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Employment — religious discrimination

United States Court of Appeals For the Seventh Circuit


Employment — religious discrimination — accommodation

Where an employee requested three weeks of unpaid leave to attend his father’s funeral in Nigeria, the employer was sufficiently on notice that the request sought a religious accommodation.

“These requests to Heartland would allow a reasonable jury to find that Adeyeye gave sufficient notice of the religious nature of his request for unpaid leave. His first request referred to a ‘funeral ceremony,’ a ‘funeral rite,’ and animal sacrifice. He explained that participation in the funeral ceremonies was ‘compulsory’ and that the spiritual consequence of his absence would be his own and family members’ deaths. A reasonable jury could certainly find that the letter’s multiple references to spiritual activities and the potential consequences in the afterlife provided sufficient notice to Heartland that Adeyeye was making a religious request. The second request was not as specific as the first, but referred to a funeral ceremony and burial ceremony and the importance of his attendance as the first child and only son. At least when read with the first letter in mind, it also conveyed a religious request with sufficient clarity to preclude summary judgment on the issue.”

Reversed and Remanded.

12-3820 Adeyeye v. Heartland Sweeteners, LLC


Appeal from the United States District Court for the Southern District of Indiana, Hamilton, J.

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