In Brown v. F.L. Roberts & Co., a lube technician, assigned to work exclusively in a cold and dangerous “lower bay” away from customer view after he refused to cut his hair on account of his Rastafarian religion, sued his employer – a Massachusetts Jiffy Lube operator – for religious discrimination. In reversing the lower court’s dismissal of the complaint, the Massachusetts appellate court ruled that a jury must decide whether requiring the employee to work away from public view was a reasonable accommodation. The court opined that there was no discussion between management and employee about alternatives to working in the lower bay, and the employer offered no evidence that the plaintiff’s Rastafarian hair style decreased sales or affected customer satisfaction.