In Ramos v. Envoy Air Inc., Civil Action No. 3:23-CV-2276-X, 2024 WL 2754055 (N.D.Tex. May 29, 2024), the court, inter alia, denied defendant’s motion to dismiss plaintiff’s claim of religious discrimination under Title VII of the Civil Rights Act of 1964.
From the decision:
[Title VII] defines religion broadly to include all aspects of religious observance and practice, as well as belief. And it requires employers to accommodate the religious practice of their employees unless doing so would impose an ‘undue hardship on the conduct of the employer’s business. In short, Title VII imposes on employers both a negative duty not to discriminate and a positive duty to accommodate.
Here, Ramos alleges that Envoy violated Title VII by refusing to accommodate her religious practice of observing the Sabbath and instead terminating her. The rule for disparate-treatment claims based on a failure to accommodate a religious practice is straightforward: An employer may not make an [employee’s] religious practice, confirmed or otherwise, a factor in employment decisions.
At the motion to dismiss stage, there are two ultimate elements a plaintiff must plead to support a disparate treatment claim under Title VII: (1) an adverse employment action, (2) taken against a plaintiff because of her protected status. [A]lthough a plaintiff does not have to submit evidence to establish a prima facie case of discrimination under [the] McDonnell Douglas [standard] at this stage, [s]he must plead sufficient facts on all of the ultimate elements of a disparate treatment claim to make [her] case plausible. A prima facie case of religious discrimination under Title VII requires a plaintiff to show: (1) she held a bona fide religious belief, (2) her belief conflicted with a requirement of her employment, (3) her employer was informed of her belief, and (4) she suffered an adverse employment action for failing to comply with the conflicting employment requirement.
Ramos clearly pled facts on all four elements of a prima facie case of religious discrimination, and therefore, plausibly alleged a religious discrimination claim under Title VII. First, she alleged that she is a member of the Seventh-day Adventist Church, and her religious beliefs prohibit her from working on the Sabbath, which is observed from sundown on Friday until sundown on Saturday. Next, she alleged that that religious practice conflicted with Envoy’s requirements for her work schedule and attendance. Ramos also alleged that Envoy was informed of her religious beliefs and practice because she notified Envoy of her religious belief and her need for an accommodation. Lastly, she alleges that Envoy denied her religious accommodation request and terminated her solely because of her absences on her Sabbath.
[Internal quotation marks omitted.]
The court thus concluded that plaintiff plausibly alleged a claim for Title VII religious discrimination.