The Sixth Circuit Court of Appeals provides a common sense decision in Yeager v. FirstEnergy Generation Corporation, reminding employers they are not liable under Title VII when “accommodating an employee’s religious beliefs would require the employer to violate federal. . . law.”
Donald Yeager, a Fundamentalist Christian, disavowed and disclaimed his social security number when he was 18 years old based on his sincerely held religious beliefs. When Yeager applied for an internship with FirstEnergy he refused to supply the number. FirstEnergy subsequently refused to hire him.
Mr. Yeager filed suit in the federal district court in March of 2014, alleging FirstEnergy discriminated against him on the basis of religion in violation of Title VII and Ohio Rev. Code Chapter 4112, when it refused to hire him or terminated him because he failed to provide his social security number. Mr. Yeager specifically alleged FirstEnergy refused to reasonably accommodate his religious observance and practice even though his request would not cause an undue hardship on its business operations.
To successfully plead a prima facie case of religious discrimination under Title VII, Yeager needed to demonstrate:
- that he held a bona fide religious belief in conflict with an employment requirement;
- he informed the employer of the belief; and
- the employer did not hire him because of his failure to satisfy the requirement.
FirstEnergy filed a Rule 12(b)(6) motion to dismiss, arguing Yeager failed to state a claim upon which relief could be granted. FirstEnergy further argued it did not create an employment requirement in conflict with Yeager’s religious belief, instead it complied with the IRS requirement that all employees have a social security number. FirstEnergy argued it was complying with federal law. The district court agreed with FirstEnergy, and dismissed Yeager’s complaint.
Yeager appealed to the Sixth Circuit, which affirmed the district court’s ruling. The court found Yeager could not establish a prima facie case of religious discrimination. More importantly, the court held, Title VII does not require an employer to reasonably accommodate an employee’s religious beliefs if such accommodation would violate a federal statute.