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Ansonia Bd. of Educ. v. Philbrook - 479 U.S. 60, 107 S. Ct. 367 (1986)


Any reasonable accommodation by the employer is sufficient to meet its accommodation obligation. The employer violates the statute unless it demonstrates that it is unable to reasonably accommodate an employee's religious observance or practice without undue hardship on the conduct of the employer's business. 42 U.S.C.S. § 2000e(j). Thus, where the employer has already reasonably accommodated the employee's religious needs, the statutory inquiry is at an end. The employer need not further show that each of the employee's alternative accommodations would result in undue hardship. The extent of undue hardship on the employer's business is at issue only where the employer claims that it is unable to offer any reasonable accommodation without such hardship


Pursuant to a collective-bargaining agreement, plaintiff Philbrook was allowed three days leave annually for religious observance, but employees were prohibited from using personal days for additional religious observance, which forced Philbrook to take time off without pay. Philbrook brought an action against defendant employer, the Ansonia Board of Education, alleging religious discrimination. The district court concluded that Philbrook failed to prove his case, but the United States Court of Appeals for the Second Circuit reversed and remanded, concluding that Philbrook had made a prima facie case and that Ansonia Board had to accept Philbrook's proposal for accommodation unless the accommodation caused an undue hardship tthe employer's business. Defendant Ansonia Board of Education petitioned for certiorari review.


Did the employer meet its obligation under § 701(j) of the Civil Rights Act of 1964, codified at 42 U.S.C.S. 2000e(j), when it demonstrated that it provided a reasonable accommodation to the employee?




The United States Supreme Court affirmed the judgment, but disagreed that the employer had to accept the employee's suggestion for accommodation. The Court held that petitioner employer could have met its obligation to accommodate under § 701(j) of the Civil Rights Act of 1964, codified at 42 U.S.C.S. 2000e(j), when it allowed respondent employee unpaid leave. The question on remand was whether the unpaid leave was a reasonable accommodation in light of how personal days were applied to non-religious purposes.

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