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Chaplin v. Du Pont Advance Fiber Sys. - 124 F. App'x 771 (4th Cir. 2005)

Rule:

To establish a prima facie religious accommodation claim, a plaintiff must establish that (1) he has a bona fide religious belief that conflicts with an employment requirement; (2) he informed the employer of this belief and requested an accommodation thereof; and (3) he was disciplined for failure to comply with the conflicting employment requirement.

Facts:

In 2000, Du Pont Advance Fiber Systems, Du Pont Spruance, and Du Pont Textiles & Interiors, Incorporated (collectively, "Du Pont") instituted a policy banning the display of offensive symbols--including the Confederate battle flag--on Du Pont property. Certain employees brought a Title VII action, 42 U.S.C.A. § 2000e et seq., alleging employment discrimination based upon their race, religion, and national origin. The district court dismissed the actions. The district court issued a subsequent order granting Du Pont's motion for fees and expenses against appellants as to all claims and granting in part its motion for sanctions against Lyons as to the religious and racial discrimination claims.

Appellant Kirk D. Lyons appealed the award of sanctions against him in connection with his clients' Title VII claims for religious and racial discrimination. Lyons asserted that the district court abused its discretion in imposing sanctions against him pursuant to Fed. R. Civ. P. 11(b)(3) because he conducted an objectively reasonable investigation of the factual basis for the claims prior to filing the action.

Appellants Kevin Lambert Chaplin, James Philip Jones, Robert Coleman Lewis, Marvin L. Oliver, Lynn Eugene Ritenour, David Eugene Rowlette, and Stephen Jackson Turley appealed the award of attorney's fees imposed upon them in connection with their Title VII claims for national origin, religious, and racial discrimination.

Appellants contended that the district court abused its discretion in awarding attorney's fees under 42 U.S.C.A. § 2000e-5(k) because appellants' claims were not frivolous, unreasonable, or without foundation.

Issue:

Did the district court abuse its discretion in imposing sanctions and awarding attorney's fees to an employer, after employees' Title VII employment discrimination claims were dismissed?

Answer:

No

Conclusion:

Finding no abuse of discretion, the United States Court of Appeals affirmed the district court's award of sanctions and attorney's fees. The Court found that the religious discrimination claim lacked any factual basis because no evidence existed in the record to suggest that the employees requested an accommodation of their religious beliefs prior to the filing of their Equal Employment Opportunity Commission charge. Applying the four-prong test to establish a prima facie religious accommodation claim, the Court held that the appellants failed the second prong:  they failed to inform employer DuPont of any bona fide religious belief that conflicted with an employment requirement and failed to request an accommodation. Although the appellants could bring causes of action for both race discrimination and national origin discrimination, the race discrimination claim was unwarranted because the employees failed to aver that they had suffered any adverse employment action. Regarding the fee award, it was unreasonable for the appellants to bring the action based upon a policy that caused them nothing more than aggravation.

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