Melvin D. Reed v. The Great Lakes Companies, Inc.
330 F.3d 931, 2003 WL 21256230 (2003)
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Rule of Law:
Under Title VII, an employee alleging a failure to accommodate a religious belief must give the employer fair warning of the employment practices that interfere with their religion. An employer cannot be held liable for intentional religious discrimination if it is unaware of the employee's religion or lack thereof.
Facts:
- Great Lakes Companies, Inc. hired Melvin Reed as an executive housekeeper for a new Holiday Inn.
- One of Reed's duties was to oversee the placement of Bibles, supplied for free by the Gideons, in every guest room.
- The hotel manager informed Reed he was to attend a meeting with the Gideons to receive the Bibles.
- During the meeting, the Gideons unexpectedly began reading from the Bible and praying, which Reed found offensive.
- Reed abruptly left the meeting before it concluded.
- Later, the manager confronted Reed, stating that Reed had embarrassed him and must follow orders.
- Reed responded, 'You can’t compel me to a religious event,' and when the manager insisted, Reed replied, 'Oh, hell no, you won’t, not when it comes to my spirituality.'
- The manager immediately fired Reed for insubordination. At no point did Reed disclose his specific religious beliefs or lack thereof to his employer.
Procedural Posture:
- Melvin Reed filed a lawsuit against Great Lakes Companies, Inc. in the U.S. District Court for the Eastern District of Wisconsin, alleging religious discrimination under Title VII.
- The district court granted summary judgment in favor of the defendant, Great Lakes.
- The district court also imposed sanctions on Reed, including a fine and an order to write a letter of apology, based on his history of prior litigation.
- Reed (Plaintiff-Appellant) appealed both the grant of summary judgment and the sanctions order to the U.S. Court of Appeals for the Seventh Circuit.
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Issue:
Does an employer violate Title VII by terminating an employee for insubordination after the employee walked out of a work meeting that unexpectedly turned religious, when the employee refused to disclose his specific religious beliefs or explain how they conflicted with his job duties?
Opinions:
Majority - Posner, Circuit Judge
No. An employer does not violate Title VII by firing an employee for insubordination under these circumstances. To establish an intentional discrimination claim, the plaintiff must show the employer acted because of the employee's religion; here, the employer did not even know Reed's religion and fired him for embarrassing the manager and being insubordinate. For a failure to accommodate claim, the employee bears a reciprocal duty to provide the employer with fair warning of the conflict between their religious beliefs and an employment requirement. Reed failed to meet this duty by refusing to disclose his beliefs and instead asserting an unqualified right to disobey orders he deemed inconsistent with his vague 'spirituality,' thus failing to trigger the employer's duty to accommodate.
Concurring-in-part-and-dissenting-in-part - Ripple, Circuit Judge
No. Judge Ripple concurs with the majority's conclusion that Great Lakes did not fail to accommodate or intentionally discriminate against Reed, as Reed's own deposition showed he was unwilling to enter into a dialogue with his employer on the matter. However, he dissents from the majority's decision regarding sanctions. He believes that neither of Reed's claims was frivolous and would therefore reverse the district court's sanctions order outright, rather than vacating and remanding it for reconsideration.
Analysis:
This case clarifies the initial burden on the employee in a religious accommodation claim under Title VII. It establishes that the employee must affirmatively inform the employer of a specific, religion-based conflict with a work requirement to trigger the employer's duty to accommodate. The decision protects employers from liability where an employee is insubordinate after a conflict and fails to engage in the interactive process by keeping their beliefs a secret. It reinforces the principle that Title VII's accommodation duty is a two-way street requiring cooperation from both parties.
