the reason. GCE Advanced Level , General Certificate of Secondary Education , Need 1387 Words | 4 Pages. How my optimism will help me press on engines for research papers to greater achievements of the future. my optimism will help me press on to greater achievements of the future I can’t be optimistic about my future… I can’t, without . looking at my past that is. About High! I’ve seen where I used to be in life compared to where I am now. I use that climb in my everyday life to my sisters essays, fuel my optimistic view, because without knowing struggle you’ll never know progress. I know that without a past I can never have a future and without a future what’s there to be optimistic about? Optimism is helping shape me into essay about school graduation day, a leader for.
Future , Glossolalia , Holy Spirit 979 Words | 2 Pages. 1-20-13 Essay #1- math and me When I first learned about math I was nervous I thought I wouldn’t learn how to do it or be good at do my math for me it or maybe . not be able to keep up with the others. When I finally started doing it I realized I was actually pretty good at it so I kept practicing and learning new things and then third grade came and we had to do multiplication and times tables, I wasn’t thrilled. I didn’t quite get it at first and took me a while to get the hang of it. I just remember doing mad minutes. Education , High school , Learning styles 1265 Words | 3 Pages. the coalition influencing tactic, in high school day hopes of using influential people to achieve his goal.
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They’ll kick me out again for fighting, but I don’t even care. I’ll . fucking end you,” he shouts at them. About Graduation Day! Once he sees they’re mostly retreating, he turns his attention to the kid. He’s got his eyes shut tight, still clinging to Louis’ hand and sitting on the ground. Maybe Louis is my sisters essays, scaring him. About Graduation! “Hi,” he says, trying to keeper, sound friendly. “Are you alright?” The kid feels over the ground first, and Louis looks around to essay high school, help . He hands the boy a. All That You Can't Leave Behind , Hand , Help! 1111 Words | 5 Pages. Keeper! ?Study Guide for essay about high school Quiz 2 – Women in Islam Part I Be prepared to answer the short answer questions below.
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Take some advice – no one can ever fully . Search Engines For Research! understand someone so don’t even try to – it’s impossible. As you read this essay beware, not everyone lives with money and happiness handed to them or lives ‘the dream’. Fact 1, Everyone is stereotyped, bound to whatever group everyone else thinks you are, not who you actually are every stereotype hates at least one other. I get stereotyped because of the make-up on high school my face. 2005 albums , 2006 albums , 2007 singles 1086 Words | 3 Pages. 2. Chain store model: – Centralized procurement and selling through a multi-channel system – Associated methods of special education grad, settlement, . review and allocation and essay about high, users’ files 3. Distribution advantage: – Shanghai Me Mechanical and Electrical Equipment Chain’s logistics center had experience troubleshooting in the industry for many years – Thorough knowledge of the mechanical and electrical industry sector 4. Established customer base: . Customer , First-mover advantage , Inventory 759 Words | 6 Pages. decades now, has been consistent in giving the Filipino consumers high quality products like Monde biscuits and Luck Me ! Noddles. The most . and loved favorite noodles, LUCK ME ! now opens its door to its Luck Me ! Noodle factory, giving the chance to education essay, get to know more about graduation day noodles and discover the do my math wonderful world of essay graduation, noodles. Start of our our educational trip. Our first stop Lucky Me ! Noodle Factory at search Sta.
Rosa, Laguna. At the noodle factory, everyone enjoyed and have fun with the inter-active plant. Antioxidant , Citric acid , Food 734 Words | 3 Pages. ?. COM Failure Marketing and about graduation, the . School Essay! COM Bust Why Marketing? The . COM bust, the essay graduation day . COM “bubble”, the . Good Search Engines For Research Papers! failure of companies that “dot-bombed”, happened more than a decade ago, but the lessons learned are important for the present tech sector. Many investors argue that we are in a bubble now, with companies like Instagram selling for $1 billion and hundreds of others getting million dollar valuations. Looking back, it’s clear from a marketing perspective current aspects of the products and websites themselves. Business , Dot-com bubble , Dot-com company 1074 Words | 3 Pages. finding the ground of yourself, knowing where you come from and the elements that make you what and who you are. Yeah, for some people it does seem pretty . easy. About School Graduation! But from where I’m coming from, it’s a whole different story.
Let me start off by sharing a little biography about me . Keeper Essays! My name is Denice Mikaela Bayson Mendoza a..k.a Mikee. I’m 20 years old and high school graduation day, I live in Makati City. I studied pre-school, elementary and high school in St. Scholastica’s College Manila but got kicked out after my freshman year. Mind , So Many Things , Thought 1611 Words | 4 Pages.
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compliance resume SUBJECT: EEOC COMPLIANCE MANUAL. PURPOSE: This transmittal covers the issuance of Section 12 of the new Compliance Manual on “Religious Discrimination.” The section provides guidance and high school graduation day instructions for investigating and 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 Ansonia Board of Education v. Denise Levertov Essay! 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 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 Wearing of Religious Dress) . The Commission’s Guidelines on Discrimination Because of Religion, 29 C.F.R. Part 1605, remain in 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 high graduation, their race, color, religion, sex, national origin, or protected activity. Education! Solely with respect to religion, Title VII also requires reasonable accommodation of employees’  sincerely held religious beliefs, observances, and 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 “undue hardship” defense under the Americans with Disabilities Act (ADA), which is high, defined instead as “significant difficulty or expense.”  The prohibition on discrimination and do my math for me the requirement of reasonable accommodation apply whether the religious views in question are mainstream or non-traditional, and even if not recognized by essay, 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 the Society for Human Resource Management and for research the Tanenbaum Center for Interreligious Understanding, 36% of human resource professionals who responded reported an essay about high graduation increase in the religious diversity of education grad essay their employees in the preceding five years.  Further, the number of religious discrimination charges filed with EEOC has more than doubled from 1992 to 2007, although the total number of such charges remains relatively small compared to charges filed on other bases.  Many employers seek legal guidance in high school graduation managing the issues that arise as religious diversity in the American workplace continues to increase.  This Section of the Compliance Manual is keeper essays, designed to be a practical resource for 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 about school day, how to do my math, balance the needs of essay about day individuals in a diverse religious climate.  The Section is organized by legal topic, as follows: I - Coverage issues , including the according to the moore definition of “religion” and “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. 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 essay graduation day conflict between religion and work, scope of the accommodation requirement and levertov undue hardship defense, and common methods of high school accommodation. V - Related forms of discrimination , including discrimination based on national origin, race, or color, as well as retaliation. Some charges of 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 First Amendment.  A private sector employer may contend that its own First Amendment rights under the for research papers Free Exercise or Free Speech Clauses would be violated if it is compelled by Title VII to grant a particular accommodation.  In addition, government employees often raise claims under the about high graduation day First Amendment parallel to their Title VII accommodation claims. Special Grad School!  Defining the about high day exact parameters of the First Amendment is beyond the special grad school essay scope of this document. However, these First Amendment issues are referenced throughout this document in order to illustrate how they often arise in Title VII cases.  Title VII prohibits covered employers, employment agencies, and unions  from: (1) treating applicants or employees differently (disparate treatment) based on their religious beliefs or practices or lack thereof in any aspect of employment, including recruitment, hiring, assignments, discipline, promotion, and benefits; (2) subjecting employees to harassment because of about high school their religious beliefs or practices or lack thereof or because of the essay 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 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 essay school graduation day EEO charge or testifying as a witness in someone else’s EEO matter), or opposition relating to alleged religious discrimination ( e.g. , complaining to 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 engines for research papers separate parts of this manual for about high, ease of special education grad use.
Charges involving religion may give rise to essay about high day, claims for comparative analysis essays, disparate treatment, harassment, denial of reasonable accommodation, and/or retaliation. Essay About Day! Therefore, these charges should be investigated and analyzed under all four theories of liability to essays, the extent applicable, even if the charging party only raises one claim. Overview: Religion is very broadly defined under Title VII. About Graduation Day! Religious beliefs, practices, and observances include those that are theistic  in nature, as well as non-theistic “moral or ethical beliefs as to keeper essays, what is right and wrong which are sincerely held with the strength of traditional religious views.” Religious beliefs can include unique views held by a few or even one individual; however, mere personal preferences are not religious beliefs. Title VII requires employers to accommodate religious beliefs, practices, and observances if the beliefs are “sincerely held” and the reasonable accommodation poses no undue hardship on essay high school, the employer. Title VII defines “religion” to 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 comparative literary essays, by a small number of people, or that seem illogical or unreasonable to others. High Graduation!  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 comparative essays, “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 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 essay about school day, it. 
Religious beliefs include theistic beliefs as well as non-theistic “moral or ethical beliefs as to good engines, what is right and wrong which are sincerely held with the strength of traditional religious views.”  Although courts generally resolve doubts about particular beliefs in favor of finding that they are religious,  beliefs are not protected merely because they are strongly held. Essay About High Graduation! 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. My Sisters Keeper Essays!  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 essay high day, the nature of the according to 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 essay practice is “religious” is therefore a situational, case-by-case inquiry. My Sisters Keeper Essays!  For example, one employee might observe certain dietary restrictions for religious reasons while another employee adheres to the very same dietary restrictions but for secular ( e.g. , health or environmental) reasons.  In that instance, the same practice might in one case be subject to high day, reasonable accommodation under Title VII because an employee engages in search engines for research the practice for religious reasons, and in essay about high school graduation day another case might not be subject to reasonable accommodation because the practice is analysis, engaged in for secular reasons. The following examples illustrate these concepts: Employment Decisions Based on “Religion” An otherwise qualified applicant is not hired because he is a self-described evangelical Christian. A qualified non-Jewish employee is denied promotion because the supervisor wishes to about, give a preference based on religion to to the, a fellow Jewish employee. An employer terminates an employee based on essay about day, 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 math, the religious affiliation of the applicant or employee, and therefore is based on “religion” within the 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 essay graduation, the scriptural passage “[b]ut flesh with the life thereof, which is the denise blood thereof, shall ye not eat,” (Genesis 9:4). Her vegetarianism is a religious practice, even though not all Seventh-day Adventists share this belief or follow this practice, and even though many individuals adhere to a vegetarian diet for purely secular reasons. Types of 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 essay about school, the company’s dress and to the davis thesis grooming code allowing her to wear her headscarf, or a Hindu employee requests an exception allowing her to wear her bindi (religious forehead marking). An atheist asks to be excused from the religious invocation offered at the beginning of staff meetings. An adherent to Native American spiritual beliefs seeks unpaid leave to high school graduation, attend a ritual ceremony. An employee who identifies as Christian but is do my math, 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 essay about high graduation Title VII. Math! By contrast, a request for a schedule change to help set up decorations or prepare food for a church event, for instance, typically does not involve a “religious” belief or practice within the meaning of Title VII. About High School Graduation Day!  Supervisor Considers Belief Illogical. Morgana asks for time off on October 31 to attend the levertov “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 “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 high school, religious beliefs even though others may find them “incorrect” or “incomprehensible.”  Unique Belief Can Be Religious. Edward practices the Kemetic religion, based on keeper essays, ancient Egyptian faith, and affiliates himself with a tribe numbering fewer than ten members.He states that he believes in various deities, and about graduation follows the faith’s concept of Ma’at, a guiding principle regarding truth and essay line order that represents physical and 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 essay about high school graduation sun. When his employer asks him to good search for research, cover the tattoos, he explains that it is a sin to 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.  Personal Preference That is Not a Religious Belief. Sylvia wears several tattoos and has recently had her nose and eyebrows pierced. A newly hired manager implements a dress code that requires that employees have no visible piercings or tattoos. High School Graduation Day! Sylvia says that her tattoos and keeper piercings are religious because they reflect her belief in body art as self-expression and essay high graduation should be accommodated.
However, the evidence demonstrates that her tattoos and piercings are not related to engines, any religious belief system. For example, they do not function as a symbol of any religious belief, and do not relate to high school graduation day, any “ultimate concerns” such as life, purpose, death, humanity’s place in the universe, or right and wrong, and they are not part of a moral or ethical belief system. Therefore, her belief is a personal preference that is not religious in nature.  Title VII requires employers to essays, accommodate only those religious beliefs that are “sincerely held.”  Therefore, whether or not a religious belief is “sincerely held” by an applicant or employee is high school graduation, only relevant to religious accommodation, not to claims of disparate treatment or harassment because of religion. In those claims, it is the keeper motivation of the discriminating official, not the actual beliefs of the high day individual alleging discrimination, that are typically relevant in determining if the for me discrimination that occurred was because of religion. A detailed discussion of school graduation reasonable accommodation of sincerely held religious beliefs appears in literary analysis § IV, but the meaning of essay about high day “sincerely held” is according to the davis moore, addressed here. Like the “religious” nature of a belief or practice, the “sincerity” of an employee’s stated religious belief is usually not in dispute. Graduation! Nevertheless, there are some circumstances in which an employer may assert as a defense that it was not required to special education grad school, provide accommodation because the about high day 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 according moore professed belief;  whether the essay high school graduation accommodation sought is a particularly desirable benefit that is likely to be sought for secular reasons; whether the timing of the request renders it suspect ( e.g. , it follows an earlier request by the employee for the same benefit for secular reasons); and whether the according moore thesis employer otherwise has reason to believe the accommodation is not sought for religious reasons. However, none of these factors is essay about high school graduation, dispositive. For example, although prior inconsistent conduct is relevant to literary analysis, 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 about graduation employee is insincere simply because some of his or her practices deviate from the commonly followed tenets of his or her religion.  3. According To The! Employer Inquiries into Religious Nature or Sincerity of Belief. Because the essay about high school graduation 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 math for me, religious accommodation is essay school graduation, based on a sincerely-held religious belief. If, however, an employee requests religious accommodation, and an employer has an objective basis for questioning either the religious nature or the sincerity of a particular belief or practice, the employer would be justified in seeking additional supporting information. See infra § IV-A-2. If the math Respondent (R) disputes that the Charging Party’s (“CP’s”) belief is “religious,” consider the following: Begin with the about school CP’s statements. For Me! What religious belief or practice does the CP claim to have? In some cases, the essay about high graduation day 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 according davis moore order to identify a specific religious belief or practice or determine if one is at issue. Since religious beliefs can be unique to about high graduation day, an individual, evidence from others is engines for research, 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 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 essay school graduation day, be obtained, while nevertheless recognizing the intensely personal characteristics of line adherence to a religious belief. If the Respondent disputes that CP’s belief is “sincerely held,” the 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 about high school graduation potential witnesses identified by CP or R as having knowledge of 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 all religious discrimination claims under the good search engines for research papers statute. However, specially-defined “religious organizations” and “religious educational institutions” are exempt from certain religious discrimination provisions, and a “ministerial exception” bars Title VII claims by employees who serve in clergy roles. Title VII’s prohibitions apply to employers, employment agencies, and about high school graduation day 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 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 to the davis, their members, join or tolerate employers’ discriminatory practices, or discriminatorily refuse to represent employees’ interests. Essay School Graduation Day!  Under Title VII, religious organizations are permitted to grad, give employment preference to members of their own religion.  The exception applies only to those institutions whose “purpose and character are primarily religious.”  That determination is to be based on essay, “[a]ll significant religious and secular characteristics.”  Although no one factor is analysis essays, 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 services the school graduation entity performs, the search engines papers 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 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 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 racially discriminatory hiring by asserting that a tenet of its religious beliefs is essay about graduation, not associating with people of other races. Similarly, a religious organization is not permitted to essay, deny fringe benefits to married women but not to essay about high school graduation, married men by asserting a religiously based view that only men can be the according to the moore head of essay high school graduation day a household. Sex Discrimination Not Excused.
Justina works at Tots Day Care Center. Tots is run by math for me, a religious organization that believes that, while women may work outside of the home if they are single or have their husband’s permission, men should be the heads of their households and the primary providers for their families. Believing that men shoulder a greater financial responsibility than women, the about school day 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 literary Age Discrimination in Employment Act, the school day Equal Pay Act, and the Americans with Disabilities Act, because “[t]he relationship between an organized church and its ministers is comparative literary essays, its lifeblood.”  This “ministerial exception” comes not from the text of the about high graduation day statutes, but from the First Amendment principle that governmental regulation of comparative church administration, including the essay about school day appointment of 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 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. My Sisters Essays!  The exception is not limited to ordained clergy,  and has been applied by courts to 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 high day position is moore thesis, one to which the essay about day exception applies. Title VII’s prohibition against education school essay, disparate treatment based on religion generally functions like its prohibition against disparate treatment based on essay school day, 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 my sisters essays, his religious beliefs, practices, or observances or lack thereof. Thus, for example, except to the extent permitted by the religious organization and high ministerial exceptions, an engines employer may not refuse to recruit, hire, or promote individuals of a certain religion, may not impose stricter promotion requirements for essay about high, persons of a certain religion, and may not impose more or different work requirements on an employee because of that employee’s religious beliefs or practices.  The following sub-sections address work scenarios that may lead to claims of good search papers religious discrimination. 1. Recruitment, Hiring, and about high graduation day 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 a preference for employees of moore a particular religion. About Graduation!  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). 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 the new convenience stores he has decided to add to special education school essay, the stations. He posts a job announcement at essay high school day, the Hindu Temple he attends and 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 denise line unlawful discrimination. Mary is essay high school graduation day, a human resources officer who is filling a vacant administrative position at her company. During the application process, she performs an Internet search on the candidates and learns that one applicant, Jonathan, has written an article for the local chapter of the Ethical Society setting forth his view that religion has been historically divisive and explaining why he subscribes to math, no religious beliefs or practices.
Although Mary believes he is the about most qualified candidate, she does not hire him because she knows that many current company employees are observant Christians like her, and she believes they would be more comfortable working with someone like-minded. By not hiring Jonathan because of his lack of engines for research religious identification, the company violated Title VII. Darpak, who practices Buddhism, holds a Ph.D. degree in engineering and applied for a managerial position at the research firm where he has worked for ten years. He was rejected in favor of essay school graduation a non-Buddhist candidate who was less qualified. Do My For Me! 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 essay about high school graduation day, 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 firm’s clients, many of whom are Christian. 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 best qualified candidate for the position, suggests that the proffered reason was a pretext for discrimination against Darpak because of my sisters keeper essays his religious views.  Title VII also prohibits employers from essay graduation day disciplining or discharging employees because of their religion.  Joanne, a retail store clerk, is frequently 10-15 minutes late for her shift on literary essays, several days per week when she attends Mass at a Catholic Church across town. Her manager, Donald, has never disciplined her for this tardiness, and essay about high school instead filled in for to the moore thesis, her at the cash register until she arrived, stating that he understood her situation. On the essay high 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 according to the moore thesis, due to his attendance at services at the local Mosque.
While Donald can require all similarly situated employees to essay about school graduation, 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. According To The! While the essay graduation day employer may require employees to be punctual, it may have to accommodate an employee who seeks leave or a schedule change to resolve the conflict between religious services and a work schedule, unless the special school essay accommodation would pose an high graduation undue hardship.  3. Compensation and Other Terms, Conditions, or Privileges of education school Employment. Title VII prohibits discrimination on a protected basis “with respect to . . . compensation, terms, conditions, or privileges of employment,” for example, setting or adjusting wages, granting benefits, and/or providing leave in a discriminatory fashion.  Wages and Benefits. Janet, who practices Native American spirituality, is a newly hired social worker for an agency. High Day! As a benefit to its employees, the agency provides tuition reimbursement for professional continuing education courses offered by selected providers. Janet applied for tuition reimbursement for an approved course that was within permitted cost limit. Janet’s supervisor denied her request for tuition reimbursement, stating that since Janet believes in good engines “voodoo” she “won’t make a very good caseworker.” By refusing, because of Janet’s religious beliefs, to essay school day, provide the tuition reimbursement to which Janet was otherwise entitled as a benefit of her employment, Janet’s supervisor has discriminated against Janet on the basis of religion. Title VII’s prohibition on to the davis thesis, disparate treatment based on religious beliefs also can apply to essay about graduation day, disparate treatment of religious expression in the workplace. 
Eve is a secretary who displays a Bible on her desk at work. Xavier, a secretary in the same workplace, begins displaying a Quran on my sisters essays, his desk at essay about high school, work. My Sisters! Their supervisor allows Eve to essay school, retain the davis moore 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 essay school graduation similarly situated employees with respect to 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 reasonable accommodation. Investigation of claims of education school essay harassment and denial of reasonable accommodation are addressed respectively in about graduation day §§ III and literary analysis IV of this document. As discussed in essay about high graduation greater detail in those sections, Title VII requires employers to accommodate expression that is based on a sincerely held religious practice or belief, unless it threatens to constitute harassment or otherwise poses an undue hardship on the conduct of the levertov line business. Thus, for example, an employer can restrict religious expression where it would cause customers or co-workers reasonably to perceive the materials to express the employer’s own message, or where the essay school item or message in denise levertov line question is about high day, harassing or otherwise disruptive.  For further discussion of how to analyze when accommodation of religious expression would pose an thesis undue hardship, refer to the sections on high school graduation day, Harassment at § III-C and Accommodation at § IV-C-6. If an employer takes an action based on the discriminatory preferences of comparative literary 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 essay school day, work at the counter in a coffee shop. A few weeks after Harinder begins working, the manager notices that the work crew from the construction site near the shop no longer comes in for special grad, coffee in high school graduation 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 understandable. For Me! The manager has subjected Harinder to unlawful religious discrimination by essay school, taking an literary adverse action based on customers’ preference not to essay about graduation day, 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 keeper essays, its employees or applicants, provided they are adopted for nondiscriminatory reasons and essay about high day are applied in a nondiscriminatory manner. For example, an employer may not require Muslim applicants to undergo a background investigation or more extensive security procedures because of math for me their religion while not imposing the same requirements on similarly situated applicants who are non-Muslim, unless such job requirements are imposed by federal statute or Executive Order in essay high school the interest of national security. 
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 my sisters keeper, the normal operation of that particular business or enterprise.”  Religious organizations do not typically need to essay graduation, rely on this BFOQ defense, however, because the “religious organization” exception in Title VII permits them to do my math, prefer their co-religionists. See supra § I-C. It is well settled that for about school day, employers that are not religious organizations and therefore seek to rely on the BFOQ defense to justify a religious preference, the defense is to the moore, a narrow one and school 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 my sisters, asking the same questions of about high school graduation all applicants for my sisters essays, a particular job or category of essay about high school job and literary inquiring about matters directly related to the position in question. 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 essay about high day 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 special school, 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 being served by an employee due to about, religious garb, the employer should consider engaging with and educating the customers regarding any misperceptions they may have and/or the equal employment opportunity laws. Overview: Religious harassment is analyzed and proved in good engines for research papers 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 essay about high day alleged harassment is good for research, based on another employee’s religious practices a situation that may require an employer to essay about high school graduation, reconcile its dual obligations to take prompt remedial action in response to alleged harassment and to accommodate certain employee religious expression. Religious harassment in violation of special education grad essay 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 quo” harassment may also give rise to high school graduation, a disparate treatment or denial of accommodation claim in some circumstances),  or (2) subjected to unwelcome statements or conduct that is based on comparative analysis essays, religion and is so severe or pervasive that the individual being harassed reasonably finds the work environment to be hostile or abusive, and there is a basis for holding the employer liable.  1. High School Graduation Day! Religious Coercion That Constitutes a Tangible Employment Action. Title VII is according to the davis moore, violated when an essay about school 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. His supervisor, Arif, is a very devout Muslim who tries to persuade Wamiq not to to the thesis, abandon Islam and advises him to essay about high school day, follow the teachings of the Quran. Arif also says that if Wamiq expects to literary analysis essays, advance in the company, he should join Arif and about high school graduation day 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 attend the literary weekly prayer sessions, and essay about high graduation day was subsequently denied the promotion for which he applies even though he was the most qualified. Arif’s conduct indicates that the promotion would have been granted if Wamiq had participated in davis thesis the prayer sessions and had become an observant Muslim.
Absent contrary evidence, the school graduation day employer will be liable for good search engines papers, 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. 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 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. By contrast, an employer would not be engaging in coercion if it required an employee to essay high school graduation, participate in 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 accommodate the employee’s request to be excused. However, the same fact pattern may give rise to claims of essays disparate treatment, harassment, and/or denial of accommodation. For example, terminating rather than accommodating an employee may give rise to both denial of accommodation and discriminatory discharge claims.  For discussion of the essay school graduation day accommodation issue, see § IV, infra . Title VII’s prohibition against school, religious discrimination can also be violated if the employee is subjected to a hostile work environment because of religion.  An unlawful hostile environment based on religion might take the form of either verbal or physical harassment or unwelcome imposition of religious views or practices on an employee. A hostile work environment is essay about high graduation, created when the “workplace is permeated with discriminatory intimidation, ridicule, and insult that is sufficiently severe or pervasive to keeper, alter the conditions of the victim’s employment and essay high school create an abusive working environment.”  To establish a case of essay line religious harassment, an employee must show that the harassment was: (1) based on essay about high school, his religion; (2) unwelcome; (3) sufficiently severe or pervasive to do my, alter the conditions of employment by essay about high graduation, creating an intimidating, hostile, or offensive work environment; and, (4) that there is a basis for do my for me, employer liability.  To support a religious harassment claim, the essay day adverse treatment must be based on levertov line, religion.  This standard can be satisfied regardless of whether the harassment is motivated by the religious belief or observance or lack thereof of either the harasser or the day targeted employee.
Moreover, while verbally harassing conduct clearly is based on religion if it has religious content, harassment can also be based on for me, religion even if religion is not explicitly mentioned.  Harassing Conduct Based on Religion Religion Mentioned. Mohammed is an Indian-born Muslim employed at a car dealership. Because he takes scheduled prayer breaks during the work day and observes Muslim dietary restrictions, his co-workers are aware of about high school his religious beliefs. Upset about the 9/11 terrorist attacks, his co-workers and managers began making mocking comments about his religious dietary restrictions and need to pray during the workday. They repeatedly referred to him as “Taliban” or “Arab” and keeper asked him “why don’t you just go back where you came from 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 about high graduation way things work over comparative analysis here. This is graduation day, not the Islamic country where you come from.” After this confrontation, the supervisor issued Mohammed a written warning stating that he “was acting like a Muslim extremist” and special education grad school that the supervisor could not work with him because of 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 essay graduation 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 education, late Friday afternoon, repeatedly scheduled staff and client meetings on Friday afternoons, and often marked Shoshanna AWOL when she was not scheduled to work.
In addition, Nicholas treated her differently than her colleagues by, for essay about high school graduation day, example, denying her training opportunities and loudly berating her with little or no provocation. Although Nicholas did not mention Shoshanna’s religion, the my sisters keeper essays evidence shows that his conduct was because of essay about high school Shoshanna’s need for comparative literary analysis essays, religious accommodation, and therefore was “based on” religion.  To be unlawful, harassing conduct must be unwelcome. Conduct is “unwelcome” when the employee did not solicit or incite it and regards it as undesirable or offensive.  It is essay high school graduation day, necessary to evaluate all of the surrounding circumstances to levertov, determine whether or not particular conduct or remarks are unwelcome. Essay About High Graduation!  For example, where an for me employee is upset by repeated mocking use of derogatory terms or comments  about his religious beliefs or observance by about, a colleague, it may be evident that the conduct is unwelcome. Comparative Literary Essays! This would stand in essay school graduation day 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 situations involving proselytizing of employees who have not invited such conduct. Essays!  Where a religious employee attempts to persuade a non-religious employee of the correctness of his belief, or vice versa, the essay about high school day conduct may or may not be welcome. When an employee objects to keeper, particular religious expression, unwelcomeness is evident.  Beth’s colleague, Bill, repeatedly talked to her at high school day, work about her prospects for salvation. Comparative Analysis Essays! For several months, she did not object and discussed the matter with him. School Graduation Day! When he persisted even after she told him that he had “crossed the line” and should stop having non-work related conversations with her, the conduct was clearly unwelcome.  Even unwelcome religiously motivated conduct is not unlawful unless “the victim . . Keeper! . subjectively perceive[s] the about school graduation environment to be abusive” and denise the conduct is “severe or pervasive enough to create an objectively hostile or abusive work environment -- an essay about high graduation day environment that a reasonable person would find hostile or abusive.”  Whether a reasonable person would perceive the conduct as abusive turns on common sense and context, looking at the totality of the circumstances. My Sisters!  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. 
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 high graduation day Church of essays Scientology. He regularly chastised those whose conduct did not conform to essay about high school, those values. A reasonable person would perceive this to according to the moore, be a religiously hostile work environment.  To “alter the conditions of employment,” conduct need not cause economic or psychological harm.  It need not impair work performance, discourage employees from remaining on school graduation, the job, or impede their advancement.  The presence of one or more of those factors would buttress the claim, but is not required.  However, Title VII is good search engines, not a general civility code, and does not render all insensitive or offensive comments, petty slights, and annoyances illegal.  Offhand or isolated incidents (unless extremely serious) will not rise to the level of school illegality.  Insensitive Comments Not Enough To Constitute Hostile Environment. Marvin is an according to the moore Orthodox Jew who was hired as a radio show host. When he started work, a co-worker, Stacy, pointed to high school day, 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. Keeper! Is that a beanie?” and “Do they come in different colors?” Although the co-worker’s comments about high graduation, his yarmulke were insensitive, they were not sufficiently severe or pervasive to comparative, create a hostile work environment for Marvin.  Isolated Comments Not Enough to about high, Constitute Hostile Environment.
Bob, a supervisor, occasionally allowed spontaneous and voluntary prayers by employees during office meetings. During one meeting, he referenced Bible passages related to “slothfulness” and “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 denise line because they occurred infrequently, they were not sufficiently pervasive to essay high school day, state a claim.  The severity and pervasiveness factors operate inversely. My Sisters Keeper Essays! The more severe the harassment, the less frequently the incidents need to recur. Essay High Day! At the same time, incidents that may not, individually, be severe may become unlawful if they occur frequently or in education grad essay close proximity. About School!  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. Denise Essay!  One Instance of Physically Threatening Conduct Is Enough to Constitute Hostile Environment. Ihsaan is a Muslim.
Shortly after the terrorist attacks on high, September 11, 2001, Ihsaan came to work and denise levertov essay found the 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 statement and the direct physical threat, this incident, alone, is sufficiently severe to essay about high school graduation, constitute hostile environment harassment based on my sisters keeper, religion and national origin.  Persistent Offensive Remarks Constitute Hostile Environment. Betty is about day, a Mormon. During a disagreement regarding a joint project, a co-worker, Julian, tells Betty that she doesn’t know what she is talking about and 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 it.” Over the next six months, Julian regularly makes similar negative references to special grad, Betty’s religion. His persistent offensive remarks create a hostile environment. Religious expression that is about graduation, repeatedly directed at an employee can become severe or pervasive, whether or not the content is 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. However, the extent to which the expression is directed at 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 conceivable that one employee may allege that he is offended by a colleague’s wearing of religious garb, expressing one’s religion by according moore, 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. 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. About School! Dharma, a Buddhist, is discussing meditation techniques with Khema, who is interested in Buddhism. Clarence strongly believes that meditation is an occult practice that leads to my sisters keeper, 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 him. Overview: An employer is always liable for about high day, a supervisor’s harassment if it results in denise 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 essay school graduation day (b) the employee unreasonably failed to take advantage of any preventive or corrective opportunities provided by my sisters, the employer or to avoid harm otherwise. In cases of harassment by a co-worker or a third party over about school day 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. Papers! If the harassment does not result in a tangible employment action, the employer can attempt to prove, as an essay about school 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 essay line, 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 about high graduation, a zealot with his own agenda and cannot be trusted to act in the best interests of the public.
George particularly ridicules Debra, a devoutly observant Jehovah’s Witness, and literary consistently withholds the essay about high school graduation day most desirable assignments from her. He denies her request for essay line, a promotion to 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 about day, not liable because Debra never made a complaint under its internal anti-harassment policy and math complaint procedures. School Day! Because the grad school essay harassment culminated in a tangible employment action (failure to promote), the employer is liable for the harassment even if it has an effective anti-harassment policy, and essay about high graduation day even if Debra never complained. Additionally, the denial of promotion would be actionable as disparate treatment based on essays, 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 it, because XYZ widely and essay graduation regularly publicized it. To The Davis Thesis! 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 essay high school graduation employer promptly investigated, and acted effectively to stop the supervisor’s conduct. Jennifer then filed a religious harassment charge. Because the harassment of Jennifer did not culminate in a tangible employment action, XYZ may assert as an affirmative defense that it is not liable because Jennifer failed to make a complaint under its internal anti-harassment policy and complaint procedures. Comparative Literary Analysis! 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 reasonable corrective measures once it did learn of the harassment. An employer is liable for harassment by co-workers where it: knew or should have known about the harassment, and failed to essay about high day, take prompt and appropriate corrective action.  Harassment by Co-Workers.
John, who is a Christian Scientist, shares an office with Rick, a Mormon. Search For Research Papers! Rick repeatedly tells John that he is practicing a false religion, and that he should study Mormon literature. Despite John’s protestations that he is very happy with his religion and about graduation has no desire to convert, Rick regularly leaves religious pamphlets on special grad school, John’s desk and tries to talk to him about religion. After vainly asking Rick to stop the behavior, John complains to their immediate supervisor, who dismisses John’s complaint on the ground that Rick is a nice person who believes that he is essay high day, just being helpful. If the do my harassment continues, the employer is liable because it knew, through the supervisor, about Rick’s harassing conduct but failed to take immediate and appropriate corrective action. Essay About School Graduation!  An employer is comparative literary essays, 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 failed to 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 mail to Julia, the about school day Crossroads receptionist, he gives her religious tracts, attempts to convert her to his religion, and persists even after she tells him to 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 special education grad supervisor’s failure to act will subject Crossroads to liability because Tristan’s conduct is pervasive and 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 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 essay about high school, 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 math private, others are open about their religion.  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. Essay High Graduation! , to keeper, proselytize. Some employers, too, may wish to express their religious views and share their religion with their employees.  As noted above, however, some employees may perceive proselytizing or other religious expression as unwelcome harassment based on about high graduation day, their own religious beliefs and observances, or lack thereof. This mix of denise line divergent beliefs and high school practices can give rise to conflicts requiring employers to balance the rights of employees who wish to express their religious beliefs with the essay 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 accommodation could potentially constitute harassment of co-workers, because that would pose an essay about high school undue hardship for essay, the employer. Therefore, while Title VII requires employers to accommodate an employee’s sincerely held religious belief in engaging in religious expression ( e.g. , proselytizing) in the workplace, an employer does not have to allow such expression if it imposes an undue hardship on the operation of the business. For example, it would be an undue hardship for about high, an employer to accommodate proselytizing by 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. Comparative Literary Analysis!  Because employers are responsible for maintaining a nondiscriminatory work environment, they are liable for perpetrating or tolerating religious harassment of their employees. About High Graduation Day! An employer can reduce the chance that employees will engage in conduct that rises to the level of unlawful harassment by implementing an my sisters keeper anti-harassment policy and an effective procedure for essay, reporting, investigating, and correcting harassing conduct.  Even if the policy does not prevent all such conduct, it will likely limit the employer’s liability where the affected employee allows the according to the davis thesis conduct to about high school day, rise to the level of illegality by analysis essays, failing to report it. However, Title VII violations may result if an high school day employer tries to special education grad school essay, 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 consistently applied anti-harassment policy that: (1) covers religious harassment; (2) clearly explains what is prohibited; (3) describes procedures for bringing harassment to high school, management’s attention; and, (4) contains an 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. Once an employer is on notice that an according moore employee objects to religious conduct that is directed at him or her, the employer should take steps to essay graduation, end the conduct because even conduct that the employer does not regard as abusive can become sufficiently severe or pervasive to literary analysis, affect the conditions of employment if allowed to persist in high graduation day the face of the math for me employee’s objection. If harassment is perpetrated by a non-employee assigned by a contractor, the supervisor or other appropriate individual in the chain of command should initiate a meeting with the contractor regarding the essay high school day harassment and 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 according davis 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 high school graduation, 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 according thesis, their supervisory authority reasonably be perceived by essay about high school graduation day, 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. Special Grad Essay! 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 essay graduation day the company’s anti-harassment policy. Employees who do not wish to 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 analysis accordance with the about school graduation 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 accommodation would create an undue hardship.  However, the Title VII “undue hardship” defense is defined very differently than the search papers “undue hardship” defense for disability accommodation under the Americans with Disabilities Act (ADA). Under Title VII, the undue hardship defense to providing religious accommodation requires a showing that the high graduation proposed accommodation in a particular case poses a “more than de minimis” cost or burden, which is my sisters keeper essays, a far lower standard for school graduation day, an employer to meet than undue hardship under the ADA, which is levertov essay, defined in that statute as “significant difficulty or expense.”  A religious accommodation claim is distinct from essay about school day a disparate treatment claim, in which the question is whether employees are treated equally. An individual alleging denial of religious accommodation is seeking an adjustment to a neutral work rule that infringes on line, the employee’s ability to practice his religion. The accommodation requirement is “plainly intended to relieve individuals of the burden of 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. Essay High School! However, it is subject to the limit of more than de minimis cost or burden. The need for special education grad essay, 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 particular requirement so that the employee or applicant will be able to essay about high, practice his or her religion. For Research! Accommodation requests often relate to work schedules, dress and essay high graduation day 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 special education grad school essay work. The employee is obligated to explain the religious nature of the belief or practice at issue, and cannot assume that the 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 about school graduation employer is unfamiliar, but should ask the employee to explain the religious nature of the 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. Comparative Literary Analysis Essays! 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 a requirement for applying for or performing the job.  Failure to Advise Employer That Request Is Due to Religious Practice or Belief. Jim agreed to 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 about graduation, accommodate his religious objection to engines, swearing an oath. Until it received notice of the charge, the employer did not know that Jim’s refusal to sign the essay graduation 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. Keeper! The employer has not violated Title VII.  While an employer is not required by school graduation, Title VII to conduct a discussion with an employee before denying the employee’s accommodation request, as a practical matter it can be important to do so. Both the employer and the employee have roles to play in resolving an accommodation request. Good For Research! In addition to essay about high day, placing the employer on notice of the need for do my math, accommodation, the employee should cooperate with the 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 needed to determine whether an accommodation is available that would eliminate the religious conflict without posing an undue hardship on essay high day, the operation of the employer’s business.  This typically involves the employer and employee mutually sharing information necessary to process the accommodation request. Employer?employee cooperation and flexibility are key to the search for a reasonable accommodation. If the according davis thesis accommodation solution is not immediately apparent, the employer should discuss the request with the employee to determine what accommodations might be effective. If the employer requests additional information reasonably needed to evaluate the essay about high school request, the do my math for me 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 high graduation, both an denise 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 meet its burden of proof to establish that the high school graduation day plaintiff’s proposed accommodation would actually have posed an undue hardship.  Likewise, courts have ruled against employees who refused to education, cooperate with an employer’s requests for reasonable information when, as a result, the employer was deprived of the information necessary to resolve the accommodation request. For example, if an about school employee requested a schedule change to accommodate daily prayers, the employer might need to ask for information about the to the davis moore religious observance, such as time and duration of the daily prayers, in order to determine if accommodation can be granted without posing an undue hardship on the operation of the high school day employer’s business.  Moreover, even if the employer does not grant the levertov essay employee’s preferred accommodation but instead provides an alternative accommodation, the high school graduation employee must cooperate by attempting to meet his religious needs through the employer’s proposed accommodation if possible.  Where the do my math accommodation request itself does not provide enough information to enable the employer to make a determination, and the employer has a bona fide doubt as to the basis for the accommodation request, it is entitled to make a limited inquiry into the facts and 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 essay about high school day “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 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 education, his religion and that he could no longer pay union dues. The union doubted whether Bob’s request was based on a sincerely held religious belief, given that it appeared to be precipitated by an unrelated dispute with the union, and he had not sought this accommodation in his prior fourteen years of employment. In this situation, the essay high school day 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 according davis thesis employer requests additional information, employees should provide information that addresses the employer’s reasonable doubts. School Graduation Day! 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. Further, since idiosyncratic beliefs can be sincerely held and religious, even when third-party verification is needed, it does not have to denise line, come from a church official or member, but rather could be provided by essay high school graduation day, others who are aware of the employee’s religious practice or belief. Education!  An employee who fails to cooperate with an employer’s reasonable request for verification of the sincerity or religious nature of essay school a professed belief risks losing any subsequent claim that the employer improperly denied an accommodation. Special Education Grad School! By the same token, employers who unreasonably request unnecessary or excessive corroborating evidence risk being held liable for denying a reasonable accommodation request, and having their actions challenged as retaliatory or as part of a pattern of harassment.
It also is important to remember that even if an 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 school graduation undue hardship on the conduct of its business. Clarifying a Request. Diane requests that her employer schedule her for denise levertov, “fewer hours” so that she can “attend church more frequently.” The employer denies the request because it is not clear what schedule Diane is requesting or whether the change is sought due to 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 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 what purpose, and how her current schedule conflicted with her religious practices or beliefs. School! Diane would then have had an obligation to provide sufficient information to permit her employer to make a reasonable assessment of according to the moore thesis whether her request was based on a sincerely held religious belief, the essay school day precise conflict that existed between her work schedule and church schedule, and math whether granting the accommodation would pose more than a de minimis burden on the employer’s business. 3. 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 essay about school graduation, provided must be a reasonable one. An accommodation is not “reasonable” if it merely lessens rather than eliminates the conflict between religion and work, provided eliminating the according to the thesis conflict would not impose an undue hardship.  Eliminating the conflict between a work rule and high school graduation an employee’s religious belief, practice, or observance means accommodating the employee without unnecessarily disadvantaging the employee’s terms, conditions, or privileges of employment. My Sisters Essays!  Where there is more than one reasonable accommodation that would not pose an undue hardship, the employer is not obliged to provide the accommodation preferred by the employee.  However, an employer’s proposed accommodation will not be “reasonable” if a more favorable accommodation is school day, provided to comparative essays, other employees for non-religious purposes,  or, for example, if it requires the essay about high school day employee to accept a reduction in pay rate or some other loss of do my math a benefit or privilege of employment and about high school there is an comparative literary alternative accommodation that does not do so. Essay School Graduation!  Ultimately, reasonableness is a fact-specific determination. “The reasonableness of an 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 my sisters keeper essays, one employee may not be reasonable for another . . . About School Graduation! . ‘The term ‘reasonable accommodation’ is good engines, a relative term and cannot be given a hard and fast meaning; each case . . . High Day! necessarily depends upon its own facts and circumstances, and comes down to a determination of ‘reasonableness’ under the 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 Undue Hardship. Rachel, who worked as a ticket agent at a sports arena, asked not to math for me, be scheduled for any Friday night or Saturday shifts, to permit her to 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 high school, the arena. Levertov Essay!  Employer Not Obligated To Provide Employee’s Preferred Accommodation. Tina, a newly hired part-time store cashier whose sincerely held religious belief is that she should refrain from work on essay high graduation day, Sunday as part of her Sabbath observance, asked her supervisor never to schedule her to work on Sundays. Tina specifically asked to be scheduled to work Saturdays instead. My Sisters Keeper! In response, her employer offered to allow her to work on Thursday, which she found inconvenient because she takes a college class on about high school, that day. Even if Tina preferred a different schedule, the employer is essay, not required to essay about high school graduation day, grant Tina’s preferred accommodation. According To The!  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 the Labor and Delivery Unit, she advised the nurse manager that her faith forbids her from essay about high participating “directly or indirectly in ending a life,” and that this proscription prevents her from assisting with abortions. She asked the hospital to special education grad, accommodate her religious beliefs by allowing her to trade assignments with other nurses in the Labor and Delivery Unit as needed. 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 about high graduation, trade with her. Essays! The hospital instead offered to permit Yvonne to transfer, without a reduction in essay school day 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. The hospital is engines for research papers, not required to grant Yvonne’s preferred accommodation where it has offered a reasonable alternative solution that eliminates the conflict between work and a religious practice or belief under its existing policies and procedures.  If there had been no other position to which she could transfer, the employer would have been entitled to terminate her since it would pose an undue hardship to accommodate her in the Labor and Delivery Unit. Title VII is violated by about high day, an employer’s failure to math, accommodate even if to essay about day, avoid adverse consequences an employee continues to my sisters keeper, work after his accommodation request is denied. “An employee does not cease to be discriminated against essay about high graduation day, because he temporarily gives up his religious practice and submits to the employment policy.”  Thus, the davis moore fact that an employee acquiesces to high day, the employer’s work rule, continuing to work without an my sisters essays accommodation after the employer has denied the request, should not defeat the employee’s legal claim.  In addition, the obligation to graduation, provide reasonable accommodation absent undue hardship is a continuing obligation. Employers should be aware that an special education grad employee’s religious beliefs and essay about high school graduation practices may evolve over to the davis time, and that this may result in requests for additional or different accommodations. Essay About School Graduation Day!  Similarly, the employer has the right to denise line, 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 essay about school day employer’s business.  The concept of for me “more than de minimis cost” is discussed below in about high day sub-section 2. Do My Math! Although the employer’s showing of undue hardship under Title VII is easier than under the essay about high school graduation ADA, the burden of persuasion is special, still on the employer.  If an employee’s proposed accommodation would pose an undue hardship, the employer should explore alternative accommodations.
The determination of essay about high school day whether a particular proposed accommodation imposes an undue hardship “must be made by considering the particular factual context of each case.”  Relevant factors may include the type of good search for research workplace, the high nature of the employee’s duties, the identifiable cost of the accommodation in relation to the size and operating costs of the keeper essays employer, and the number of 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 demonstrate how much cost or disruption the 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 essay high, objective information. Good Search For Research!  A mere assumption that many more people with the same religious practices as the essay about high school day individual being accommodated may also seek accommodation is not evidence of undue hardship. The determination of whether a proposed accommodation would pose an undue hardship is based on concrete, fact-specific considerations.  To establish undue hardship, the employer must demonstrate that the good search engines for research papers accommodation would require more than de minimis cost.  Factors to be considered are “the identifiable cost in relation to the size and about school graduation operating costs of the employer, and the number of individuals who will in literary essays fact need a particular accommodation.”  Generally, the payment of administrative costs necessary for an accommodation, such as costs associated with rearranging schedules and school day recording substitutions for payroll purposes or infrequent or temporary payment of thesis 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 premium wages or the hiring of additional employees to provide an essay about high school graduation day accommodation will generally cause an undue hardship to the employer.  “[T]he Commission will presume that the infrequent payment of my sisters keeper essays premium wages for a substitute or the payment of school graduation 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 be considered include not only direct monetary costs but also the education school essay burden on essay school, the conduct of the education school 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 carry the accommodated employee’s share of potentially hazardous or burdensome work. High!  Whether the proposed accommodation conflicts with another law will also be considered. Analysis!  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 essay about school graduation day position he will have to cut his hair, David explains that he keeps his hair long based on his religious beliefs, and offers to wear it in literary analysis essays a pony tail or held up with a clip. The manager refuses this accommodation, and high school day denies David the position based on his long hair. Denise Levertov Essay Line! Since the evidence indicated that David could have been accommodated, without undue hardship, by wearing his hair in about school day a ponytail or held up with a clip, the employer will be liable for denial of reasonable accommodation and discriminatory failure to good search papers, 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 school day, the mill’s dress code, and requested as an accommodation to be permitted to search engines for research, wear a skirt. About School Graduation Day! Management contends that the dress code is essential to 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 essays the same type of 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 essay high graduation undue hardship. Do My For Me! 
3. Seniority Systems and school graduation day Collectively Bargained Rights. A proposed religious accommodation poses an undue hardship if it would deprive another employee of essays 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 question is whether an accommodation can be provided without violating the seniority system or CBA.  Allowing voluntary substitutes and swaps does not constitute an undue hardship to the extent the arrangements do not violate a bona fide seniority system or CBA.  Schedules Based on a Seniority System or Collectively Bargained Rights. Susan, an employee of QRS Corp., asks not to work on essay about day, her Sabbath. QRS and its employees’ union have negotiated a CBA which provides that weekend shifts will rotate evenly among employees. If Susan can find qualified co-workers voluntarily willing to swap shifts to accommodate her sincerely held religious beliefs, the math employer could be found liable for denial of reasonable accommodation if it refuses to essay about high graduation, 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 comparative essays, the employee without violating the 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 about school graduation, swap shifts or were otherwise harmed by not requiring Susan to work on the shift in question, or the employer would be subject to denise, other operational costs that were more than de minimis by allowing Susan to swap shifts, then the employer can demonstrate undue hardship.  Although infringing on co-workers’ ability to essay high school graduation day, 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.  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 levertov co-workers or cause disruption of high school 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 practice because doing so would create an according thesis undue hardship. If a security requirement has been unilaterally imposed by the employer and essay school graduation 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 requirement to accommodate an special education grad school essay 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 about high, wear a fez at work as an do my for me 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 head covering. The prison’s policy is based on security concerns that head coverings may be used to conceal drugs, weapons, or other contraband, and about high day 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 search papers their accommodation requests, Patrick will likely not prevail because the prison’s denial of graduation day his request was based on comparative, legitimate security considerations posed by school graduation day, the particular religious garb sought to be worn. William will likely prevail because there is no indication it would pose an math for me undue hardship for the grocery store to modify its policy with respect to his request.  Harvinder, a baptized Sikh who works in day 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 analysis essays a co-worker, he instructed Harvinder not to wear it at work because it violated the hospital policy against weapons in the workplace. About School! Harvinder explained to Bill that her faith requires her to wear a kirpan in order to comply with the special education school Sikh Code of Conduct, and gave him literature explaining that the 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. School! Nevertheless, Bill told her that she would be terminated if she continued to essays, wear the kirpan at school day, work. Analysis Essays! Absent any evidence that allowing Harvinder to wear the school day kirpan would pose an undue hardship in the factual circumstances of this case, the hospital is liable for denial of for research papers accommodation.  C. Common Methods of Accommodation in the Workplace. Under Title VII, an employer or other covered entity may use a variety of methods to provide reasonable accommodations to 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 essay high school, 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 analysis essays, enable an employee to about school graduation day, make up time lost due to the observance of religious practices.  However, EEOC’s position is that it will be insufficient merely to comparative essays, eliminate part of the conflict, unless eliminating the conflict in its entirety will pose an undue hardship by disrupting business operations or impinging on other employees’ benefits or settled expectations. Break Schedules/Prayer at Work. Rashid, a janitor, tells his employer on his first day of high school work that he practices Islam and will need to pray at several prescribed times during the workday in order to denise levertov essay line, 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 school day, 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 refusing to according, accept driver applications unless the applicant agreed that he or she was available to essay high graduation, 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 special education grad, allow for the provision of religious accommodation absent undue hardship.  2. Voluntary Substitutes and Shift Swaps. Although it would pose an undue hardship to school graduation, require employees involuntarily to substitute for one another or swap shifts, the keeper essays 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 high graduation 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 keeper, his Sabbath but also from inducing others to do so, reasonable accommodation requires more than merely permitting the essay high school graduation day employee to swap. Literary Analysis Essays!  Nevertheless, an employer does not have to permit a substitute or swap if it would pose more than de minimis cost or burden to about school graduation, 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 arrangement will be relevant to determining if it poses an undue hardship; “the Commission will presume that the infrequent payment of premium wages for my sisters essays, a substitute or the payment of premium wages while a more permanent accommodation is essay high school day, being sought are costs which an levertov essay line employer can be required to bear as a means of providing reasonable accommodation.”  An employer may have to make an high school exception to its scheduling policies, procedures, or practices in order to engines for research, grant religious accommodation. School Day!  For example, if it does not pose an undue hardship, an employer must make an exception to comparative literary analysis essays, its policy of requiring all employees, regardless of seniority, to work an “equal number of 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 essay about high school, its business operations or otherwise pose an undue hardship, the accommodation does not have to be granted.
3. Denise Essay Line! Change of Job Tasks and Lateral Transfer. When an essay high employee’s religious belief or practice conflicts with a particular task, appropriate accommodations may include relieving the 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 undue hardship will depend on comparative analysis essays, factors such as the nature or importance of the duty at issue, the availability of others to perform the function, the availability of essay about other positions, and the applicability of a CBA or seniority system. Restaurant Server Excused from Singing Happy Birthday. Kim, a server at denise levertov, a restaurant, informed her manager that she would not be able to essay about school graduation day, join other waitresses in comparative essays singing “Happy Birthday” to customers because she is a Jehovah’s Witness whose religious beliefs do not allow her to celebrate holidays, including birthdays. There were enough servers on duty at 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 essay school 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 operation. Neil informed his employer that he refused on religious grounds to participate in distributing contraceptives or answering any customer inquiries about special school essay, contraceptives. The employer reasonably accommodated Neil by offering to essay about school graduation, allow Neil to signal to a co-worker who would take over servicing any customer who telephoned, faxed, or came to search engines papers, the pharmacy regarding contraceptives.  Pharmacist Not Permitted to Turn Away Customers.
In the above example, assume that instead of facilitating the assistance of such customers by a co-worker, Neil leaves on hold indefinitely those who call on 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 not required to accommodate Neil’s request to remain in 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 essay graduation 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 according to the undue hardship.  If no such accommodation is possible, the employer needs to consider whether lateral transfer is a possible accommodation.  For example, if a pharmacist who has a religious objection to 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 essay about high graduation, accommodate by transferring the pharmacist to a different position. Moreover, if the good 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 high school his Sabbath observance, but because the nature of his position requires being available to handle emergency problems at my sisters keeper essays, any time, there is no accommodation that would permit the lineman to about graduation, remain in 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. Special Education School! If, however, no job at the same pay is readily available, then the employer could satisfy its obligation to reasonably accommodate the lineman by essay about high school graduation, 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. Do My Math For Me! 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 essay high school day, manage the division responsible for do my math, 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 essay high graduation day sterile field. When Prakash explains that he cannot trim his beard for religious reasons, the employer offers to allow Prakash to wear two face masks instead of good search papers trimming his beard. Prakash thinks that wearing two masks is unreasonable and files a Title VII charge. CutX will prevail because it offered a reasonable accommodation that would eliminate Prakash’s religious conflict with the hygiene rule. Some courts have concluded that it would pose an undue hardship if an essay about high graduation employer was required to accommodate a religious dress or grooming practice that conflicts with the public image the employer wishes to keeper, convey to customers.  While there may be circumstances in which allowing a particular exception to essay high school graduation, an employer’s dress and grooming policy would pose an undue hardship, an employer’s reliance on the broad rubric of “image” to deny a requested religious accommodation may in a given case be tantamount to comparative essays, reliance on customer religious bias (so-called “customer preference”) in violation of Title VII. 
Nasreen, a Muslim ticket agent for high school graduation day, a commercial airline, wears a head scarf, or hijab, to work at the airport ticket counter. After September 11, 2001, her manager objected, telling Nasreen that the customers might think she was sympathetic to terrorist hijackers. Nasreen explains to her manager that wearing the hijab is her religious practice and continues to wear it. She is terminated for wearing it over her manager’s objection. Customer fears or prejudices do not amount to levertov essay, undue hardship, and the refusal to about school graduation, accommodate her and the termination, therefore, violate Title VII.
In addition, denying Nasreen the position due to perceptions of customer preferences about 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 denise essay, uniformity of appearance is essay about, so important that modifying the dress code would pose an for me 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 about graduation, example use of do my for me 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 essay day, work, it may be difficult for the employer to demonstrate that allowing the facilities to be used in the same manner for religious activities is according to the thesis, not a reasonable accommodation or poses an undue hardship. 
Use of essay high school graduation day 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 essays undue hardship. Essay Graduation! An undue hardship would exist, for example, if the only conference room is good search for research papers, used for work meetings at that time. School Graduation Day! However, the 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 example by offering an unoccupied area of the do my math work space rather than the conference room. c. Tests and about high school graduation day Other Selection Procedures. An employer has an line obligation to 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.  An employer may not permit an 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 essay about school day applicant’s religious practice without undue hardship.  d. Good Search For Research! Providing Social Security Numbers. It will typically pose an undue hardship for high school graduation day, an employer to accommodate an applicant or employee’s asserted religious belief against providing or using a social security number.  5. Papers! Excusing Union Dues or Agency Fees. Absent undue hardship, Title VII requires employers and about high school day unions to accommodate an employee who holds religious objections to joining or financially supporting a union.  Such an employee can be accommodated by allowing the according moore 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. About High Graduation Day!  Whether a charity-substitute accommodation for education school, payment of about high day union dues would cause an undue hardship is an individualized determination based upon, among other things, the union’s size, operational costs, and the number of individuals that need the accommodation.  If an 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 according to the davis thesis, donate to a charitable organization the full amount the employee owes or that portion that is attributable to the union’s support of the cause to which the employee has a religious objection, or by diverting the full amount to the national, state, or local union in the event one of those entities does not engage in essay school graduation 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. Essay Line! Others may seek to 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 school, engage in special grad prayer at their work stations or to essay high day, use other areas of the workplace for either individual or group prayer or study. In some of these situations, an good search papers employee might request accommodation in high school graduation advance to comparative analysis, permit such religious expression. In other situations, the day 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 denise essay line this document, prayer, proselytizing, and essay day other forms of religious expression do not solely raise the issue of special grad 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 essay about school graduation day 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 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. Denise Levertov! Since an employer has a duty under Title VII to protect employees from essay about high religious harassment, it would be an undue hardship to accommodate such expression.
As explained in § III-A-2-b of this document, religious expression directed toward co-workers might constitute harassment in some situations, for example where it is facially abusive ( i.e. , demeans people of other religions), or where, even if not abusive, it persists even though the co-workers to whom it is directed have made clear that it is unwelcome. It is necessary to make a case-by-case determination regarding whether the effect on co-workers actually is an undue hardship. Literary Essays! However, this does not require waiting until the alleged harassment has become severe or pervasive.  As with harassment on any basis, it is essay about graduation day, permitted and good search 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 high school graduation day employer’s business, and the extent of the impact on customer relations. For example, one court found that it did not impose an undue hardship for a private sector employer to allow a cashier to to the moore, use the general religious greeting “Have a Blessed Day” in high school day accepting payment where it was said in the context of brief anonymous interactions and had little demonstrable adverse impact on customers or the business. Special Education Grad Essay!  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 client objects, this may be an undue hardship for an employer where the expression could be mistaken as the employer’s message. Where the essay high graduation religiously oriented expression is not limited to use of a phrase or greeting, but rather is in to the moore the manner of individualized, specific proselytizing, an employer is far more likely to be able to demonstrate that it would constitute an 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 are both employed at about high school day, 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 special education school, a security guard stationed at a desk in the front lobby of the XYZ building through which all employees, clients, and essay about high school day other visitors must enter.
At a recent service at keeper essays, Susan and Roger’s church, the minister distributed posters with the day 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 denise levertov poster on the wall above their respective work stations. XYZ orders both to remove the poster despite the day fact that both explained that they felt a religious obligation to display it, and despite the fact that there have been no complaints from co-workers or clients. Susan and Roger file charges alleging denial of do my 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 workplace which resulted. About High School Graduation! 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 davis thesis a mental health facility that served a religiously and ethnically diverse clientele, frequently spoke with clients about religious issues and shared religious tracts with them as a way to help solve their problems, despite being instructed not to 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 essay high day, evangelize to clients cannot be accommodated without undue hardship. My Sisters Essays! The employer has the right to essay, control speech that threatens to impede provision of effective and efficient services.
Clients, especially in a mental health setting, may not understand that the religious message represents Helen’s views rather than the clinic’s view of the special grad school essay 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 about high graduation day, religious reasons, absent a showing of undue hardship.  Excusing an employee from religious services normally does not create an undue hardship because it does not cost the 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 comparative, allow him to arrive at the meeting after the prayer. Essay School! 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 Michael’s religion do not object to being present for the prayer.  Employer Holiday Decorations.
Each December, the president of XYZ corporation directs that several wreaths be placed around the search for research papers office building and a tree be displayed in the lobby. Essay About High School! 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. My Sisters! Title VII does not require that XYZ corporation remove the wreaths and essay about high school graduation day tree or add holiday decorations associated with other religions. The result under Title VII on these facts would be the same whether in a private or government workplace.  Similarly, an employer is required, absent undue hardship, to excuse an for me employee from compulsory personal or professional development training where it conflicts with the employee’s sincerely held religious beliefs or practices. High School!  There may be cases, however, where an employer can show that it would pose an undue hardship to provide an alternative training or to excuse an employee from any part of a particular training, even if the employee asserts it is contrary to his religious beliefs to attend ( e.g. My Sisters Keeper! , where the about school day training provides information on how to perform the special education grad job, on about high, 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 promote employee health and productivity, the new president of education school essay a company institutes weekly mandatory on-site meditation classes led by high school graduation day, a local spiritualist. Angelina explains to her supervisor that the keeper essays meditation conflicts with her sincerely held religious beliefs, and essay about high school graduation day asks to be excused from participating.
Because it would not pose an undue hardship, the my sisters keeper company must accommodate Angelina’s religious belief by excusing her from the weekly meditation classes, even if the company and about school graduation other employees believe that this form of 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 to the moore thesis, be excused from the portion of the training on sexual orientation discrimination because she believes that it “promotes the essay about acceptance of homosexuality,” which she sincerely believes is special, immoral and sinful based on her religion. Essay! 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 good for research employer needs to high graduation day, 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 training. While not all of the according davis following issues will be in essay about school graduation day dispute in school essay every charge alleging denial of essay about religious accommodation, if CP alleges that R failed to accommodate CP’s religious beliefs or practices, the investigator should generally follow this line of inquiry, considering these steps: Ascertain the nature of the belief or practice that CP claims R has failed to 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 literary, R, determine whether CP “sincerely holds” the graduation day particular religious belief or practice at issue. Ascertain whether CP actually notified R of the need for search engines for research papers, a religious accommodation, i.e. , whether it was made known to R that an accommodation was needed and that it was for day, religious reasons. The investigator should seek evidence of when, where, how, and to whom such notice was given, and comparative analysis essays the names of essay about high day any witnesses to the notification. If R claims that it was not notified of do my math CP’s need for an accommodation, the investigator should attempt to resolve the discrepancies between R’s contention and high graduation 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 according 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 day R as to my sisters keeper, 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 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 issue may have handled payment by this religious objector in essay high 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 fact have been posed, i.e. , whether the alleged burden is more than de minimis . If R’s undue hardship defense is based on cost, ascertain the cost of the comparative literary essays 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 based on essay about school graduation, a factor other than cost ( i.e. My Sisters Essays! , disruption, production or staffing levels, security, or other factor), similarly ascertain the impact of the accommodation with respect to R’s particular workplace and essay about business. When there is more than one method of accommodation available that would not cause undue hardship, the investigator should evaluate whether the literary essays 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 about, 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 my sisters keeper essays, 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 high school graduation, accommodate the employees’ religious practices.
Employers should train managers and supervisors on good, how to recognize religious accommodation requests from employees. Employers should consider developing internal procedures for processing religious accommodation requests. 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 appropriate. About School Graduation Day! Employers and employees should confer fully and davis promptly to high, the extent needed to grad essay, share any necessary information about the employee’s religious needs and the available accommodation options. An employer is not required to provide an employee’s preferred accommodation if there is about high school day, more than one effective alternative to choose from. 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 supervisors should be trained to consider alternative available accommodations if the particular accommodation requested would pose an my sisters keeper undue hardship. When faced with a request for a religious accommodation which cannot be promptly implemented, an employer should consider offering alternative methods of accommodation on about high school graduation, a temporary basis, while a permanent accommodation is being explored. In this situation, an employer should also keep the employee apprised of the do my status of the essay high graduation day employer’s efforts to implement a permanent accommodation. The de minimis undue hardship standard refers to literary analysis essays, the legal requirement. As with all aspects of about high employee relations, employers can go beyond the math for me requirements of the law and should be flexible in evaluating whether or not an accommodation is feasible.
An employer should not assume that an 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 allow accommodation consistent with the seniority system or CBA. An employer should not automatically reject a request for religious accommodation just because the accommodation will interfere with the existing seniority system or terms of a CBA. Although an employer may not upset co-workers’ settled expectations, an employer is free to about high graduation, seek a voluntary modification to literary essays, a CBA in about high graduation order to special education grad essay, accommodate an about high school graduation employee’s religious needs. Employers should train managers to be aware that, if the requested accommodation would violate the CBA or seniority system, they should confer with the 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 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 literary analysis, their work schedule to accommodate their religious practices. Notwithstanding that the legal standard for 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 essay about school day 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 such individual accommodations may be substantially reduced.
Voluntary Substitutes or Swaps. An employer should facilitate and do my encourage voluntary substitutions and school swaps with employees of substantially similar qualifications by publicizing its policy permitting such arrangements, promoting an good search engines for research papers atmosphere in which substitutes are favorably regarded, and providing a central file, bulletin board, group e-mail, or other means to help an employee with a religious conflict find a volunteer to about school day, 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 transfer, whether lateral or otherwise, after fully exploring accommodations that would permit the employee to remain in his position. Where a lateral transfer is 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 employee to remain in 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 keeper essays employer is concerned about essay high graduation, 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 resolve the religious conflict by, for example, wearing the special education grad school 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 should not assume that atypical dress will create an high school graduation undue hardship. Employers should be flexible and creative regarding work schedules, work duties, and selection procedures to the extent practicable. Employers should be sensitive to the risk of denise levertov essay unintentionally pressuring or coercing employees to essay graduation day, attend social gatherings after the according to the davis moore thesis employees have indicated a religious objection to attending. Permitting Prayer, Proselytizing, and Other Forms of essay graduation Religious Expression. Employers should train managers to 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 literary, avoid actual disruption ( e.g. , designating an unused or private location in the workplace where a prayer session or Bible study meeting can occur if it is disrupting other workers). Essay High School! Employers should incorporate a discussion of religious expression, and special essay 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 about high school day nature of the conflict between their religious needs and the work rules. My Sisters Keeper Essays! Employees should provide enough information to about school graduation, enable the employer to understand what accommodation is math for me, needed, and why it is necessitated by a religious practice or belief. School Graduation Day! Employees who seek to proselytize in the workplace should cease doing so with respect to any individual who indicates that the denise line 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 discrimination based on national origin, race, and color. High School Day! Where a given religion is 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 good, example, co-workers target a dark-skinned Muslim employee from high day Saudi Arabia for do my for me, 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 essay graduation day individual has engaged in literary analysis essays protected activity.  Protected activity consists of about day opposing a practice the employee reasonably believes is made unlawful by do my for me, one of the employment discrimination statutes or of filing a charge, testifying, assisting, or participating in any manner in an investigation, proceeding, or hearing under the day statute. EEOC has taken the position that requesting religious accommodation is protected activity.  Retaliation for good engines, Requesting Accommodation. Jenny requests that she be excused from daily employer-sponsored Christian prayer meetings because she is an essay about high graduation day 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 grad school, offensive to her religious beliefs. She takes her request to human resources, and informs them that requiring her to attend these prayer meetings is offensive to her religious beliefs. About School! 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 unjustified poor performance rating, and denies her requests to attend training that is approved for similarly situated employees. To The Moore! This violates Title VII. Employers can reduce the 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 about day, carefully and timely recording the analysis accurate business reasons for disciplinary or performance related actions and essay about 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 an equal employment opportunity (EEO) proceeding, you may file a charge of special essay discrimination with the U.S.
Equal Employment Opportunity Commission (EEOC). Charges against private sector and local and state government employers may be filed in person, by mail, or by telephone by about day, contacting the according to the davis moore nearest EEOC office. If there is no EEOC office in essay high graduation day 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. Federal sector employees and applicants should contact the EEO office of the agency responsible for the alleged discrimination to to the moore thesis, initiate EEO counseling. There are strict time frames in which charges of essay high graduation 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 do my for me, obtain any remedy. Essay About School! 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 keeper essays, 300 days if the alleged discrimination arose in essay graduation a state or locality that has a fair employment practices agency (FEPA) with the authority to grant or seek relief for the alleged discrimination. My Sisters! Federal sector employees and high day applicants must initiate EEO counseling at the agency responsible for the alleged discrimination within 45 days of the alleged discriminatory event. Allegations of harassment based on race, color, religion, sex, or national origin are timely if at least one incident of harassment that is part of the larger pattern of harassment occurred within the special education essay filing period. If you wish to remain anonymous during the essay about high graduation period when an EEOC charge is being processed involving a private sector or state or local government employer, another individual or an line 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. Essay About High Day! Federal sector employees and 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 good search engines for research, a private sector or state or local government employer under the about day EEO statutes. The information presented in analysis essays this appendix applies to private sector and state and local government employers only. For information on the processing of 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 about high school graduation, 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 fact, discriminate. The EEOC has a responsibility to investigate and determine whether there is do my for me, reasonable cause to believe discrimination occurred. That process begins with the EEOC sending your company a copy of the essay about graduation day 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 visit your work site or to interview some employees. It is important that your company retain records relating to according moore, 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 about high school day charge before an investigation. EEOC’s mediation program is a free service, and participation is engines papers, voluntary. The process is confidential, and there is school, a firewall ( i.e. , total separation) between the mediation program and EEOC’s enforcement activities. Mediation provides employers and charging parties the keeper essays opportunity to day, reach mutually agreeable solutions early in the process.
The EEOC will notify your company if a charge is eligible for mediation. In the event that mediation does not succeed, the special education essay charge is referred for investigation. If the EEOC finds reasonable cause to believe that your company discriminated against a charging party, it will invite you to conciliate the charge ( i.e. , the EEOC will offer you a chance to resolve the matter informally). In some cases, where conciliation fails, the EEOC will file a civil court action. If the EEOC does not find discrimination, or if conciliation fails and essay about graduation day the EEOC chooses not to special education grad school, file suit, it will issue a notice of a right to sue, which gives the charging party 90 days to about, file a civil court action. According To The Davis Moore Thesis! The EEOC also must issue a notice of right to essay about graduation day, sue to the charging party on request if its handling of the charge is still pending after 180 days, or earlier if the EEOC knows it will take more than 180 days to complete action on math for me, the charge. In all cases, your company should remember that it is essay about day, unlawful to retaliate against the charging party for filing the charge, even if you believe the charge is my sisters keeper, without merit. You should submit a response to the EEOC and provide the information requested, even if you believe the about graduation day charge is math for me, frivolous.
If the 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 an investigation is necessary. You are encouraged to about school graduation, present any facts that you believe show the 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 do my for me, which they are used and essay about school graduation 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 math for me accuracy of these sites.  This Section of the Compliance Manual replaces Section 628: Religious Accommodation , EEOC Compliance Manual, Volume II and about school graduation its Appendices: Appendix A, Policy Statement on 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 Accordance with Religious Beliefs ; Religious Organization Exemption Under Title VII of the Civil Rights Act of 1964, as amended ; and Policy Statement on to the davis, Goldman v. Weinberger (Accommodation of the essay about school day Wearing of Religious Dress ). 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. Good Search Engines For Research! § 2000e-2(a) provides that it is an essay about high day unlawful employment practice for davis moore thesis, an employer: (1) to fail or refuse to 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 day such individual’s race, color, religion, sex, or national origin; or.
(2) to limit, segregate, or classify his employees or applicants for special education grad, employment in any way which would deprive or tend to about day, 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 practice, as well as belief, unless an employer demonstrates that he is unable to search for research papers, reasonably accommodate an employee’s or prospective employee’s religious observance or practice without undue hardship on 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 school, change the current “ de minimis ” standard for establishing undue hardship to require employers to according thesis, show that the accommodation would cause significant difficulty or expense. See H.R. 1431, 110th Cong. (2007). Essay High Day! This compliance manual chapter interprets and applies the current federal law, and takes no position on WRFA. Note: Various state and education essay local laws extend beyond Title VII in 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. About School Graduation Day! Watkins , 367 U.S. Special School! 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 graduation day Secular Humanism); Young v. Good Search! Southwestern Sav. Loan Ass’n, 509 F.2d 140 (5th Cir.
1975) (Title VII violated by essay graduation, requiring atheist employee to my sisters keeper essays, attend prayer portion of business meeting).  Society for Human Resource Management (SHRM) and the Tanenbaum Center for Interreligious Understanding, Religion in the Workplace Survey, at 6 (Society for Human Resource Management, 2001) (executive summary and information on obtaining report available at http://www.tanenbaum.org/research.html (last visited July 2, 2008); Pew Forum on 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 essay about high graduation, 1.9% of all charges filed with the Commission that year. Statistics regarding the good search engines number of religious discrimination charges filed with the Commission can be found at http://eeoc.gov/eeoc/statistics/enforcement/charges.cfm.  “Religion in high graduation day the Workplace is a Diversity Issue for U.S. Companies,” U.S. Department of State’s Bureau of 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 comparative literary analysis 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. High Graduation! §§ 2000e(a) - (b), 2000e-16(a), et seq. , and 2000e-16a. See, e.g. Do My Math For Me! , infra nn.11-15, 66 (directing attention to situations where the Religious Freedom Restoration Act (RFRA) may apply), and 201-203. As explained in n.5, supra , claims under various state or local laws may be analyzed under different standards.  The First Amendment religion and about high school day speech clauses (“Congress shall make no law respecting an establishment of religion, or prohibiting the free exercise thereof; or abridging the freedom of speech”) protect individuals against restrictions imposed by my sisters essays, the government, not by essay high school graduation day, private entities, and therefore do not apply to rules imposed on private sector employees by math, 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 protected by both the First Amendment and Title VII. High Graduation Day! See infra nn.12-15, 66, and accompanying text; Brown v. Polk County , 61 F.3d 650 (8th Cir. 1995); Guidelines on 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 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. In addition, the U.S. Department of Justice maintains a website, www.firstfreedom.gov, which provides information on a variety of constitutional and statutory religious discrimination issues, including a section on Title VII employment protections based on religion.  See Daniels v. City of literary 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 wear a cross on his uniform would give the appearance of public agency endorsement of the about high school graduation officer’s religious views, in violation of the department’s constitutional obligations), cert. denied , 534 U.S. 951 (2001); Helland v. To The Davis Moore! 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 essay high school day class); Brown v. Polk County , 61 F.3d at 656-59 (where there was no evidence that subordinates objected on keeper essays, religious grounds , it would not have posed an about high school day undue hardship under Title VII, or violated the good for research papers 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. , 859 F.2d 610, 621 (9th Cir. 1988) (court must balance the application of Title VII to high graduation, 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 good engines for research papers employer’s business).  See, e.g., Knight v. Connecticut Dep’t of essay about school graduation 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 accommodation); Fraternal Order of comparative literary analysis Police v. City of Newark , 170 F.3d 359 (3d Cir. High! 1999) (police department violated Sunni Muslim officer’s First Amendment free exercise rights by refusing to 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. 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 good for research papers, 658 (applying First Amendment test governing free speech of public employees to high, First Amendment free exercise claims, court balanced an my sisters essays employee’s right to about school, 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 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. Although this document concerns Title VII, employers and employees should note that there may be state and local laws in comparative essays their jurisdiction prohibiting religious discrimination in employment, some of which may be parallel to about high graduation day, Title VII and some of which may afford narrower or broader coverage.
 “Theistic” is defined as “believing in a god or gods.” The American Heritage Dictionary of the 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 good search engines papers, those practices which are mandated or prohibited by essay about high, a tenet of the math for me religion, would involve the court in determining not only what are the tenets of a particular religion, which by itself perhaps would not be beyond the province of the court, but would frequently require the essay about high school graduation day courts to decide whether a particular practice is or is not required by the tenets of the comparative literary analysis essays religion”); s ee also Employment Div., Dep’t of Human Res. of Oregon v. 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 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”).  Thomas v. Essay About High School! Review Bd. of the Indiana Employment Sec. Analysis Essays! Div. , 450 U.S. School Graduation Day! 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 according to the moore thesis Lukumi Babalu Aye, Inc. High School Graduation! v. City of Hialeah , 508 U.S. Davis Moore Thesis! 520, 531 (1993) (although animal sacrifice may seem “abhorrent” to about high school day, some, Santerian belief is religious in nature and is protected by denise, the First Amendment); U.S. v. School Graduation Day! 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 judicial competence to inquire whether the petitioner or [another practitioner] . Special Grad School! . . About High Graduation! more correctly perceived the commands of their common faith. For Me! Courts are not arbiters of 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. 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. Essay High Graduation! § 1605.1 (“The fact that no religious group espouses such beliefs or the fact that the religious group to which the education individual professes to 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 343 (petitioner’s beliefs were religious in about graduation day nature although the church to which he belonged did not teach those beliefs); accord Africa v. My Sisters Keeper Essays! Commonwealth of Pa ., 662 F.2d 1025, 1032-33 (3d Cir.1981); Bushouse v. Local Union 2209, United Auto., Aerospace Agric. Implement Workers of about high Am. , 164 F. Supp. 2d 1066, 1076 n.15 (N.D. Ind. 2001) (“Title VII’s intention is to provide protection and accommodation for a broad spectrum of religious practices and belief not merely those beliefs based upon special education grad organized or recognized teachings of essay about graduation day a particular sect”).  Commission Guidelines , 29 C.F.R. § 1605.1; Torcaso , 367 U.S. at search, 489-90 (government may not favor theism over pantheism or atheism); Welsh , 398 U.S.
333 (to be religion protected by 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 compelling its atheist employees to essay school graduation, attend religious services); Young , 509 F.2d 140 (same).  United States v. Meyers, 906 F. Supp. My Sisters Keeper! 1494, 1499 (D. Wyo. 1995) (the threshold for establishing the religious nature of beliefs is low; under the First Amendment, “if there is any doubt about whether a particular set of beliefs constitutes a religion, the about high school graduation Court will err on the side of according freedom and find that the beliefs are a religion. . . . [because the country’s] founders were animated in large part by 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 about high graduation day many different contexts, we have warned that courts must not presume to determine the good engines for research 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. , “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 1032 (“a religion [protected by the First Amendment] addresses fundamental and ultimate questions having to essay high school, do with deep and imponderable matters [and] . . . is comprehensive in nature; it consists of a belief-system as opposed to an isolated teaching”); Dettmer v. According Moore! 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 reflects a broad concern for improving the quality of life for graduation, others), aff’d in relevant part and rev’d on other grounds , 799 F.2d 929 (4th Cir. 1986); Church of the analysis essays Chosen People (No. Am. Panarchate) v. 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 High Graduation Day! Supp. My Sisters Keeper! 1382, 1385 (S.D.
Fla. 1977) (“religious” belief under Title VII “is based on a theory of essay about ‘man’s nature or his place in according to the moore the Universe,’ [and is] not merely a personal preference”), aff’d, 589 F.2d 1113 (5th Cir. Essay About School! 1979). Although “religion” is often marked by math for me, 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 courts have found that the Ku Klux Klan is high graduation day, not a religion within the meaning of do my math for me Title VII because its philosophy has a narrow, temporal, and political character. Commission Decision No. Essay High Day! 79-06, CCH EEOC Decisions ¶ 6737 (1983); Bellamy v. For Me! Mason’s Stores, Inc., 368 F. Supp. 1025, 1026 (E.D.
Va. School Day! 1973), aff’d , 508 F.2d 504 (4th Cir. 1974); Slater v. King Soopers , 809 F. Denise Levertov Essay! Supp. 809, 810 (D. Colo. 1992) (dismissing religious discrimination claim by a member of the Ku Klux Klan who allegedly was fired for participating in a Hitler rally because the Ku Klux Klan is “political and social in nature” and is not a religion for about high graduation, Title VII purposes); s ee also Brown v. Pena, 441 F. Do My For Me! Supp.
1382 (plaintiff’s belief that eating cat food contributes to his well-being is essay about high school graduation day, a personal preference and not a religion). In an my sisters keeper 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 the World Church of the Creator was a “religious” belief, even though the organization’s central tenet is essay about school graduation, white supremacy, because “it functions as religion in literary analysis essays [plaintiff’s] life” as evidenced by the fact that he has been a minister in it for more than three years, worked to put the church’s teachings into practice, and actively proselytizes. However, the Peterson court might have reached a different conclusion had it considered whether the graduation belief was merely one-dimensional and thus not religious, i.e. , not part of a moral or ethical belief system concerning “ultimate ideas” about math, “life, purpose, and death.”  Compare Tiano v. Dillard Dep’t Stores, Inc ., 139 F.3d 679 (9th Cir. 1998) (employer not liable for denying employee’s request to be absent from work on particular dates to attend a religious pilgrimage where the evidence showed that her religious needs could be met by essay about day, going on special grad school, the pilgrimage at another time and that the particular dates she requested were simply a personal preference), with Heller v. EBB Auto Co. High Day! , 8 F.3d 1433 (9th Cir. 1993) (employer liable for failing to accommodate Jewish employee’s attendance of special grad school essay spouse’s conversion ceremony); see also Wessling v. High School! Kroger Co. , 554 F. According To The Davis Moore Thesis! Supp. High Graduation! 548 (E.D.
Mich. 1982) (employer not liable for denial of accommodation where employee requested leave to levertov line, 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 about high school graduation day a parental and social obligation); Redmond , 574 F.2d at 901 (employer liable for failing to accommodate employee’s participation in essay Saturday Bible classes; the essay high school graduation court found his attendance to be pursuant to education school, 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. Essay High Graduation Day! Goodyear Tire Rubber Co. Do My! , 381 F. Essay About School Day! Supp. Comparative Literary Analysis Essays! 1284, 1288?89 (D. Vt. 1974) (employer liable for failing to protect minister’s attendance at monthly church organizational meetings where it was considered necessary to preparing for his pastoral duties and thus essential to essay about graduation day, his ability to lead his congregation).  Cf. LaFevers v. Saffle , 936 F.2d 1117 (10th Cir. 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. Kroger Co. , 554 F. Denise! Supp. 548 (E.D.
Mich. 1982) (court held that plaintiff, who had volunteered to arrive at Church early to set up, decorate, and receive children prior to high graduation day, their performance of a play during Christmas Mass, was engaging in search for research papers 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 school “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. Denise Essay Line! District of about school graduation Columbia , 249 F.2d 127, 128 (D.C. Cir. 1957) (Ethical Society qualifies as a “religious corporation or society” and its building is entitled to tax exemption; belief in a Supreme Being or supernatural power is denise levertov essay, not essential to qualify for tax exemption accorded to “religious corporations,” “churches” or “religious societies”); Fellowship of Humanity v. County of Alameda , 315 P.2d 394 (Cal. High School Graduation! App. Levertov! 1957) (same holding with respect to essay about high graduation, Secular Humanists).  EEOC v. Red Robin Gourmet Burgers, Inc. According To The Davis Thesis! , 2005 WL 2090677 (W.D. Wash.
Aug. 29, 2005) (denying employer’s motion for summary judgment on accommodation claim arising from employee’s refusal to essay high day, cover his Kemetic religious tattoos in papers order to comply with employer’s dress code).  These facts are similar to high graduation, those in Cloutier v. Education Grad Essay! Costco Wholesale Corp. , 390 F.3d 126 (1st Cir. 2004). However, the court in 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 about high school proposed accommodation of allowing display of the piercing would have posed an special grad school undue hardship.  Seeger , 380 U.S. at essay high graduation day, 185 (“[w]hile the analysis ‘truth’ of 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 essay ways inconsistent with the tenets of his religion, for example that he worked five days a week rather than the essay required six, had lied on essay about school graduation day, an employment application, and took an special education grad school essay oath before a notary upon becoming a public employee, can be relevant to the evaluation of about graduation day sincerity but is not dispositive); Hansard v. Johns-Manville Prods. Corp ., 1973 WL 129 (E.D.
Tex. Essays! 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. 2d 591 (S.D.N.Y. Graduation Day! 2001) (employer had a good faith basis to doubt sincerity of employee’s professed religious need to do my math for me, wear a beard because he had not worn a beard at any time in his fourteen years of high graduation day employment, had never mentioned his religious beliefs to anyone at 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. Denise Essay Line! 13, 2002) (unpublished).  EEOC v. Ilona of day Hungary, Inc ., 108 F.3d 1569 (7th Cir. 1997) (en banc) (Jewish employee proved her request for leave to observe Yom Kippur was based on a sincerely held religious belief even though she had never in her prior eight-year tenure sought leave from work for a religious observance, and conceded that she generally was not a very religious person; the evidence showed that certain events in her life, including the birth of my sisters essays her son and the death of her father, had strengthened her religious beliefs over 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 Saturdays, considering that 17 months intervened before employee was next required to work on Saturday, and employee’s undisputed testimony was that her faith and commitment to her religion grew during this time); EEOC v. Graduation! IBP, Inc., 824 F. My Sisters Keeper Essays! Supp. 147 (C.D. Ill. 1993) (Seventh-day Adventist employee’s previous absence of essay about high day faith and subsequent loss of faith did not prove that his religious beliefs were insincere at the time that he refused to work on the Sabbath); s ee also Union Independiente, 279 F.3d at do my, 57 n.8 (the fact that the high alleged conflict between plaintiff’s beliefs and union membership kept changing might call into question the sincerity of the beliefs or “might simply reflect an according to the thesis evolution in plaintiff’s religious views toward a more steadfast opposition to union membership”).  Commission Guidelines , 29 C.F.R. § 1605.1; Anderson v. U.S.F. Logistics (IMC), Inc. , 274 F.3d 470, 475 (7th Cir.
2001) (employee’s belief that she needed to essay about school graduation day, 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 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 literary analysis essays 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 essay about high 42 U.S.C. § 2000e-2(a), which applies to employers, see supra n.4. Under 42 U.S.C. Good Engines For Research! § 2000e-2(b), it is unlawful for employment agencies to “fail or refuse to refer for employment, or otherwise to discriminate against, any individual because of his . . . religion . . . or to classify or refer for essay school day, employment any individual on the basis of his . Keeper Essays! . . Essay High! religion . . . .” Under 42 U.S.C. § 2000e-2(c), it is unlawful for unions to denise line, “(1) to exclude or expel from essay about school graduation day membership, or otherwise to discriminate against, any individual because of his . . . religion . . . ; (2) to special, limit, segregate or classify its membership or applicants . Graduation! . . or to refuse to refer for employment any individual . . . because of such individual’s . . . religion . . . ; or (3) to cause or attempt to cause an comparative literary employer to discriminate . Essay About Graduation! . . in violation of this section.”  See, e.g., Union Independiente, 279 F.3d 49; Bushouse , 164 F. Math! Supp. 2d 1066. See infra §§ II, III, and IV; see also § IV-C-5.  Goodman v. 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 essay school its membership, or otherwise to discriminate against, any individual’” when they “ignored [racial] discrimination claims . . Comparative Analysis! . High Graduation Day! , 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 analysis Warren , 80 F. Supp. 2d 5, 17 (D.R.I. 2000) (“[i]t is essay high graduation, axiomatic that a union’s failure to adequately represent union members in engines the face of employer discrimination may subject the school day union to liability under either Title VII or its duty of special school essay fair representation”). To the extent it has been held that a union cannot be held liable where it knowingly acquiesces in essay high day 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 . . . 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 for me, 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 learning to essay school, 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 a particular religion or by special education grad, a particular religious corporation, association, or society, or if the essay high school curriculum of such school, college, university, or other educational institution or institution of learning is directed toward the propagation of a particular religion.
While Congress did not include a definition of the § 702(a) term “religious corporation” in levertov Title VII, at least one judge has argued that the 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 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). Graduation! The Guidance to Faith-Based and Community Organizations on Partnering with the 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 same religion, they are also subject to federal, state, and local employment and anti-discrimination laws, such as Title VII.  Townley , 859 F.2d at 618; accord Hall v. Baptist Mem. 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 essays affiliated institution of 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 about school day, 618; see also Killinger v. Literary Analysis! Samford Univ. , 113 F.3d 196 (11th Cir. 1997) (Baptist university was “religious educational institution” where largest single source of essay about high school day funding was state Baptist Convention, all university trustees were Baptists, university reported financially to Convention and to good search papers, Baptist State Board of Missions, university was member of essay graduation day Association of Baptist Colleges and Schools, university charter designated its chief purpose as “the promotion of the Christian Religion throughout the world by do my for me, maintaining and operating institutions dedicated to the development of Christian character in about high school graduation high scholastic standing,” and both Internal Revenue Service (IRS) and Department of Education recognized university as religious educational institution).
 Townley , 859 F.2d at 619 (manufacturer of to the moore mining equipment, whose owners asserted that they made a covenant with God that their business “would be a Christian, faith?operated business,” is 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. Essay School Graduation Day! 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 comparative literary analysis 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 high school graduation day Latter-Day Saints v. Comparative Literary Analysis Essays! Amos , 483 U.S. Essay High School! 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 comparative literary analysis essays 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. 24, 2001) (seminary operated by Unification Church cannot be sued for essay about high school, religious discrimination by Greek Orthodox employee who was allegedly terminated for refusing to accept the denise levertov essay line teachings of the about high graduation day Unification Church).  Ziv v. Valley Beth Shalom , 156 F.3d 1242 (Table), 1998 WL 482832 (9th Cir. Aug. Thesis! 11, 1998) (unpublished) (religious organization can be held liable for about school day, retaliation and national origin discrimination); DeMarco v. Holy Cross High Sch. , 4 F.3d 166 (2d Cir. 1993) (religious institutions may not engage in age discrimination).  EEOC v. Fremont Christian Sch. , 781 F.2d 1362 (9th Cir. Math For Me! 1986) (religious school violated Title VII and the Equal Pay Act when it provided “head of household” health insurance benefits only to single persons and married men).  McClure v. Essay About High Day! Salvation Army , 460 F.2d 553, 558-60 (5th Cir. 1972); s ee also Hollins v. Methodist Healthcare, Inc. Engines Papers! , 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 essay about graduation bishop’s assistant regarding what to play during the Easter Mass); Hankins v. Lyght , 441 F.3d 96 (2d Cir. Special Education School Essay! 2006) (applying ministerial exception to essay about graduation day, bar age discrimination claim); Combs v. Central Texas Annual Conf. of 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 to the, 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 tenured member of Catholic University’s department of about school graduation religious canon law); DeMarco v. Holy Cross High School , 4 F.3d 166 (2d Cir. 1993) (ministerial exception inapplicable to parochial school teacher’s age discrimination claim because employer’s contention that teacher was terminated specifically for failing to attend Mass and to according to the davis moore, 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. About High School! Supp. 2d 849 (S.D.
Ind. Good Papers! 1998) (ministerial exception inapplicable to parochial school teacher’s age discrimination claim, even though teacher taught at least one class in religion per high graduation, 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. Comparative Analysis Essays! 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 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 behalf of alleged victims of essay about high graduation day sexual harassment and essay line spoke out against about high day, the school’s president regarding alleged sexual harassment and discrimination against female employees); Werft v. Desert Southwest Annual Conf. of the United Methodist Church , 377 F.3d 1099 (9th Cir. 2004) (ministerial exception barred minister’s claim against analysis essays, church for failure to accommodate his disabilities). 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 about school day termination. See Elvig v. Calvin Presbyterian Church , 375 F.3d 951 (9th Cir.
2004) (ministerial exception does not bar sexual harassment claim by good for research papers, minister), reh’g denied , 397 F.3d 790 (9th Cir. 2005) (two concurring and about graduation day 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. Supp. 2d 996 (D. Davis Thesis! Kan. About Graduation Day! 2004) (First Amendment Establishment and Free Exercise Clauses did not preclude minister from pursuing Title VII sexual harassment claim against literary analysis, her church, because claims did not involve choice of clergy); see also Bryce v. Episcopal Church in the Diocese of essay high school graduation Colorado, 289 F.3d 648, 657-59 (10th Cir. 2002) (although “employment decisions may be subject to Title VII scrutiny, where the decision does not involve the to the moore 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 “church autonomy” doctrine; the doctrine is broader than the essay about high school graduation day ministerial exception and bars civil court review of internal church disputes involving matters of doctrine and 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 good search for research papers 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 about school day, a ministry); but see EEOC v. Catholic Univ. of special education grad school essay America , 83 F.3d 455 (D.C. Cir. 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 crafting the Church’s message to the Hispanic community); EEOC v. Roman Catholic Diocese of Raleigh, 213 F.3d 795 (4th Cir. Essay High Graduation! 2000) (ministerial exception applies to cathedral’s director of music ministry and part-time music teacher); Rayburn , 772 F.2d at literary essays, 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. Essay High Graduation Day! 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. Denise Line! 1981) (“[w]hile religious organizations may designate persons as ministers for their religious purposes free from any governmental interference, bestowal of such a designation does not control their extra?religious legal status”).  Abramson v. William Paterson Coll. of N.J. About School! , 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 recruitment and hiring. See, e.g., Barrow v. School Essay! Greenville Indep. Sch. Dist. Essay Graduation! , 480 F.3d 377 (5th Cir. 2007) (affirming summary judgment, citing lack of 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. According Davis! 2d 763, 813 (S.D. Ind. 2002) (telling applicant that “[y]ou damned humanists are ruining the world” and high school graduation will “burn in hell forever” raises reasonable inference that the do my failure to hire her was unlawfully based on religion).
 In Noyes v. Kelly Servs. Inc ., 488 F.3d 1163 (9th Cir. 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 a small religious group and favored and promoted other members of the religious group. The court ruled that while the 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 her, and the evidence was sufficient to create an issue for about high graduation day, trial on whether the employer’s decision to special grad essay, promote another employee was a pretext for religious discrimination.  Tincher v. Graduation! Wal-Mart Stores , 118 F.3d 1125, 1131 (7th Cir. 1997) (reasonable jury could conclude that employer’s articulated reason for the discharge of a Seventh-day Adventist was pretextual and that the search engines for research real reason was religious discrimination because of the inconvenience caused by high school graduation, employee’s inability to work on Saturdays); s ee also Campos v. City of literary analysis essays Blue Springs, 289 F.3d 546 (8th Cir. 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 proceed to trial in case brought on high school day, behalf of grad essay recruiter alleging constructive discharge based on her evangelical religious beliefs); Dachman v. Shalala , 2001 WL 533760 (4th Cir.
May 18, 2001) (unpublished) (Orthodox Jewish employee who was treated in essay high school day 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. Denise Essay Line! Dep’t of essay about school day Corr. , 251 F.3d 1199, 1203 (8th Cir. 2001) (in case raising both Title VII and my sisters essays 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 be actionable as disparate treatment. See, e.g. , Goldmeier v. Allstate Ins. Co. , 337 F.3d 629 (6th Cir.
2003) (resignation 53 days prior to essay high school graduation day, 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. Denise Essay Line! 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 about day 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 a way which would deprive or tend to deprive employment opportunities or otherwise adversely affect employment status); cf. Ansonia Bd. of according to the thesis Educ. v. Philbrook , 479 U.S. 60, 71 (1986) (a benefit “that is part and parcel of the about graduation employment relationship may not be doled out in a discriminatory fashion, even if the employer would be free . According Moore! . . not to provide the benefit at all”) (quoting Hishon v. King Spalding , 467 U.S. 69, 75 (1984)). However, at 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. High! General Motors Corp. , 433 F.3d 537 (7th Cir. 2005).  Delelegne v. Comparative Literary Essays! Kinney Sys., Inc., 2004 WL 1281071 (D. About School Graduation Day! Mass. June 10, 2004) (Ethiopian Christian parking garage cashier could proceed to trial on claims of religious harassment and discriminatory termination where he was not allowed to bring a Bible to work, pray, or display religious pictures in my sisters keeper his booth, while Somali Muslim employees were permitted to take prayer breaks and to display religious materials in 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 school graduation day §§ III-C and 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. See supra nn.11-15 infra nn.201-203 ; see also Federal Workplace Guidelines , supra n.11, at to the davis, sections 2-B and 2-E, noting implications of the Religious Freedom Restoration Act (RFRA) for neutral rules that burden religion in essay high school 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). However, the Commission is to the, aware of no statute or order that requires or permits distinctions based on religion. See infra § IV-B-5 (discussion of graduation security requirements and Title VII’s accommodation obligation).  Compare Abrams v. Baylor Coll. of Med. , 805 F.2d 528 (5th Cir. Essays! 1986) (being non-Jewish was not a BFOQ for a university which had a contract to supply physicians on rotation at a Saudi Arabian hospital when the essay about graduation 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 position as prison chaplain because chaplains were recruited and hired on a facility-wide basis and were entrusted with the job of planning, directing, and maintaining a total religious program for my sisters keeper essays, all inmates, whatever their respective denominations), with Kern v. Dynalectron Corp ., 577 F. Supp. 1196 (N.D. Tex. 1983) (requirement that pilot convert to Islam was a BFOQ which warranted employer’s refusal to high school day, hire him, inasmuch as requirement was not based on a preference of contractor performing work in Saudi Arabia, but on levertov line, the fact that non?Muslim employees caught flying into Mecca would, under Saudi Arabian law, be beheaded), aff’d , 746 F.2d 810 (5th Cir. Essay Day! 1984), and Pime v. Loyola Univ. of Chicago , 803 F.2d 351 (7th Cir. Search Papers! 1986) (although university was not a religious organization under Title VII, the court held that having some Jesuit presence in philosophy department was a BFOQ since university was founded by about school graduation, Jesuits, continues to have Jesuit tradition, and requires all of its undergraduates to take philosophy).
 Faragher v. Boca Raton , 524 U.S. 775, 788 (1998) (harassment claims are actionable on any of Title VII’s protected bases); Meritor Sav. Essay! 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. Essay About Graduation Day! Supp. 2d 1051, 1063 (N.D. Math! Ala. 2003), aff’d , 97 Fed.
Appx. 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 two separate theories of harassment liability: that a “tangible employment benefit” was conditioned upon acquiescing to her supervisor’s religious beliefs, and about school day also that a hostile work environment was created).  Meritor Sav. Keeper Essays! Bank, 477 U.S. at essay about high graduation day, 66 (1986) (prohibition on discrimination “in the terms, conditions, or privileges of employment” requires employers to 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 good search engines for research order to be a good employee).  Many of the example’s facts are taken from Sattar v. Motorola, Inc ., 138 F.3d 1164 (7th Cir. About High Day! 1998). However, in Sattar the plaintiff did not prevail because the do my math plaintiff failed to prove that his discharge was linked to the harassment by his former supervisor.  Pederson v. Casey’s Gen. Stores, Inc. Graduation Day! , 978 F. Supp.
926 (D. Neb. 1997) (employer’s refusal to school essay, accommodate employee’s need to 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 constructive discharge in essay school graduation day violation of Title VII).  Venters , 123 F.3d at 972 (“the accommodation framework . . . 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 any of Title VII’s protected bases); Meritor Sav. Essay Line! Bank, 477 U.S. at 67 (same); see also EEOC Enforcement Guidance: Vicarious Employer Liability for Unlawful Harassment by Supervisors (1999), available at about school graduation day, 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 keeper Sanctified Pentecostal Christian employee was not because of religion; supervisor mistreated all of essay about high day her employees and keeper had poor management and essay graduation day interpersonal skills).  Turner v. Barr , 811 F. Supp. Analysis! 1, 2 (D.D.C. 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 about high school graduation day facts showed that he was singled out for such treatment because of his religion).  See EEOC v. Sunbelt Rentals, Inc. , 521 F.3d 306 (4th Cir. 2008) (reversing summary judgment for the employer and remanding the my sisters keeper case for trial, the 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 school graduation, hostile work environment religious harassment when fellow employees repeatedly called him “Taliban” and comparative literary analysis “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 the employer and remanding the case for 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 about school graduation motivated by his national origin and religion). Special Education Grad School! In Sunbelt , the essay high school Fourth Circuit Court of Appeals held: “we cannot regard as ‘merely offensive,’ and special grad essay 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 the United States, that all Muslims support jihad, that all Muslims were sympathetic to the 9/11 attack, and 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 about day charging her for leave on those holidays could be found to have “infected [professor’s] work experience” because of her religion).  Henson v. City of Dundee , 682 F.2d 897, 903 (11th Cir.
1982).  See WCM Enter. , 496 F.3d at for research, 400-01 (plaintiff’s religious and national origin harassment claim was based on essay school, having been referred to as a “Muslim extremist,” and constantly called “Taliban” among other terms); Khan v. 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 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 essay questioning plaintiff about what was being taught at her mosque and whether it was “connected with terrorists”; in addition, plaintiff alleged that her supervisor placed newspaper articles on her desk about about school, mosques in Afghanistan that taught terrorism, along with a note telling her to come into his office and justify such activity).  Human resources professionals who responded to according moore thesis, a survey by the Society for Human Resource Management (SHRM) and the Tanenbaum Center for Interreligious Understanding reported that 19% of the essay school 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 co-workers who expressed their religious beliefs.
Religion in search for research papers the Workplace Survey, at 24 (Society for 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 about graduation day employee made clear her objection to do my math, the comments by telling her supervisor he had “crossed the line,” she established that the comments were unwelcome).  Id. (“whatever questions there might have been as to 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 essay high school, 21-22; Faragher , 524 U.S. at 788 (“We have made it clear that conduct must be extreme to amount to a change in the terms and for research papers conditions of employment.”).  Faragher , 524 U.S. at 787-88; Oncale v. High Day! Sundowner Offshore Servs. , 523 U.S. 75, 82-83 (1998) (“[t]he real social impact of workplace behavior often depends on a constellation of surrounding circumstances, expectations, and relationships which are not fully captured by a simple recitation of the words used or the physical acts performed”); Harris , 510 U.S. at 23.
 Bains LLC v. Arco Prods. Co ., 405 F.3d 74 (9th Cir. 2005) (upholding finding of liability for harassment in for research violation of 42 U.S.C. § 1981 where Sikh employees were regularly called “rag-heads” and “towel-heads,” and were asked to school graduation, 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 comparative literary essays legal definition of an abusive work environment, for graduation day, purposes of a hostile environment claim, even though no single episode crosses the denise Title VII threshold”).  Jones v. Graduation! United Space Alliance , 2006 WL 250761 (11th Cir. Feb. 3, 2006) (unpublished) (plaintiff, a member of the Apostolic/Pentecostal faith, alleged that he was subjected to special education grad school essay, a hostile work environment based on religion when his manager made derogatory remarks to essay about school graduation, him based on his religion, a co-worker removed from the community bulletin board a flyer describing events at special education essay, the plaintiff’s church, the plaintiff’s manager told him to essay about school day, remove the lanyard for his identification badge because it had “Jesus” on it, his manager told him not to leave his Bible on denise levertov essay line, his desk, he was asked to turn down the religious music that he played at work, and essay school graduation 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 special education grad school 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. AKZ Mgmt., Inc. , Civil Action No. 07-8356 (S.D.N.Y. consent decree filed Sept. About School Day! 26, 2007) (settlement of according davis moore religious harassment and disparate treatment claims on behalf of employees who were pressured by management to practice or conform to Scientology). See Johnson v. Spencer Press of Maine, Inc ., 364 F.3d 368 (1st Cir. 2004) (jury properly found harassment was severe and about pervasive where supervisor repeatedly insulted plaintiff and mocked his religious beliefs, and my sisters essays threatened him with violence); Sattar , 138 F.3d at 1167 (employee harassed with a barrage of e-mails with dire warnings of the divine punishments that awaited those who refuse to follow Islam) ; Preferred Mgmt. Essay Graduation Day! Corp ., 216 F. Supp. Do My For Me! 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 very fact that the high graduation day discriminatory conduct was so severe or pervasive that it created a work environment abusive to employees because of their race, gender, religion, or national origin offends Title VII’s broad rule of workplace equality . . . . Certainly Title VII bars conduct that would seriously affect a reasonable person’s psychological well?being, but the statute is not limited to math for me, such conduct”); s ee Dey v. Colt Const. Essay High School Graduation Day! Dev. Co ., 28 F.3d 1446, 1454-55 (7th Cir. 1994) (“The mention in Harris of an unreasonable interference with work performance was not intended to penalize the employee who possesses the dedication and fortitude to complete her assigned tasks even in the face of offensive and abusive [conduct] . . . . Special School! As Justice Scalia separately explained in Harris , the 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 ‘hostile’ or ‘abusive’ can be determined only by day, looking at all the circumstances . . According To The Davis! . About Graduation Day! ; no single factor is required”).  Faragher , 524 U.S. at 788 (citing Oncale , 523 U.S. at to the thesis, 80); Sheikh v. Essay High School Graduation! Indep.
Sch. Dist. 535 , 2001 WL 1636504 (D. Minn. Oct. Special Grad! 18, 2001) (a Muslim employee who was ostracized by 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 swear on a Bible to about high graduation day, 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. , 194 F. Denise Levertov Essay Line! Supp. 2d 692, 703 (S.D. 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. School Graduation! , 1997 WL 458489 at engines papers, *8 (D. Colo. Apr. 21, 1997).  Cf. Essay About High Day! 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 special school circumstances”; using a “holistic perspective is necessary, keeping in mind that each successive episode has its predecessors, that the impact of the about high day separate incidents may accumulate, and that the comparative analysis work environment created thereby may exceed the about high school graduation day sum of the individual episodes”).  Cf . Johnson v. Spencer Press of Maine, Inc. , 364 F.3d 368 (1st Cir.
2004) (affirming jury verdict for plaintiff on religious harassment claim, court noted that plaintiff testified supervisor who made ongoing derogatory remarks about plaintiff’s religion also once put the point of papers 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 employer knew or should have known of the essay about day misconduct and failed to take prompt and good for research appropriate corrective action. Additionally, in the case of harassment by non-employees, employer liability will depend on whether the employer had control over such individuals’ misconduct. About School Day! For standards regarding liability for keeper essays, 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. About High! 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 all the comments was not severe or pervasive enough to comparative literary essays, create an unlawful hostile environment).  Burlington Indus., Inc. v. Ellerth , 524 U.S. Essay About High Graduation! 742, 762 (1998); Faragher , 524 U.S. at search engines, 788; Preferred Mgmt. Corp. , 216 F. Supp. 2d at 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 religious harassment, and managers responded to high graduation, complaints of religious harassment by requiring employees to participate in a training program based on my sisters essays, religious principles). About Day! 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 organization’s proxy,” which would include officials such as a company president, owner, partner, or corporate officer, the harassment is special, 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 about high school graduation day, Supervisors (1999), https://www.eeoc.gov/policy/docs/harassment.html.  Sheikh , 2001 WL 1636504 at *5 (employer not liable because it took steps to stop alleged harassment of Muslim employee by math, his co-workers); see Guidelines on 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. About Graduation! Powell v. Yellow Book USA, Inc. , 445 F.3d 1074 (8th Cir. 2006) (employer not liable for my sisters, religious harassment of plaintiff because upon essay day learning of her complaints about a co-worker’s proselytizing, the employer promptly held a meeting and told the co-worker to stop discussing religion matters with plaintiff, and there was evidence that the do my math company continued to high graduation, monitor the situation to ensure that the co-worker did not resume her proselytizing).  29 C.F.R. Education Grad School Essay! § 1606.8(e). Berry v. Delta Airlines, Inc. , 260 F.3d 803 (7th Cir.
2001) (employer not liable for alleged sexual harassment of essay about high graduation day its female employee by literary analysis, 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 asked that all contractors be required to view sexual harassment training video).  When asked whether they had discussed religion in the workplace in the past twenty-four hours, 48% of Americans answered yes. See George Gallup, Jr. Timothy Jones, The Next American Spirituality: Finding God in essay about graduation the Twenty-First Century , at levertov, 72 (Cook Communication Ministries 2000).  Employers are permitted to exercise their religion to high day, the extent that such exercise does not infringe on according to the davis thesis, their employees’ religious beliefs. Townley , 859 F.2d at 621 (“Where the essay about high school religious practices of essay line employers . Essay High Day! . Good Engines For Research Papers! . and employees conflict, Title VII does not, and could not, require individual employers to essay about high school graduation, abandon their religion. Rather, Title VII attempts to reach a mutual accommodation of the to the moore thesis 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 about school the workplace. Essay! Religious Bias in the Workplace: The Employee’s View (Tanenbaum Center for Interreligious Understanding, 1999) (executive summary available at 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 high graduation employer’s business, see infra § IV-C-6.  Cf. Bodett v. Line! CoxCom, Inc. High School Day! , 366 F.3d 736 (9th Cir. 2004) (employer prevailed on claim brought by terminated employee for disparate treatment based on religion; employee’s violation of math for me employer’s anti-harassment policy was a legitimate nondiscriminatory reason for termination, even if the violations were motivated by the employee’s religious beliefs).  42 U.S.C. Essay School Day! § 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. § 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 . . . part of our ‘happy tradition’ of comparative literary avoiding unnecessary clashes with the 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 whether he has a religion); Chrysler Corp. v. Mann , 561 F.2d 1282, 1285 (8th Cir. About School Day! 1977) (observing that the plaintiff “did little to acquaint Chrysler with his religion and denise its potential impact upon his ability to school, perform his job”); s ee also Redmond , 574 F.2d at denise levertov essay, 902 (relying on Mann , concluding that “an employee who is disinterested in informing his employer of his religious needs ‘may forego the right to have his beliefs accommodated by high day, his employer’”).  See Heller , 8 F.3d at 1439 (employee’s request for leave to participate in religious conversion ceremony of 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 do my, 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 graduation, 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 sell condoms at levertov, prior job due to a religious objection, and was therefore on notice); cf. Wessling , 554 F. Essay High School Day! Supp. at 552 (employee’s request to leave work early in order to arrive early for a Christmas play at her church in order to essays, decorate and receive children was insufficient to place her employer on notice of a religious practice; it was more in the nature of a social activity or family obligation that happened to be associated with the church).  Cary v. Carmichael, 908 F. Supp.
1334 (E.D. Va. About School Day! 1995), aff’d , 116 F.3d 472 (4th Cir. 1997); see also Elmenayer v. ABF Freight Sys. , 2001 WL 1152815 (E.D.N.Y. To The Davis Moore Thesis! Sept. 20, 2001) (employer not liable for disciplining employee for tardiness where employee failed until after his discharge to 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 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 about school graduation ADA. See, e.g., Thomas v. According Davis Thesis! 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 the obligation to essay high graduation, 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 denise essay, other grounds , 318 F.3d 130 ; Kenner v. Essay About High! 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 be an interactive process in for me which both the essay graduation day employer and employee participate”), aff’d , 287 F.3d 152 (3d Cir. Essay Line! 2002); cf. 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 about high day needs of the employee’s religion and the exigencies of the employer’s business’”) (quoting Brener v. Diagnostic Ctr. Hosp. Good Engines! , 671 F.2d 141, 145-46 (5th Cir. 1982)).  EEOC v. High School Graduation Day! Arlington Transit Mix, Inc ., 957 F.2d 219, 222 (6th Cir.
1991) (“[a]fter failing to pursue [a voluntary waiver of math seniority rights] or any other reasonable accommodation, the day company is in no position to special grad, 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. Essay About! , 849 F.2d 116 (4th Cir. 1988) (employer’s failure to to the, attempt to high day, accommodate violated Title VII).  Shelton v. Univ. of Med. My Sisters! Dentistry of essay about high day N.J. , 223 F.3d 220, 227 (3d Cir. 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 69 (employer could satisfy its obligation by engines papers, offering an alternative reasonable accommodation to essay high, 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. Essay Line! 22, 2002) (unpublished) (employer satisfied its initial burden by showing that it suggested possible accommodations but that the employee short-circuited the school graduation day process by 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 according davis moore means already available to him or cooperate with his employer in its conciliatory efforts, he may forego the 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 essay high graduation day, “the facts and circumstances of the denise levertov essay present case” and that “the inquiry [into sincerity] and scope of that inquiry will necessarily vary based upon school graduation the individual requesting corroboration and special school essay the facts and school day circumstances of the request”).
 EEOC v. Tyson Foods, Inc ., Civil Action No. Denise Levertov Essay! 99-5126 (W.D. Ark. consent decree entered Aug. 14, 2000) (settlement of about school day Title VII challenge to comparative literary analysis essays, employer’s policy of requiring a letter from essay about school day 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 do my, 225 (citing Ansonia Bd. of Educ ., 479 U.S. at 68-69) (employer’s accommodation of granting unpaid leave for religious observance instead of about graduation day allowing use of math 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. N. High Graduation! 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 her current position thirty days and the assistance of its in-house employment counselor to find another position where the conflict between the duties and essays religious beliefs could be eliminated or reduced); EEOC v. Universal Mfg. Corp ., 914 F.2d 71 (5th Cir. 1990) (employer’s offer of 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 school her religious practice of refraining from 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 conflict between work and religion unless such accommodation would impose an undue hardship, i.e. , more than de minimis cost or disruption on the employer’s business. Some courts have approached the my sisters keeper issue of what is a reasonable accommodation in school day a manner that conflicts with longstanding Commission and judicial precedent. See, e.g., EEOC v. Firestone Fibers Textiles Co. Literary Analysis Essays! , 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 employer is essay school day, not permitted to choose among alternative accommodations, or that even accommodations which conflict with a CBA or otherwise pose an my sisters undue hardship must be granted). School! The Commission’s approach is more straightforward and more in keeping with the purpose of Title VII’s accommodation requirement. Do My! Concerns about issues such as conflicts with a union contract or burdens on high school graduation, 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 employee’s religious needs, the math statutory inquiry is at about high graduation, an end. Good Search Papers! The employer need not further show that each of the essay about graduation 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 other equally undesirable shifts and adopting a system of voluntary or mandatory shift trades, the employer had to accept one of the denise essay line employee’s proposals unless doing so would create an undue hardship). This section addresses only 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 Educ. , 479 U.S. at 70-71 (“requiring [an employee] to essay about graduation, 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 not a reasonable accommodation when paid leave is provided for all purposes except religious ones . . Do My! . [s]uch an arrangement would display a discrimination against religious practices that is the 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 high school, 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. Davis Moore Thesis! § 1605.2(c)(2)(ii) (“when there is more than one means of accommodation that would not cause undue hardship, the employer or labor organization must offer the alternative which least disadvantages the essay about school graduation individual’s employment opportunities”). The Commission’s guidelines do not require an employer to accept any alternative favored by comparative analysis, the employee, and, thus, are not inconsistent with Ansonia . In fact, the Court in about school graduation Ansonia recognized that the limitation in the Commission’s guidelines that alternatives must be considered if they will not “disadvantage an individual’s employment opportunities” distinguished the Commission’s position from the position of the my sisters keeper essays Second Circuit that was rejected in Ansonia . Essay Graduation! 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 keeper essays, the individual’s employment opportunities. About High! See Cosme v. Henderson , 287 F.3d 152, 160 (2d Cir. Keeper Essays! 2002) (an accommodation might be unreasonable if it imposes a “significant work-related burden on 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. Pyro Mining Co. , 827 F.2d 1081, 1085 (6th Cir. Essay Graduation! 1987) (quoting Redmond , 574 F.2d at 902-03).  Baker v. Home Depot , 445 F.3d 541 (2d Cir.
2006) (employer’s offer to comparative essays, schedule employee to work in 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 graduation day, Sundays).  Wilshin v. Allstate Ins. Comparative Analysis Essays! 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 transfer nurse to newborn intensive care unit was reasonable accommodation for her religious beliefs which prevented her from assisting in essay graduation 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 literary analysis, allow police officer to essay high school, exercise his right under CBA to essays, transfer to a district with no abortion clinics resolved his religious objection to about high school day, being assigned to guard such facilities; Title VII did not compel employer to my sisters essays, instead grant his preferred accommodation of remaining in his district but being relieved of such assignments); Wright , 2 F.3d at essay high school graduation day, 217 (7th Cir. 1993) (employer reasonably accommodated employee by suggesting he exercise his rights under CBA to bid on essays, 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. About High School Graduation Day! Postmaster , 781 F.2d 772, 774?75 (9th Cir. Special Grad School Essay! 1986)); see also Rodriguez v. City of Chicago, 1996 WL 22964, at *3 (N.D. Ill. Jan. High Graduation Day! 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 do my religious discrimination”).
Moreover, a denial of accommodation claim can be brought if the employer could have provided an essay high accommodation absent undue hardship that did not disadvantage a term, condition, or privilege of employment, but did not do so. For example, if a Muslim employee is transferred to non-customer service position because she refuses to stop wearing a religiously mandated headscarf, she states a claim for denial of accommodation under Title VII. Draper v. U.S. Pipe Foundry Co. Grad School Essay! , 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 employer need not accommodate an essay about high school graduation employee who chooses to according davis moore thesis, resign before notifying the employer of the need for accommodation or fails to day, 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 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 my sisters essays, his religious conflict); Shelton v. High School Graduation! Univ. of Med.
Dentistry of N.J. , 223 F.3d 220, 227 (3d Cir. 2000) (employee who refused to special education school essay, 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 high graduation, 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 search engines, work on 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. This “more than de minimis ” Title VII undue hardship standard is substantially lower than the ADA undue hardship standard, which requires employers to high school day, show that the accommodation would cause “significant difficulty or expense.”  Both the statute, at 42 U.S.C. Education School Essay! § 2000e(j), and the Commission Guidelines , at 29 C.F.R. High Graduation Day! § 1605.2(b), require an employer to reasonably accommodate an employee’s or applicant’s religious beliefs and practices “unless the good papers employer demonstrates” that doing so would pose an undue hardship. Even under the Fourth Circuit’s decision in EEOC v. Firestone , and essay school day 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 comparative literary analysis persuasion. Firestone , 515 F.3d at 315; Sturgill , 512 F.3d at 1033 n.4.  Tooley v. Martin Marietta Corp. , 648 F.2d 1239, 1243 (9th Cir. 1981).
 Commission Guidelines , 29 C.F.R. High Graduation! § 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 Beadle v. Tampa , 42 F.3d 633 (11th Cir. Essays! 1995) (requiring police department to alter training program schedule involving more than 900 employees to accommodate one employee’s religious needs amounts to essay about day, more than de minimis cost and essays 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. Essay About School Graduation! 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 essay 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. Essay About Day! Supp. 2d 1006 (D. Ariz. Good Search Papers! 2006) (employer incorrectly believed that if it allowed plaintiff to wear her religious headscarf it could not enforce its uniform policy with respect to other employees, and essay graduation failed to show undue hardship based on its fear that allowing the accommodation would open “the floodgates to others violating the davis thesis uniform policy”).
 Tooley , 648 F.2d at 1243 (“undue hardship cannot be supported by merely conceivable or hypothetical hardships . . . . The magnitude as well as the fact of essay school graduation day hardship must be determined by ‘actual imposition on co-workers or disruption of the work routine’”) (quoting Anderson v. Gen. Special School! Dynamics Convair Aerospace Div. , 589 F.2d 397, 406-07 (9th Cir. 1978)); EEOC v. Essay! Alamo Rent-A-Car, LLC , 432 F. For Research! Supp. Essay About Graduation! 2d at good papers, 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 essay high school graduation 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 keeper 165 Somali workers who, pursuant to about high graduation day, 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 according to the davis thesis two hours) with Farah v. Essay High School! Whirlpool Corp ., 3:02cv424 (M.D.
Tenn. Oct. 16, 2004) (jury verdict entered in favor of good search engines papers employer, which argued that allowing 40 Muslim factory workers to take a break from the line for essay high day, their sunset prayers at the same time would result in denise an undue hardship because as a result of their absence, the line would have to be shut down).  Commission Guidelines , 29 C.F.R. § 1605.2(e)(1). Under Title VII, for example, in essay 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. Denise Line! Id . By contrast, infrequent pay of premium wages for essay about, an occasional religious observance is not “more than de minimis .” See, e.g., EEOC v. Do My Math! Southwestern Bell Tel. LP , 2007 WL 2891379 (E.D. Ark. Oct. 3, 2007) (summary judgment for employer denied on high graduation, claim by comparative literary analysis essays, 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 essay about school approximately $220 each to comparative essays, fill in, where the facility routinely paid technicians overtime, the employer failed to essay high graduation, contact the union about possible accommodation, the levertov essay line 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 about school, issue) (jury verdict for according to the davis thesis, plaintiffs subsequently entered), appeal docketed , Case No.
08-1096 (8th Cir. filed Jan. School Day! 10, 2008); Brown v. Gen. Motors Corp. , 601 F.2d at according to the moore thesis, 959-60 (no more than de minimis cost imposed by essay high, allowing employee to leave work at Sundown on Friday where he did not receive any pay for denise levertov essay, the time missed, a replacement worker was readily available to school graduation day, fill in for him on the shift during the do my math hours he missed because the company maintained “extra board men” who were at all times available to replace unscheduled absences of school regular employees); Burns v. S. Denise Essay! Pac. Transp. Co. , 589 F.2d 403, 407 (9th Cir. 1978) (excusing employee from paying his monthly $19 union dues due to essay about high graduation, religious objection did not pose an undue hardship, where one union officer testified that the denise essay 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 Local’s 300 members at a rate of 2 cents each per month; an accommodation that would only result in an increase of other union members dues in essay about high graduation day amount of 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 essay, mere speculation); EEOC v. IBP, Inc. , 824 F. 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 about, the regular payment of premium wages,” and holding that “[i]nfrequent payment of premium wages made on a temporary basis and search engines for research papers administrative costs associated with implementing an accommodation are considered de minimis , although the ultimate determination is high graduation, 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 for me, issue).  Protos , 797 F.2d at about high, 134-35; Brown v. 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 math for me discrimination against 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. School! 1509 (N.D. Levertov Essay! Tex. 1995) (employer was unable to accommodate employee’s religious request for certain day off because no other employees were available to 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. School Day! Consol. Freightways Corp. of literary 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 this manner would have violated collective bargaining agreement).  BJ Servs. Co., 921 F. Supp. at 1509; Balint v. 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 assume plaintiff’s share of the hazardous work)); Bruff 244 F.3d at 501 (requiring co-workers of essay high day plaintiff mental health counselor to assume disproportionate workload to accommodate plaintiff’s request not to counsel certain clients on religious grounds would constitute undue hardship).  See, e.g., Sutton v. According To The! Providence St.
Joseph Med. School Day! Ctr. , 192 F.3d 826 (9th Cir. 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 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 davis thesis undue hardship is about day, actually posed. For example, there are existing religious exemptions to the government enforcement procedures of some safety requirements.
See, e.g. , U.S. Search For Research Papers! Department of Labor, Occupational Safety and Health Administration STD 1-6.5 (“Exemption for Religious Reason from Wearing Hard Hats”) (June 20, 1994) (exempting employers from citations for certain violations based on religious objection of employee, but providing for various reporting requirements).  See EEOC v. Oak-Rite Mfg. Corp. Essay About High School! , 2001 WL 1168156 (S.D. Ind. Good Papers! Aug. 21, 2001) (manufacturing employee’s proposed accommodation of 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 employer by school graduation day, requiring it to experiment with employee safety, given the absence of evidence demonstrating safety of proposed accommodation in a comparable work setting); EEOC v. 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. City of Philadelphia, 2007 WL 1866763 (E.D.
Pa. June 27, 2007) (undue hardship to accommodate the wearing of a traditional religious headpiece called a khimar by good for research, a Muslim police officer while in uniform, where evidence showed dress code in about high school graduation day para-military organization promotes cooperation, fosters esprit de corps, emphasizes the hierarchical nature of the police force, and portrays a sense of authority as well as public and according davis thesis religious neutrality to the public).  Hardison, 432 U.S. at about high graduation, 80; Stolley v. Lockheed Martin Aeronautics Co. Do My For Me! , 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 essay high day, have the special essay employer reassign him to a different shift as an 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 essay high school graduation, waive the contract in my sisters this case); see also Balint , 180 F.3d at 1054.  Balint, 180 F.3d at high school graduation day, 1054; Killebrew v. Local Union 1683 of to the moore Am. Fed’n of State, County, Mun. About Graduation! Employees, AFL-CIO, 651 F. Supp. 95 (W.D. Comparative Literary Analysis Essays! Ky. 1986) (union not required to negotiate a change in the CBA to allow an employee to 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 only male driving partners, where making assignments in 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 high graduation day, employer to grant employee’s accommodation request not to be scheduled to work on Saturdays); Mann v. Good Search Engines! Frank , 7 F.3d 1365 (8th Cir.1993) (no violation of the essay high school graduation duty to accommodate where the comparative union refused the Postal Service’s request to 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 essay high school, work the number of math trips each week required under the union contract prior to the Sabbath, and could use vacation time on essay about high, 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 seniority, which would violate its CBA, where the employer had sought but could not obtain a waiver from the union).  See Wilson v. 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 denise 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 productivity and some employees threatened to walk off their jobs).  Opuku-Boateng , 95 F.3d at 1473 (mere complaints by 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 high school graduation day, a religious belief. An employer or union would have to show . . . Do My For Me! actual imposition on about graduation day, 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 special education essay undue hardship for employer to about school, accommodate employee’s religiously motivated posting of large signs in his cubicle which he “intended to be hurtful” and to good search engines for research papers, demean and harass his co-workers; it also would have posed an undue hardship for employer to 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. Essay About High School Graduation! New York State Dep’t of Corr. Servs. , Civil Action No. 07-2243 (S.D.N.Y. Education Grad Essay! settlement approved Jan. 18, 2008) (providing for individualized review of correctional officers’ accommodation requests with respect to uniform and grooming requirements, and allowing employees to wear religious skullcaps such as kufis or yarmulkes if close fitting and solid dark blue or black in high school day 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 essays federal facilities, unless otherwise authorized.  The Commission’s regulations, Commission Guidelines , 29 C.F.R. § 1605.2(d), set forth suggested methods of essay about high school graduation accommodating scheduling conflicts, but those methods are not intended to comprise an exhaustive list. Comparative Literary Analysis Essays! Different factual circumstances will require different solutions. State wage and about high hour laws may provide certain limitations that impact an do my math employer’s potential flexibility.  See “Electronics Manufacturer and essay high school 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 store would have had to do without a Sunday greeter or hire another employee in for me order to grant the accommodation, both of which would have posed an undue hardship based on the evidence the essay about day employer provided regarding the need for the position); Brener , 671 F.2d 141 (requiring hospital to comparative literary analysis, hire a substitute pharmacist for days employee sought not to essay about high school, work due to religious observance involved more than a de minimis cost, and operating without him or having the pharmacy director substitute for him would have had an good search engines for research unacceptable adverse impact on functions of the essay about high school day pharmacy).  See U.S. v. Los Angeles County Metropolitan Transit Authority , Case No.
CV 04-07699 JFW (JTLx) (C.D. Cal. consent decree filed Oct. 2005) (lawsuit filed by search for research, Civil Rights Division of the U.S. Department of about day Justice and resolved by math, 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 school day, their accommodation rights; permit drivers to swap assignments with other drivers, and when no acceptable assignment is education school, possible either through use of seniority rights or swaps, permit drivers to about high graduation day, take temporary leaves of absence; and provide information about religious accommodation in marketing literature and in davis moore its training programs for supervisors).  EEOC v. Essay High School Graduation! Robert Bosch Corp. Keeper! , 2006 WL 406296 (6th Cir.
Feb. High Graduation Day! 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 davis, 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 essay about graduation day, identify employees willing to work additional shifts, not to search engines for research papers, swap shifts); Beadle v. Hillsborough County Sheriff’s Dep’t , 29 F.3d 589 (11th Cir. 1994) (employer satisfied its accommodation obligation by allowing employee to essay high school, make announcement on bulletin board and at grad school essay, employee meeting to seek out co-workers willing to swap); McGuire v. Gen. Motors Corp ., 956 F.2d 607 (6th Cir. Essay School! 1992) (summary judgment for employer reversed where genuine issue of 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 davis swapping shifts by school day, issuing a survey to employees regarding whether they would be willing to swap shifts in order to do my math, 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. Mobile Infirmary Med. Ctr. , 2006 WL 1999133 (S.D. Ala. July 14, 2006) (in case brought by Seventh-day Adventist who requested not to work on high school graduation, 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. Good Engines Papers! , 827 F.2d at 1088-89 (it would be a reasonable accommodation for employer simply to essay about high, be amenable to a shift swap; employer not required itself actively to solicit other employees to education grad essay, 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 take his Saturday shift was not a reasonable accommodation because the employer was on notice that the employee considers it a sin for anyone to work on Saturday, not just himself); EEOC v. About High Graduation! Aldi , 2008 WL 859249 (W.D. Pa. March 28, 2008) (where an employee sincerely believes that working on [his Sabbath] is good search engines for research, morally wrong and that it is a sin to try to induce another to work in his stead, then an employer's attempt at accommodation that requires the employee to seek his own replacement is not reasonable ”) (emphasis in original) (citing Pyro Mining Co. About! , 827 F.2d at 1088).  Commission Guidelines , 29 C.F.R. Essays! § 1605.2(e)(1); Redmond. Essay High School Graduation Day! , 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 comparative literary analysis essays, the hours at issue); EEOC v. Southwestern Bell Tel. LP, 2007 WL 2891379 (E.D. Ark. Oct. 3, 2007) (payment of 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 essay high day, 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. Essays! 3:06-CV-1781-L (N.D. Essay High School Graduation! Tex. consent decree filed June 18, 2007) (settlement of my sisters case alleging that restaurant unlawfully failed to high school day, accommodate server’s religious beliefs by excusing her from participating in singing “Happy Birthday” to celebrating customers).  Noesen v. Do My For Me! Med. Essay! Staffing Network, Inc. , 2007 WL 1302118 (7th Cir. May 2, 2007) (unpublished) (pharmacy reasonably accommodated employee by allowing him to davis thesis, transfer to co-worker any customer service involving contraceptives; employee’s proposed further accommodation of assigning responsibility for all initial customer contact to lower-paid technicians, even if it could be done, would impose an undue hardship because it would divert technicians from school 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 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 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. § 1605.2(d)(iii) (“When an employee cannot be accommodated either as to good search engines papers, his or her entire job or an assignment within the about school graduation job, employers and labor organizations should consider whether or not it is possible to change the education grad school job assignment or give the essay about high school day employee a lateral transfer.”); Rivera v. Choice Courier , 2004 WL 1444852 (S.D.N.Y. June 25, 2004) (employer’s failure to consider transferring employee to analysis essays, 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 transfer to lower-paying non-counselor job could satisfy Title VII if plaintiff could not be accommodated in her current position or an about high graduation day equivalent position).  Shelton , 223 F.3d at 227 (offering transfer to nurse who had religious objection to abortion procedure sometimes performed in my sisters keeper essays her department was a reasonable accommodation); EEOC v. Dresser-Rand Co. , 2006 WL 1994792 (W.D.N.Y. July 14, 2006) (summary judgment for employer denied in case on behalf of a Jehovah’s Witness who allegedly was denied transfer to essay about high school graduation, different assignment as an accommodation of his religious objection to working on search papers, 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 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 be assigned to full-time, permanent work at about high school, a casino was unreasonable; police and comparative analysis essays fire departments “need the cooperation of all members” and need them to perform their duties “without favoritism”), cert. denied , 541 U.S. 989 (2004). Because public protectors, such as police officers and essay high graduation firefighters, are obliged to 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 do my math for me their job and their religious beliefs may not be able to be resolved. However, it is not per se unreasonable for public protectors to obtain changes in 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 essay about high graduation 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. Mich. Good Search For Research Papers! 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 about, conform with the company’s grooming standards); EEOC v. My Sisters Keeper Essays! Pilot Travel Ctrs .LLC , Civil Action No. 2:03-0106 (M.D. Tenn. consent decree filed April 9, 2004) (settlement prior to ruling on essay high day, merits of claim on behalf of my sisters Messianic Christian maintenance worker, who wore beard as part of his religious practice, and was terminated for essay day, refusing to shave in compliance with employer’s no-beard policy).  United Parcel Serv ., 94 F.3d at good engines for research, 318-20; c ompare Daniels , 246 F.3d 500 (police department may be able to essay about day, 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 levertov therefore would pose an undue hardship under Title VII), cert. denied , 534 U.S. 951 (2001), with Draper v. Logan County Pub.
Library , 403 F. Supp. 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).  See, e.g., Cloutier v. Costco Wholesale Corp. , 390 F.3d 126 (1st Cir.
2004) (holding that it would pose “an undue hardship to high school graduation, require Costco to grant an exemption because it would adversely affect the employer’s public image,” given Costco’s determination that facial piercings detract from the davis thesis “neat, clean and essay about high school graduation day professional image” that it aims to cultivate).  Denying the employer’s motion for summary judgment in EEOC v. Red Robin Gourmet Burgers, Inc. Keeper! , 2005 WL 2090677 (W.D. Wash. Aug. 29, 2005), the court ruled that notwithstanding the employer’s purported reliance on a company profile and customer study suggesting that it seeks to essay about school day, present a family-oriented and 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 . . . . Red Robin must provide evidence of ‘actual imposition on co-workers or disruption of the work routine’ to grad, demonstrate undue hardship.” S ee also Brown v. Essay About High Graduation! F.L. Roberts , 419 F. Supp. 2d 7, 17 (D. Good Papers! Mass. 2006) (district court held no Title VII violation occurred when employer transferred lube technician whose Rastafarian religious beliefs prohibited him from essay high school day 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 law of the circuit, the court nevertheless observed in dicta: “If Cloutier’s language approving employer prerogatives regarding ‘public image’ is read broadly, the implications for persons asserting claims for religious discrimination in the workplace may be grave. Essay! One has to wonder how often an employer will be inclined to cite this expansive language to terminate or restrict from customer contact, on image grounds, an employee wearing a yarmulke, a veil, or the 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 religious practices of essay graduation day 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 do my for me claim on behalf of Muslim employee who was terminated pursuant to restaurant appearance code requiring male employees to 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. 02-C-6172 (N.D. Ill.) (Order of Resolution filed September 3, 2002) (resolving claim on essay high, behalf of special education 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. City of Philadelphia, 2007 WL 1866763 (E.D.
Pa. June 27, 2007) (granting summary judgment to the employer, the court ruled that the City of about school graduation 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 a Muslim police officer while in uniform, in contravention of the do my department’s dress code directive).  See U.S. v. New York State Dep’t of Corr. Servs. , Civil Action No. 07-2243 (S.D.N.Y. settlement approved Jan. High School! 18, 2008) (settlement of analysis essays case brought on behalf of Muslim correctional officers by U.S. Department of Justice providing that employee requests for high graduation day, religious exemptions from uniform and grooming requirements of 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 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 levertov line Religious Exercise”), example (d) (under the essay about First Amendment, government workplaces that allow employees to use facilities for do my math for me, non-work related secular activities generally are required to allow the essay about high graduation privilege on equal terms for 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 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. 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. Special Education! 1996) (Table) (unpublished).  Commission Guidelines , 29 C.F.R. § 1605.2(d)(2); Tooley , 648 F.2d at 1242-44 (union cannot force an school day employer, under a contractual union security clause, to terminate three Seventh-day Adventists who offered to pay an amount equivalent to dues to a nonreligious charity because the union failed to keeper, show that such an accommodation would deprive it of funds needed for essay about graduation day, its maintenance and operation); EEOC v. 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 accommodate an employee who has a sincerely held religious opposition to unionism by allowing an equivalent contribution to a mutually agreeable charity in lieu of dues payment); Burns , 589 F.2d at 406-07 (allowing equivalent charitable contribution in lieu of dues did not constitute undue hardship notwithstanding administrative cost to levertov, union and “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. Essay About School Graduation! UAW , 523 F. Supp. 2d 592 (E.D. Denise Line! Mich.
Oct. Day! 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 requiring the employee to pay to a charity of math for me his choice an high school graduation 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 special grad school essay, 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. About Graduation Day! Employees , 937 F. Denise Essay! Supp. 166, 168 (N.D.N.Y.
1996) (referring to essay about school, “mutually agreeable” charity as reasonable accommodation). Some CBAs have charities listed in 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. 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 denise essay line, union where loss of essay school graduation plaintiff’s dues represented only .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 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 all” and union’s asserted fear of many religious objectors was based on mere speculation; the denise line court noted, however, that if “in the essay high graduation future, the essays expressed fear of widespread refusal to school day, 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 for me 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. Essay School! Springfield Educ. Ass’n , 319 F. Supp. Denise Essay! 2d 90 (D. Mass.
2003) (not a reasonable accommodation to 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). Cf. Madsen v. Associated Chino Teachers, 317 F. Supp. School Day! 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 dues to grad school 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 essay school graduation day EEOC v. Ohio Civil Service Employees Association , Case No. Good Engines Papers! 2:05-CV-799 (S.D.
Ohio consent decree filed Sept. School Graduation! 2006) (lawsuits filed by Civil Rights Division of U.S. Department of Justice and keeper EEOC against Ohio state agencies and their employee union, respectively, over school day their refusal to davis moore thesis, accommodate state employees’ religious objections to payment of union dues unless the essay high school graduation employees were members of churches that have “historically held conscientious objections to my sisters keeper essays, joining or financially supporting” unions; pursuant to settlement reached prior to ruling by high, court on merits, the consent decree provides that a state employee is education grad school essay, permitted to pay an amount equal to about, the union service fee to 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. 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 my sisters, accommodate an employee who has a sincerely held religious opposition to unionism by allowing equivalent contribution to mutually agreeable charity in lieu of dues payment, even if he “is not a member of an organized religious group that opposes unions”).  Wilson, 58 F.3d at essay graduation day, 1341-42 (given disruption among co-workers actually caused in workplace, employee’s request to wear at do my math, all times a button containing a graphic photograph of 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 jury).  Wilson, 58 F.3d at 1341-42 (employer denied certain accommodation options because of demonstrated disruption to 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 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 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 phrase with co-workers and supervisors who did not object, but prohibited her from using the phrase with customers where at least one regular client objected; allowing her to high, use the good search phrase with customers who objected would have posed an undue hardship); Banks v. Serv. Am. About High School! Corp. , 952 F. Supp. 703 (D. Denise Levertov Essay! 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 essay high school day “Praise the Lord,” presented a triable issue of fact regarding whether they could have been accommodated without undue hardship; in the absence of do my math 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. , 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 beliefs of some customers and therefore cost the high day company business).  See Knight , 275 F.3d at 164-65 (allowing employee to evangelize clients would cause undue hardship). Compare Baz v. Comparative Literary Analysis Essays! 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 would have violated the First Amendment Establishment Clause, to about day, 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 to the davis moore thesis, whether courier was denied reasonable accommodation where employer could have accommodated courier’s need to essay high school, 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 my sisters essays, Lord”).  Moreover, a private employer’s own rights under the First Amendment Free Speech Clause may provide a defense to day, a Title VII accommodation claim, if the proposed accommodation would require the 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 First Amendment Establishment Clause would likely justify its refusal to display a religious message. However, Susan’s display probably would not violate the keeper Establishment Clause, or pose an undue hardship for Title VII purposes, because it has a minimal effect on any co-workers who saw it, whereas Roger’s display might be perceived to constitute government endorsement of a particular religion and high pose an do my Establishment Clause violation. See Berry v. Essay About School Graduation! Dep’t of Social Servs. School Essay! , 447 F.3d 642 (9th Cir. 2006) (accommodating social worker’s request to display religious items in his cubicle and to discuss religion with clients would have posed an about high graduation undue hardship under Title VII on county social services department since the accommodations sought would create a danger of the special essay employer violating the Establishment Clause); cf. Peloza v. Capistrano Unified Sch. High Graduation Day! 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 denise essay talking with students about religion during school day was justified by school district’s interest in avoiding Establishment Clause violation); Draper v. Logan County Pub. Library , 403 F. Supp. 2d 608 (W.D. Ky. 2005) (public library’s decision to school, bar employee from wearing necklace with cross was not justified by library’s purported interest in 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 according to the davis moore rafters”).  Knight , 275 F.3d 156; Grant v. Fairview Hosp. Healthcare Serv., 2004 WL 326694 (D. Minn. 2004) (ultrasound technician was offered a reasonable accommodation of his religious beliefs when hospital excused him from performing ultrasounds on essay about graduation day, women contemplating abortions; hospital did not have to allow technician to literary analysis, provide pastoral counseling, as that accommodation would have posed an undue hardship); see also Grossman v. South Shore Pub.
Sch. Dist. About High! , 507 F.3d 1097 (7th Cir. 2007) (affirming summary judgment for school district on terminated guidance counselor’s First Amendment free exercise and according davis thesis Title VII claims, the court ruled that the school district was permitted to terminate counselor for essay school, her conduct, even if her actions of praying with students who approached her for guidance and throwing away school contraceptive education materials were motivated by comparative literary analysis essays, her religious beliefs; there was insufficient evidence that her termination was based on her religious views alone as opposed to these actions, which the school district was entitled to essay about graduation, 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. Native Angels Homecare Agency , Civil Action No. 7:06-cv-83 (E.D.N.C. My Sisters! consent decree filed March 22, 2007) (settlement prior to decision by court on essay about high graduation day, 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 denise essay line Title VII where her superior advised her that she had obligation to high school, 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 beyond the good search engines scope of 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 high these items does not violate the my sisters essays establishment clause of the about graduation First Amendment. See County of Allegheny v. ACLU , 492 U.S.
573 (1989) (stand-alone crèche on education, county courthouse steps violated establishment clause, but display elsewhere of Christmas tree next to a menorah and a sign proclaiming “liberty” did not); Lynch v. Donnelly , 465 U.S. 668 (1984) (holding that government-sponsored display of about day crèche did not violate establishment clause because it was surrounded by various secularizing symbols, thus precluding a perception of government endorsement of religion); Federal Workplace Guidelines , supra n.11 at Section D (example (b)). To The Davis Moore Thesis! For a discussion of both Title VII and establishment clause claims arising from about school graduation day holiday decorations in federal government employment context, see, e.g., Spohn v. West , 2000 WL 1459981 (S.D.N.Y. Oct. 2, 2000). In the private sector, establishment clause constraints would not apply. Special Education Grad School Essay! As a best practice, however, all employers may find that sensitivity to the diversity of their workplace promotes positive employee relations.  An employer may accommodate the employee’s religious belief by substituting an alternative technique or method that does not conflict with the employee’s religious belief or by excusing the essay about school employee from comparative literary analysis essays that part of the training program that poses a conflict, if doing so would not pose an graduation day undue hardship.
 Many employers have policies that require employees to treat each other with “courtesy, dignity and respect.” This terminology fits within the ambit of “professionally” as used in the example. See also Peterson v. My Sisters Keeper! Hewlett-Packard Co. , 358 F.3d 599 (9th Cir. 2004) (it would have constituted undue hardship for about graduation, employer to accommodate employee by eliminating portions of its diversity program to which employee raised religious objections; to do so would have “infringed upon denise levertov essay line the company’s right to promote diversity and encourage tolerance and about school good will among its workforce”). 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 undue hardship to accommodate an employee by my sisters keeper, excusing him from the training or a portion thereof. Essay High Day! If the training required or encouraged employees to 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 accommodate an employee who objects to participating on my sisters keeper essays, religious grounds. Buonanno v. ATT Broadband, LLC, 313 F. Supp.
2d 1069 (D. Colo. 2004) (company can require and instruct employees to treat co-workers with respect in accordance with corporate diversity policy, but violation of Title VII occurred where company did not accommodate employee’s refusal on religious grounds to sign diversity policy asking him to “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. About Graduation Day! § 1605.2.  EEOC v. WCM Enter., Inc. , 496 F.3d 393 (5th Cir.
2007) (evidence was sufficient for employee to keeper essays, proceed to essay about high school, trial on claim that he was subjected to hostile work environment harassment based on both religion and national origin where harassment motivated both by 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. 1996) (Catholic Filipino employee made out a prima facie case of national origin and religious discrimination, although he did not prevail on the merits).
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Free Information Technology essays. Nowadays people tend to read articles or news directly from gadgets such as Smartphone and tablets. Wea??re already seeing some changes, even with semantics. For example, you publish a book, but you launch an e-book. Essay About School. E-books are more similar to the Internet than to traditional books. To The Moore. The lengths of e-books are changing. E-books can be shorter than print books, as seen with long-form journalism and essay high graduation day, e-shorts by Byliner, Atavist, Kobo, and according to the davis moore thesis, Kindle Singles. E-books can also be published as serials, allowing for the agile model of publishing.
Readers now have the essay about school chance to give input and help shape the content. The evolution of the E-Books make people change their reading habits. These habits lead to reduction of people visited the library. Library can be defined as a collection of sources of information and similar resources, made accessible to a defined community for reference or borrowing. Levertov. It provides physical or digital access to material, and may be a physical building or room, or a virtual space, or both.
In another words, people love to subscribe eBooks through gadgets than visit the library to find a books. In these situation library should play a role in increasing their information about people interest in the form of books and Journals. High Graduation. It is because more people nowadays tend to read E-Books or E-Journals than visiting the library. Though e-readers are becoming more and more popular, theya??re not outdistancing print, and therea??s no indication that they will even in the future. Education Grad Essay. In 2012, researcher found that of the high graduation adults questioned, only 5 percent of them read exclusively e-books. People of special education grad, all ages prefer print books than E-books because of many reason. It will cover the pro and cons of print books and E-books. There will be a justification made in these report. About School Day. The purposes of this report are;
i) To justify the statement a?˜..Libraries should provide more books rather than invest in new technology such as ebooks and e-journals. ii) The pros and cons of E-Book and E-Journals. With the advance of phones, tablets, and according davis, ereaders, ebooks have become a popular reading standard. Still, there’s something about the feel of an old-fashioned paper book. Ebooks can be read practically anywhere on anything, it really help when we in about, work and have no time to open a book.
On another hand, some researchers discovered that 62 percent of the respondents actually prefer printed books to e-books, even though theya??re technically the technological and digital generation. i) Paper books cannot be deleted and real experience. There are few opinion that agree, library should invest more in books because books is more practical than ebooks. One of them are; a??The ebook I was reading told me I was 84% finished with the book when the book ended.
The remaining 16% was excerpts from the author’s other books, an denise levertov, author interview, and a discussion guide. Paper books are far superior when it comes to letting you know your place in about high day, a book, and that’s why I prefer booka?? In these case library should give more attention to math for me providing a books than invest in technology. Libraries should be responsible for keeping paper books as one day the essay school graduation day internet may not exist. It is a known fact that paper books are the only reliable and safe source of information. The best way to start and finish your book is reading the book itself. One day your gadget may lost all the data because of technical problem such as virus and malware. There is no guarantee that ebooks will kept forever in our phone. Leta??s take an do my, example, when A format their phone or laptop the data store in it will not exist and may deleted. School Graduation Day. It will destruct the good engines papers ebooks in essay about high graduation day, their phone. Lending print books couldna??t be easiera?” just grab the book and pass it along; no set-up or hassle involved.
There is just something about print books that ebook cana??t compete with, the way the spine cracks the fist time ita??s open, the way the pages feel in your hands, the rich scent of paper, the way they wear over time and according to the moore thesis, gain character. People will appreciate the books when they can touch, feel and read it. The best part it we can hold a pen and write down anything that we thought about every passage we read. While ebooks are probably going to be around for quite a while, there is something really special about being able to essay high school graduation hold something in comparative, your hands that your parents, grandparents, and other family members had when they were young. Some people love to sit with their family and holding a book than holding a tablet. It is because they will more concentrate on the book their read. Seeing a shelf full of school graduation, books and topics is inspiring and stimulates the to the moore thesis imagination. Keeping books in handphone and essay about high school, bookshelf is much different.
When we keep books in bookshelf we can see the books in my sisters keeper essays, our house or any place. If we keep the books in our gadgets, it was like the about school graduation day books we read are never exist. The situation is we read and delete rather than read and keep it for keeper, our collection. It’s no secret that reading is good for you. Just six minutes of reading is about graduation enough to my sisters reduce stress by 68%, and numerous studies have shown that reading keeps your brain functioning effectively as you age. One study even found that elderly individuals who read regularly are 2.5 times less likely to develop Alzheimer’s than their peers. But not all forms of essay day, reading are created equal. ii) E-books are damaging our health.
Ebooks will damaging our physical and mental health than we might think. When we read through smartphone, the math for me light from the screen may destruct our sight and lead to eyes problem. Researchers have been examining the differences between reading regular books and e-books for years. Many of the studies have shown that reading old-fashioned books has plenty of advantages over e-books, which can be gateways to essay about high school graduation other electronic distractions, all of which screw with your sleep. Analysis Essays. This is essay graduation day why you should ditch the screen for printed pages.
Using laptops or phones late at night to read doesn’t make way for restful sleep. Reading helps you de-stress faster or just as fast as listening to music, taking a walk, or having a cup of tea or coffee, according to a 2009 study. When researchers measured heart rate and muscle tension, they found that people relaxed just six minutes into reading. But reading on a device might cancel out special grad essay, this effect, and may even impact your stress levels negatively. Repeated use of mobile phones or laptops late at high school day night has been linked to depression, higher levels of stress, and fatigue among young adults. Constant use of according to the thesis, technology not only disrupts our sleeping patterns and throws off our circadian rhythms, but it fosters a shorter attention span and fractured focus a?” online, we jump from meme to meme and link to link, checking Facebook intermittently. Social media and technological distractions also always seem to foster guilt and regret, and about graduation day, before we know it, three hours have passed and our brains feel like mush. People nowadays love to read something with visual than directly words by according to the thesis, words. Thata??s why people will love to check facebook than open their books in their smartphone or tablets.
Reading an old-fashioned paper book might seem out of style, wasteful, or impractical. High School Graduation Day. But dona??t underestimate the simplicity of holding a physical book in essays, your hands, flipping through the pages, and not having anything else to shift your focus to. Commit to the classic paper book and you’ll get the full, healthier experience. Reading in print helps with comprehension. A 2014 study found that readers of a short mystery story on a Kindle were significantly worse at remembering the order of events than those who read the same story in paperback. About High. Lead researcher Anne Mangen of do my math for me, Norway’s Stavanger University concluded that “the haptic and tactile feedback of a Kindle does not provide the same support for mental reconstruction of school graduation, a story as a print pocket book does.” iii) Survey about special essay Prints books and E-books. Textbook makers, bookstore owners and college student surveys all say millennials still strongly prefer print for pleasure and learning, a bias that surprises reading experts given the about school day same groupa??s proclivity to consume most other content digitally.
Marlene England (Owner of a bookstores) said millennials regularly tell her they prefer print because ita??s a??easier to follow stories.a?? Pew studies show the highest print readership rates are among those ages 18 to 29, and the same age group is still using public libraries in large numbers. Don Kilburn, North American president for Pearson, the education essay largest publisher in the world and the dominant player in education, said the move to essay about high school day digital a??doesna??t look like a revolution right now. It looks like an evolution, and ita??s lumpy at best.a?? And it can be seen most prominently on college campuses, where students still lug backpacks stuffed with books, even as they increasingly take notes (or check Facebook) on laptops during class. This is the report made by The Washington Post. This post shows that more people will choose prints book than E-books. In order to justify this report, there is a survey has been conducted with 20 respondent. It will ask about which the respondent prefer in essays, finding information. The question will cover their choices about prints books or E-books. Survey about Print Books Vs E-books. 1. How many Books have you read in the last year? a??11 or more Books.
2. About. Have you purchased an essay, E-book or a print book in the last 12 months? a??Ia??ve purchased only E-books. a??Ia??ve purchased only printed books. a??Ia??ve bought both e-books and essay school graduation, printed books. a??No Ia??havena??t purchased either. 3. Do you prefer to read E-Books or Print Books? a??Print books only. 4. Do you agree with the following statement: a??Library should invest more in books publication than ebooks and e journals..a??
a??Neither agree or disagree. Result of the survey. 1. How many Books have you read in the last year? Among the 20 respondent the majority will read four to five books in a year. 2. Have you purchased an according to the thesis, E-book or a print book in about high school graduation, the last 12 months? These finding shows more people prefer to essay purchased both e-books and high school graduation, printed books. Printed books are more popular among the reader. 3. Do you prefer to read E-Books or Print Books? The third questions shows that most of the respondent prefer print books than E-books. Many people wrote in good for research papers, their comments and had clear reasons for avoiding the screen like, a??Therea??s something about curling up with a good book in high day, onea??s hands that cana??t be beata?? and a??I spend enough time on computers at work, need a breaka?? to a??I like the feel of the pagesa??. Seems like the smell and feel of paper, curling up on a rainy afternoon with a mug of good engines for research papers, tea is high school graduation better than seeing on good search engines papers, screen with brighting light that can distract our eyes.
4. Do you agree with the essay high school following statement: a??Library should invest more in books publication than ebooks and good search engines for research papers, e journals..a?? The last questions is about the essay high school main topic that need to justify with the survey. More respondents strongly agree that library should vary and invest in print books to denise levertov satisfied people needs in reading a print books. The result show that most of them strongly agree library should invest more on graduation, prints book than E-books. We will forget how good to hold a books in do my for me, real and high school graduation day, appreciate the denise levertov essay writing in the print books. Library will play a main role in promoting a people to read a print books. Readers absorb less on Kindles and high school, iPads than when they read on denise levertov essay line, paper. A few years back, researcher wrote that it’s faster to read paper books than e-books, study shows. For a conclusion, it is better if we invest more on printed books because many people cana??t forget the smell of the books and also the sentimental value when we hold a book than smartphones.
The survey will be the evidence that print books may allow for deeper reading and essay about high, stronger understanding and grad school, memory than digital books. Nostalgia, comfort and convenience seem to be big reasons in favor for keeping the physical book alive. Another study show that sixteen to school graduation day 24-year-olds are known as the super-connected generation, obsessed with snapping selfies or downloading the latest mobile apps, so it comes as a surprise to learn that 62% prefer print books to ebooks. The two big reasons for preferring print are value for money and an emotional connection to grad physical books. Essay About. On questions of special education essay, ebook pricing, 28% think that ebooks should be half their current price, while just 8% say that ebook pricing is essay about school graduation day right. Sometimes books in literary analysis, digital form is about school graduation day expensive than books in according moore thesis, printed form. People nowadays will consider much on the value of the things they buy. It is better to buy something that we can see and hold than in virtual form. Search our thousands of essays: If this essay isn't quite what you're looking for, why not order your own custom Information Technology essay, dissertation or piece of coursework that answers your exact question? There are UK writers just like me on high graduation, hand, waiting to help you.
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