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Originally appeared in Labor and Employment Newsletter - February 2002
In Ali v. Alamo Rent-A-Car, the Court of Appeals for the Fourth Circuit held that refusal to accommodate an employee’s religious beliefs does not violate Title VII’s prohibition against religious discrimination unless the employee suffers an adverse employment action.
Alamo transferred a management trainee, Zeinab Ali, to a new position after she refused to stop wearing a head scarf, which she wore in accordance with her religious beliefs. Ali sued Alamo, alleging that its refusal to allow her to wear the head scarf constituted religious discrimination. The district court granted Alamo’s motion to dismiss on the grounds that the complaint failed to allege an adverse employment action.
Ali appealed, conceding that she did not suffer an adverse employment action, but arguing that religious discrimination claims do not require such a showing. Ali relied on the accommodation provision in Title VII’s definition of "religion," arguing that an employer’s refusal to accommodate should be sufficient to establish religious discrimination. The Fourth Circuit disagreed, holding that an adverse employment action is a necessary prerequisite to a finding of all Title VII discrimination. Because Ali conceded that she did not suffer an adverse employment action, the court declined to consider exactly what constitutes an adverse employment action under Title VII.
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