An employee must show that an adverse employment decision was motivated by the employee’s need for a religious accommodation in order to establish a prima facie religious discrimination case under Title VII of the Civil Rights Act of 1964, the U.S. Court of Appeals for the Second Circuit ruled in a precedential opinion issued on July 15, 2026.
Quick Hits
In Bergin v. New York State Unified Court System, the Second Circuit held that, to bring a failure to accommodate claim under Title VII of the Civil Rights Act of 1964, an employee must show that the need for a religious accommodation provided motive for an adverse employment decision.
The court’s decision revokes the Second Circuit’s previous prima facie test for a Title VII claim of failure to accommodate religion and adopts the test set forth in the 2015 Supreme Court of the United States’s decision in EEOC v. Abercrombie & Fitch Stores, Inc.
The Second Circuit ruling reinforces that, to establish a prima facie case of… Read the complete article here...
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