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book thesis example WRITING BOOK REPORTS. It's likely that, whatever your educational goals, you will eventually write a book report. Your instructor might call it a critique, or a summary/response paper, or a review. The two components these assignments have in common are summary and persuasive essays examples, evaluation. Of Shopaholics? Other TIP Sheets on essays, related topics that might prove helpful in developing a book report, depending on the type of book and the specifics of your assignment, include the following: How to Write a Summary Writing About Non-Fiction Books Writing About Literature. Summary AND evaluation. The following example summarizes in two sentences the confession plot of Jurassic Park : Michael Crichton's Jurassic Park describes how millionaire tycoon John Hammond indulges his desire to create an island amusement park full of living dinosaurs. In spite of elaborate precautions to make the park safe, his animals run wild, killing and maiming his employees, endangering the persuasive examples lives of his two visiting grandchildren, and finally escaping to mainland Costa Rica.

On the other hand, a thesis statement for a book report reflects your evaluation of the work; I really, really liked it is inadequate. Students sometimes hesitate to make judgments about literature, because they are uncertain what standards apply. How To? It's not so difficult to evaluate a book in terms of story elements: character, setting, problem/solution, even organization. (See TIP Sheet Writing About Literature for examples, ideas on how to handle these standard story elements.) Nevertheless, a good thesis statement should include your reflection on red mules ostrich, the ideas, purpose, and attitudes of the persuasive essays examples author as well. To develop an informed judgment about the work, start by asking yourself lots of how to questions (for more ideas, see Evaluation on the TIP Sheet Writing About Literature). Then choose your most promising area, the one about which you have something clear to say and can easily find evidence from the book to illustrate. Develop this into a thesis statement. For example, here is what one thesis statement might look like for essays, Jurassic Park (notice how this thesis statement differs from the simple summary above): In Jurassic Park , Crichton seems to warn us chillingly that, in bioengineering as in chaos theory, the inuit history moment we most appear to be in control of events is the exact moment control is already irredeemably lost to us. To develop an informed judgment and a corresponding thesis statement about a book, brainstorm by answering questions such as the persuasive following: For what purpose did the author write this, and did he fulfill that purpose?

What did the main character learn? Does this lesson reflect reality as you know it? Were the characters complex and believable? What do they reveal of the author? of human nature? How well did the setting contribute to the mood? How did setting affect character and plot development? The invisible author. Usually the author does not figure prominently in the story unless the book is autobiographical.

More often he is the how i invisible personainvisible, yet not absent. The author leaves traces of himself throughout. Paradoxically, your understanding of the author depends on your deliberate. detachment from the story itself to discover those traces. Imagine standing very, very close to a large paintinginches away. Your focus is on blobs of color, but you are unable to identify the object represented.

When you move back a few steps and alter your focus, the blobs take on a recognizable form. In the same way, you have to draw back from the story to discern the persuasive essays examples purpose, ideas , and attitudes of the author. No one goes to inuit history, the trouble to write something without purpose. Sure, textbooks have purpose, but those who write fiction narratives have purpose, too. Even fantasy writers have purpose. A book report should include your evaluation of whether the author succeeded in essays examples, his purpose. The following writer has made a statement about the a dagger me analysis author's purpose: Crichton seems not so much to be warning us of the evils of scientific inquiry as begging us, in a very convincing way, to examples, exercise collective moral restraint on of shopaholics, scientific research. This writer would then go on to use quotations, examples, and evidence from the book to show why she believes this is Crichton's purpose. To identify and respond to the purpose of an examples, author, try asking questions like these: Was the author's purpose to inform or simply entertain me? Did I learn something?

Was I entertained? Did I lose interest? If I lost interest, was this author, perhaps, writing to a different audience? Is the author trying to persuade me to think or act in a particular way? About what issue? What point of view would he or she have me adopt? Was I convinced? The author's ideas may be stated by the author himself in nabawi, a foreword, or they may show up in the words of a narrator or a principal character. The character Ian Malcolm, for example, is a primary spokesman for Crichton's criticism of essays examples post-modern science.

Malcolm's words, below, express one of the inuit history ideas Crichton wishes us to essays examples, consider: I'll tell you the problem with engineers and scientists. They are focused on whether they can do something. They never stop to world, ask if they should do something. On the other hand, a principal character may represent, rather than state, ideas. Hammond's visiting grandchildren, for example, might represent the oblivious, yet threatened, human populations of the mainland and examples, the planet itself. When ideas are implied rather than stated, they are called themes.

To discover and evaluate ideas in a book, try asking questions like the following: What was the nabawi central problem in the book? Was it a personal, social, or moral problem? Does it relate to life as you know it? What ideas(s) about life and persuasive essays, society does the author seem to hold? What did the principal character(s) learn?

How did they change? What does this seem to say about people? About society? About morality? Once you have identified what ideas an author is trying to examine, you must still determine what the author's attitude is how i see the, toward those ideas. An author's attitudes are revealed in part by the tone, or overall mood, of the persuasive work. Before? In writing, as in conversation, tone is not so much stated as implied. In reading we depend solely on persuasive essays examples, the emotional overtones of the words to infer the attitudes of the author. A Dagger I See Before? For example, suppose you have determined that Crichton wishes to explore the idea of how private industry exploits scientific research. You must then determine, as well, what Crichton's attitude is examples, toward this situation. Does he think this is a positive development, or a negative one, or a little of confession both?

Does he think it is examples, inevitable, or preventable? One way to figure out confession Crichton's attitude about this is to persuasive examples, identify the tone he uses to tell the story. We describe the i see me analysis tone of a book with adjectives, and essays examples, more than one if necessary: straightforward, complex, ironic, creepy, pathetic, bitter, comic, tragic. For example, here is a statement using three different adjectives to describe Crichton's attitude toward one of the central problems in is this i see me analysis, Jurassic Park : Crichton strikes an persuasive essays, ominous tone in Jurassic Park. Even though this is a cautionary tale, the author nevertheless is optimistic that the mainstream scientific community, represented in nabawi, this story by Alan Grant, can learn restraint and respect for nature. (When identifying the tone of persuasive essays a book, make the effort to distinguish an individual. character's attitude from the author's overall attitude-they may differ.) To begin talking about tone, ask yourself questions such as these: Is there a particular setting or scene that stands out in my mind? What was the inuit history mood of that scene? Is this mood indicative of the persuasive entire book? Is the author an optimist, a pessimist, or a realist? How does he show it? Does a principal character experience one persistent state of mind or emotion?

What would I call it? Is it indicative of the nabawi dome work overall? Did the mood of the persuasive work help or hinder my understanding of the author's ideas? Butte College | 3536 Butte Campus Drive, Oroville CA 95965 | General Information (530) 895-2511.

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Paragraph About Wedding Party Essays and essays examples, Research Papers. THE WEDDING As I opened my eyes with the sun streaming in through the inuit history, window, I smiled to myself and thought The day has finally arrived. . I couldnt believe the sun had finally decided to persuasive essays examples, make an appearance as it had rained every morning since I had arrived in confession, Mexico. Examples! Its time to get up Nicole, I called out. Nicole was to be a bridesmaid at my Dad and Christines wedding along with me although my role was to be the best woman as well as a bridesmaid. I opened the curtains and nabawi, the sunlight. English-language films , Marriage , Wedding 1007 Words | 3 Pages. examples of classification paragraph about nursing. ? PARAGRAPH DEVELOPMENT The English paragraph can be divided into three sections: INTRODUCTION, BODY, and CONCLUSION. Persuasive Examples! The . INTRODUCTION briefly states the content of the paragraph and how to start an informative essay, enables a reader to establish his expectation of what is to come. THE BODY is the main part of the paragraph , which is developed sequentially.

THE CONCLUSION, the writer summarizes what he has already discussed in the main part and finishes his presentation of the idea. The following paragraph is an example. Sample. New Testament , Paragraph , The Reader 2241 Words | 7 Pages. chronological, fully-detailed, easily followed events. The extract is about a Mongolian Wedding which Stewart attended. Persuasive! The . extract is very precise as Stewart uses time keywords in chronological order such as Throughout the start, evening, In the morning, By mid afternoon and At four o'clock at the beginning of each paragraph making it easy for readers to follow up and relate to essays, the story effectively. He first shows the reader a hint about the Mongolian people he met with; they are unpredictable, boisterous. Comedy , Family , Genghis Khan 1088 Words | 3 Pages.

marriages, like most other cultural wedding ceremonies, are deeply concerned with their religious rituals and how i, customs. Persuasive Essays! Most ceremonies in red mules ostrich, the . Hindu culture are family oriented with great emphasis on persuasive essays entertainment and inspiration. Also, off course, the amount of world decorations and the extent to which the rituals are carried out persuasive examples depends greatly on confession the class of the families in society. Wealthier families are inclined to spend vast amounts of money into persuasive essays examples the wedding ceremony to make it extremely extravagant. Family , Hindu wedding , Hinduism 1431 Words | 4 Pages. culture, there will be many different customs and traditions in festival celebrations.

Wedding customs are one of the most representative and a dagger, . symbolic customs in revealing the differences. The wedding customs between China and persuasive essays examples, America can reveal the with feathers, differences in thinking model, value of essays examples orientation, and code of conduct as well as religion beliefs of the two countries. Chinese wedding style A Chinese wedding is an extremely special occasion fulls of bright red color everywhere--tablecloths. Bachelor party , English-language films , Marriage 740 Words | 3 Pages. Weddings in America A wedding is the ceremony in which two people are united in marriage. (Wikipedia.com) American . wedding are held upon high standards and based upon strong values that are shared between the two parties being wed, these two are brought together to form their sacred bondage of love and life with each other.

Weddings in America are known to be the most flexible and masjid nabawi dome, varied in the entire world due to the variation of race and persuasive essays, ethnic backgrounds that the American culture embodies. As. Bridal shower , Culture , Formal wear 1158 Words | 3 Pages. taught and practically instituted). High cost of weddings , unacceptable traditional practices and nabawi, envy (one family demanding to have a more . lavish wedding ceremony than the other) are cited as the main reasons why many Afghan boys and girls have remained single. In Afghanistan, one of the poorest countries in persuasive examples, the world, bridegrooms are expected to pay not only for their weddings , but also all the red mules with, related expenses, including several huge prewedding parties and money for the brides family, a kind of reverse. Afghanistan , Hamid Karzai , Kabul 1679 Words | 6 Pages. INTRODUCTION Background information on Wedding Planning Definition of wedding planning Wedding planning is the . process of coordinating all of the details involved in the making a wedding a remarkable event in accordance to the time schedule and persuasive, budget of inuit history those responsible for the wedding . Essays! Objectives of wedding planning ? Planning This involves visualizing the wedding itself and then putting things in how to start, order for persuasive that vision to materialize. ? Scheduling This is creating a work plan for the events. Marriage , Planning , Project management 1317 Words | 4 Pages. Displaying 31 - 60 of 1,500 The Wedding Dance muscles were taut and firm, bronze and compact in their hold upon his 5 Wedding . Dance | Amador T. Daguio skill - how frank his bright eyes were. Masjid Nabawi! She looked.

Wedding Dance rule that a man can marry another woman, so Lumnay went to persuasive examples, the wedding dance. But while seeing her husband married to another woman, she could not take it anymore. Wedding Dance Summary rule that a man can marry another woman, so Lumnay went to the wedding dance. But while seeing her. Dance , Dance music , Drama 1154 Words | 4 Pages. Indian Wedding vs American Wedding. Indian Wedding VS American Wedding Every country and every religion have their own traditions and its help to . differentiate each other. Even though wedding ceremony has the same meaning in every culture, the inuit history, way of persuasive essays celebration is different.

An Indian marriage is inuit history, essentially different from a typical American wedding . Indian wedding is persuasive essays, about the association of family members follow the traditions, functions, customs while traditional American Wedding is about Bridal shower, Bridal Party , The. Family , Formal wear , Husband 1148 Words | 3 Pages. Wedding Calendar Checklist The following checklist is how i, designed with the (ideal) timetable of twelve months. If youre planning your . wedding on a shorter schedule, just start at the beginning of the list and try to catch up as quickly as possible. Use the boxes to the left of the essays examples, items to see the world, check off tasks as you complete them. 9 to 12 months prior to wedding day: ?Arrange a gathering for you and your parents. ?Determine budget and how expenses will be shared. ?Discuss the size, style, location. Marriage , Wedding , Wedding cake 760 Words | 2 Pages. Weddings ; What Everyone Should Know Nicole Carlson Purpose: To inform the audience about weddings . Thesis: . In order to plan a beyond successful wedding , it is essays examples, important to learn and is this before me analysis, understand the key elements that will make a wedding a day nobody will ever forget. Examples! I. Introduction a. Attention Getter: Ladies, imagine a day where you get to walk down the aisle in the biggest, whitest dress you could find to the prince charming you always dreamed of. Or guys, watching the woman. Census , Dream , Flower 1012 Words | 3 Pages.

her instantly daydream about married life, and then when she snaps back to reality, and how i world, then Jennifer blurts out, Yes! Ill marry you! Nick . begins to essays examples, slide the ring onto her now trembling finger. The light reflects off the stones, which are twinkling like stars in the night sky. Anticipating the upcoming occasion, waterworks start to flow from her like a dripping faucet. I See Before! Jennifer thinks, Nothing beats the excitement of examples preparing and ostrich, organizing my dream wedding . The wedding day is the persuasive essays examples, day when couples.

Bachelor party , English-language films , Marriage 1759 Words | 5 Pages. as the formal union between two people, typically recognized by of shopaholics, the law, in essays examples, which the two become partners. As Americans, we are much more lenient with the . idea of inuit history marriage and persuasive essays examples, the actual wedding process, however; in places such as Pakistan- a wedding symbolizes much more for the Indian culture. Indian weddings are known for an informative essay their extremely elaborate ceremonies- including before and after the persuasive essays examples, big day, and i see, their opulent celebrations (Husain, 120). In Indian culture, marriage symbolizes not just. Arranged marriage , Bridal shower , Family 1133 Words | 3 Pages. ? PROJECT CHARTER 3-Month Wedding Project Emily Chan MGT5164 March 14, 2013 Business Case This charter proposes the business case . of planning a proper wedding for persuasive essays examples Mary-Jo and Bobby Doe, named the 3-Month Wedding Project. This project has been initiated in response to i see me analysis, Mary-Jo's engagement by essays examples, her parents. It aims to start an informative, provide her with a legal wedding , a memorable wedding experience, and leave all parties involved with a sense of enjoyment and satisfaction, given the essays, time constraint of three. Banns of marriage , Marriage , Project management 1776 Words | 7 Pages.

This summer I attended my cousins Jills wedding . She and Blaire married quite young as society looks at how to start essay it today, Jill being 22 and Blaire 23. Essays Examples! . They wanted a very traditional wedding , with a large bridal party and all the traditional themes. See The! I love weddings , but as I analyze their wedding in essays examples, a feminist approach, so many of the traditional concepts are degrading to the bride. The marriage symbolizes a transfer of an informative essay ownership. Persuasive! Traditional weddings have rituals developed that supress women, and bring. Bridal Chorus , Extended family , Family 1387 Words | 4 Pages.

Suddenly you are overwhelmed with the idea that you have a wedding to how i, plan. There are many questions to ask as you begin planning your . Persuasive! wedding . Wedding Date and how to an informative, Venues. Persuasive! It is important to set a wedding date before you move forward with many plans. Discuss a date with your fiancee and make preliminary decisions about where you want to hold the wedding and reception. Budget. Set an overall budget that you will use for the entire wedding . Sit down for a budget discussion with your fiance and your. American films , English-language films , Marriage 1984 Words | 5 Pages.

How to world, plan a Party When planning any kind of party you need to follow some simple steps to have a perfect . Essays Examples! party . A couple things you will need to confession of shopaholics, get started is to persuasive, determine what the before me analysis, party is for. Then you can determine where the party is going to take place you will also need to determine the time and persuasive essays, date, guest list, invitations, food, drinks, decorations and of course entertainment. First you need to confession, decide what your party is for persuasive and where its going to take place. Inuit History! For example If. Academic dress , Birthday , Graduation 995 Words | 3 Pages. ? Wedding Planning and Organizing by Sarpys events Submitted to Dr. Mona Zoghaib in partial completion of the Senior Seminar in Project . Management course on Tuesday 14th of April 2015. Project Manager: Laurie Kouyoumdjian Project Coordinator: Mohammad Doueiri Project team members: RozyAvessian, Tarek El Jurdi and TsolerSayegh INITIATION The initiation phase is the persuasive essays, first phase for red mules with ostrich any project.

In order to ensure a good management for any kind of a project, one should always have sufficient. English-language films , Management , Marriage 1476 Words | 7 Pages. WEDDING PROJECT PART II The Wedding Project Student Name University of Phoenix The Wedding Project One of . the most significant days in examples, a person's life is her wedding day! To ensure that such a momentous event goes off without a hitch, appropriate planning is of shopaholics, required. And when it comes to wedding planning, picking one's partner could very well be the easiest of all the planning decisions to make. Months will be spent prior to the wedding researching vendors, comparing products and prices. English-language films , Marriage , Project management 1789 Words | 7 Pages. Introductory Paragraph: About Antony Gormley. Stephanie Quick Quick 1 6th Hour English 2012 April 24 Introductory Paragraph : About Antony Gormley Everyone is curious . by nature, constantly seeking answers to questions we may know nothing about . Our inquisitive minds leave us pondering the fact that some questions have a multitude of answers leaving us with only examples, our own opinion on what is right. Antony Gormley had an endless amount of questions dealing with the human body. He asked questions such as, where do we begin and how i see the, where do we end.

Antony Gormley , Human body , New York City 1059 Words | 3 Pages. Chinese and German Wedding Cultures. Chinese and essays, German Wedding Cultures The two cultures I chose to analyze for this project were China and Germany. I chose Germany because I . lived there briefly while serving in the military and understand some of their culture and masjid, traditions but want to know and understand more. Persuasive Examples! I chose China because I believe their wedding traditions as well as their culture varies greatly from our own.

I entered into start an informative essay this project with the belief that the German wedding traditions would be very similar to essays, the. Bridal shower , China , Marriage 2795 Words | 7 Pages. A Fantasy Fairy Tale Wedding Royalty and Romance. A Fantasy Fairy Tale Wedding Royalty and Romance: arent these at of shopaholics the heart of every union? Its no wonder that the persuasive, fairytale . Inuit History! wedding also known as Happily Ever After or Dreams Do Come True, to name just two never goes out of fashion. You have thought about it since you were a little girl. When playing dress-up, you may have even dressed as a princess, a bride, a fairy tale heroine or maybe Cinderella. You pictured yourself and dreamed about being swept by your prince charming. Though now. Dashiki , Formal wear , Marriage 2367 Words | 6 Pages.

Indian Weddings Sociology Cassandra Wea. Indian Traditional Wedding The Indian wedding compared to persuasive, the Christian wedding , in my opinion is red mules, much more . intense and has many more rituals. Their weddings are much more colorful, comparatively to our traditional black and essays examples, white and are much more intricate and ornate. Not only that, but there is how i, much more involved in the actual wedding before the examples, ceremony even takes place. Lastly, the bride and groom dont rely on a priest to marry them, they marry themselves. An Indian wedding is see the world, not just the. Arranged marriage , Henna , Indian wedding 1000 Words | 3 Pages. Mgt 437 50th Wedding Anniversary Project. 50th Anniversary Wedding Background Sheryl Landau and brothers want to celebrate their 50th . Wedding Anniversary of their parents. Persuasive! She and her brothers are paying for the costs of the anniversary party ; however, they do not know where to with, start as they plan the persuasive, party . The Landau brothers call in inuit history, Team A to develop a project proposal for planning the anniversary party . Team A will need to persuasive, gather some crucial information about the parents, budget, venue, expectations.

Budget constraint , English-language films , Marriage 1246 Words | 5 Pages. Comparison of Wedding of India and China. College-Abay Daraga, Albay College of Nursing COMPARATIVE ANALYSIS Wedding Tradition of India and China Desiree A. Leal BSN IV-A . Rommel Quinones Instructor The approach of inuit history these paper work is to know and essays, compare the confession of shopaholics, two countrys tradition when it comes to wedding . Talking about wedding , we all know that it is the persuasive examples, important aspect when two people want to enter the life of having a family. According to Webster, wedding is the ceremony of marriage with its accompanying festive. And as I. Gift , Marriage , Wedding 1388 Words | 4 Pages. The Joys of Planning a Wedding The verdict is in - I will only of shopaholics, get married once. I've always felt that in my heart, but the experience of . planning my wedding removed any doubts that I may have had. The process of planning a wedding is so extensive and involved that once the process has started, there is persuasive essays, no turning back.

You will be completely absorbed in the ins and outs of the entire day from that point forward. While the main focal point should be the nabawi, actual ceremony uniting the man and persuasive essays, woman. Focal point , Marriage , Want 1016 Words | 3 Pages. Impact of Minor Parties In this paper, I will be discussing the inuit history, impact of minor parties . Essays! Minor parties are . political parties who have little to no impact on elections due to the amount of supporters and/or money is put into the party . However, in the United States, minor parties sometimes have a huge impact on politics and elections, whether its just getting their word out confession there and the major parties actually listen and discuss their issues, or they can even change which major party wins the election. Bill Clinton , Democratic Party , Election 1027 Words | 3 Pages.

In The Introductory Paragraph To This Essay About Essays. ?In the introductory paragraph to this essay about essays examples essays I will tell you that you dont need an introductory . paragraph , at least not of the 1) topic sentence 2) structural methodology 3) thesis statement varity that we were all taught in high school. What you do need is That Thing; maybe a question, a fear or a fury. It makes your blood boil. Its all you can talk about when you sit down with your friends over how to start a glass of wine or two or five, or maybe you cant talk about persuasive it with anyone, just your. Education , Essay , Essays 1304 Words | 4 Pages. ?NARRATIVE PARAGRAPH The toddler climbed laboriously up onto the stool, determined to help her mother.

But her mother did not notice; she . was far too busy with the frantic preparations for the birthday party . Ten three-year-olds and their mothers coming for an afternoon of treats, games and face painting: a herald of another party , ten years from now, when make up would be the how to start, order of the day, the childs father had observed. As the persuasive, mixer whirred and the dishwasher swished and the oven beeped. Joan Caulfield , Telephone call , The Reader 1328 Words | 3 Pages. Irish 1 Irish Wedding Culture Laura Adair Introduction to Cultural Anthropology Rachel Grabner September 27, 2010 Irish 2 Different . Is This A Dagger I See! places have different cultures. Some aspects of persuasive examples life can look the same in most cultures. We do not really think about what our parents have passed on to us. We also do not think too much of where it has come from or if it is part of our culture. We just live our lives. Masjid Nabawi! Well that is how other cultures are. Their culture is just how they live.

I have. Bridal Chorus , Culture , Irish language 1599 Words | 5 Pages. his life post-war. 8 January[edit] It is persuasive examples, June 1943 and how i see the, Anne is essays, dreaming about her fourteenth birthday party . Suddenly she wakes . up and an informative, remembers she is in the annex. Her family give her whatever they can, but the essays, only present that really excites her is a bar of chocolate.

Also, the families are wearing out their clothes and don't have the money to replace them. In fact, the van Daans have little money left and argue about whether they should sell Mrs van Daan's fur coat. Me Analysis! Otto measures Anne and. Anne Frank , Fritz Pfeffer , Margot Frank 1328 Words | 4 Pages. reaction papers? How about formal and informal themes?

Who didnt fail to impress their teachers with the introduction of their research paper? . Writing is persuasive essays examples, just so essential to every students lifefrom elementary to high school and inuit history, extending through collegefrom the simplest to the most complex. In line with the fact that no student can escape from persuasive, writing, this aims to give them knowledge on is this a dagger i see me analysis how to persuasive, compose an effective written piece through the how i world, use of effective paragraphs . THE PARAGRAPH A successful. Horror film , Paragraph , Reader 1899 Words | 6 Pages. nose and smile, and we resembled our biological father, who we both have only met a few times in our lives. Examples! It was a terrific day, and when it was over and . before it was time for us to is this a dagger i see me analysis, return home, my sister invited me to her wedding . This essay is about her wedding . Persuasive Essays! I arrived at the Baltimore Airport on a warm but breezy late Friday afternoon. The airport was very busy, all of the people scurrying around, looking for flights, bags, and loved ones. I found a cab and proceeded to my hotel. Bed , Bed and breakfast , Breakfast 683 Words | 3 Pages. ?Classifications of paragraph A classification paragraph begins a main idea and masjid nabawi, discusses the subcategories of essays that topic, . comparing and world, contrasting them with each other.

Following are some examples of classification paragraphs . Here are a couple of short classification paragraphs , in order to get you started with learning about how they should be formed and what they are. Remember: Classification paragraphs start with a main idea, using the rest of the paragraph to explain a series of secondary. Weight loss 2231 Words | 6 Pages. Middle Ages As the ages have past weddings have changed, the most interesting weddings took place in the middle ages. Middle . ages were full of mystery and lust, women were not merely wives but prizes and a possession, rarely was it love. The reasons of which people were married was determined by their class.

Most of the marriage laws we know today evolved during this era. The celebrations were extravagant, full of color and magnificent entertainment and exquisite feasts, radical compared to. Gift , Islamic contributions to essays, Medieval Europe , Marriage 1115 Words | 3 Pages. Planning a Wedding On a Budget Every woman wants to have the wedding of their dreams. Weddings can be very . expensive. An average wedding in Bennington County, Vermont costs between $18,364 and $30,606 for a guest count of a dagger 112-126 people, and the majority of woman however do not possess the means to persuasive examples, have such a lavish event.

But there are other ways to have your dream wedding without spending much money. If you budget and shop around you can have your dream wedding . The idea of a wedding is to. Costs , Marriage , The Guest 2952 Words | 7 Pages. My Perfect Wedding Christmas Day is usually a holiday mainly observed to commemorate the birth of Jesus. For non Christianity followers it . is a day to exchange gifts, decorate houses and for Santa Clause. For me, Christmas of two thousand eight changed my life forever. This is the day my now to be husband kneeling down on one knee, asked me to spend the me analysis, rest of my life with him. His proposal was short sweet and sincere. Without a doubt I gracefully replied Yes, I will. With many new emotions. A Flock of Seagulls , Chandelier , Gown 1210 Words | 3 Pages. vent1 Event or Party Planner Mary Bolin EN101 W13 6WKA Section 2 Instructor: Karen Lawler February 14, 2013 Event or Party . Planner 2 Event or Party Planner Abstract The object of this paper is to persuasive essays examples, discuss Party /Event Planning as a career.

This paper will include all areas pertinent to becoming a professional Event Planner. I chose this topic because it was suggested in the lesson plans that we consider writing about our current or future career environment. I am majoring in Business Management. Event planning , Party 1479 Words | 4 Pages. 1/14/13 The Big Fat Indian Wedding s; the confession, Only Way Out. by Padmaja Iyeng ar Hom e | Ka bir | Poe try | Blogs | BoloKids | W rite rs | . Contribute | Se a rch | Conta ct | Site Ma p | Gift Shop | Adve rtise | RSS | Login | Re giste r Ja nua ry 14, 2013 Cha nne ls In Focus Analy s is Cartoons Educ ation Environment Going Inner Opinion Photo Es s ay s Colum ns A By s tander's Diary Bus ines s My W ord PlainSpeak Random Thoughts India Ne st Arc hitec ture As trology Ay urveda . Aamir Khan , Boy , Indian wedding 1579 Words | 7 Pages. Wedding planner duties What does a wedding planner do? A wedding planner is persuasive, a professional who assists with . the design, planning and management of a client's wedding . Service packages Management This package is for couples who chose and nabawi dome, booked the essays, venue for wedding , but also worry about not being able to handle everything on the big day. Time: 1 month before the wedding day Duties: Manage and arrange all the masjid dome, tasks Ensure that the workflow in the wedding. English-language films , Management , Marriage 464 Words | 3 Pages. acceptance.

This process was placed in the hand of persuasive essays examples go-between, who acted as a buffer between two parties . The important parties . in how i, proposal and betrothal negotiations were the parents of the bride and essays, groom, rather than the bride and the groom. When the boys parents identified a future bride, they would send the go-between to present gifts to the girls parents and to express their feelings about the match. Feathers! If the proposal was well-received, the go-between would obtain the date and hour of the. Bridal Chorus , Family , Gift 1971 Words | 6 Pages. Mr. amp; Mrs. Smith - Wedding Scope Team C MGMT 404 Week 3 Table of Contents Page Cover Page1 Table of Contents2 Project . Scope3-13 Proposed Budget 3 Budget Breakdown4 Project Objective 5 Deliverables 6-7 Milestones8 Technical Requirements 9 Limits and Exclusions 10 Customer Review 11-12 Measurements of Success13 Team Cs Week 3 Information 14 Team Cs Signatures15 Proposed Budget: The estimate of persuasive examples a maximum of $10,000 is based upon the following. American films , Bridal shower , English-language films 1132 Words | 6 Pages.

Wedding Traditions Changed by Society. 2012 Wedding Traditions: Modern Society and dome, Changes The words I do, some of the most significant words to known to a human being, . Persuasive Essays Examples! believing in an everlasting love. The tradition that goes into red mules feathers seeing such a beautiful face on persuasive examples such a day makes people think how much relief they can have. All the red mules, months of planning and essays, fixing everything to make it perfect finally came. Masjid Nabawi Dome! Most people do not realize how much time or adjustments must be made in order to essays, fit their criteria of ostrich a perfect wedding . Due to. Marriage , Mehndi , Same-sex marriage 2613 Words | 7 Pages. 6 Bibliography 7 Project Overview Project Name Wedding Proposal for Mark and Mary-Jo Project Background I have been asked by essays examples, Mary-Jo . parents to how i world, prepare a wedding event that will fulfill her daughters dreams. I will provide information that will give you the image and essays, details regarding activities and with, cost of the event. Persuasive! Business Case This project charter proposes the start, planning a proper and legal wedding for Mark and Mary-Jo, entitled the persuasive, Wedding Project for Mark and Mary-Jo. This project was initiated.

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Informative Speech - History Of The Wedding Cake Specific Purpose: To inform my audience about the history and . development of the modern wedding cake. Central Idea: Our decadent, modern wedding cake took centuries to evolve from its humble beginnings as rough breads. I. Feathers! The origins of todays wedding cake can be traced back to ancient Roman II. Essays! With the Roman conquests, the Roman wedding traditions were carried to III. During the 1660s, a French chef visiting England was.

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AKUNTANSI C ( KONSENTRASI SEKTOR PUBLIK ) TUGAS RESUME 2 AKUNTABILITAS, AKUNTANSI, DAN AUDITING SEKTOR PUBLIK. Persuasive Examples! AKUNTABILITAS , AKUNTANSI, DAN AUDITING SEKTOR PUBLIK. Masjid Nabawi! Sri Anggriani Astuti. Persuasive Examples! Standar Pemeriksaan Keuangan Negara (SPKN), yang masih dalam bentuk konsep dan mengacu pada Government Auditing Standards yang diterbitkan GAO, menyatakan bahwa akuntabilitas adalah kata kunci yang memunculkan kebutuhan akan akuntansi dan auditing. An Informative Essay! Demikian pula dalam proses-proses pelaksanaan pemerintahan di Indonesia, konsep akuntabilitas merupakan kunci penyelenggaraan kepemerintahan yang baik. Essays! Berbagai stakeholder organisasi pemerintahan, baik legislatif, eksekutif, maupun masyarakat luas, memerlukan informasi tentang: Penggunaan sumber daya publik secara benar dan sesuai dengan peraturan perundang-undangan yang berlaku. Masjid Nabawi! Penyelenggaraan program-program pemerintah yang mencapai tujuan-tujuan dan sasaran-sasaran yang diharapkan.

Penyediaan layanan kepada masyarakat secara efisien, ekonomis dan efektif. Essays Examples! Tugas utama pertanggungjawaban hal-hal di atas kepada legislatif dan masyarakat luas berada di tangan jajaran pegawai dan pejabat pemerintahan. Auditor berperan dalam pelaksanaan akuntabilitas dengan menyediakan laporan-laporan yang menambah kredibilitas dan keandalan informasi yang dilaporkan oleh pegawai dan pejabat pemerintah tersebut. Masjid! Sebagai suatu proses, auditing berhubungan dengan prinsip dan prosedur akuntansi yang digunakan oleh organisasi. Persuasive Essays! Auditor mengeluarkan suatu opini atas laporan keuangan suatu entitas. Of Shopaholics! Laporan keuangan merupakan hasil dari sebuah sistem akuntansi dan diputuskan atau dibuat oleh pihak pengelola. Essays! Pengelola suatu entitas mengunakan data-data mentah akuntansi untuk kemudian dialokasikan ke masing-masing laporan surplus-defisit dan neraca serta menyajikan hasilnya dalam suatu bentuk laporan yang dipublikasikan. Masjid Nabawi! Hubungan antara akuntansi dengan auditing merupakan suatuhubungan yang tertutup. Persuasive Essays Examples! Auditor selalu menggunakan data-data akuntansi dalam melaksanakan kerja auditing. How To Essay! Lebih jauh lagi, auditor harus membuat suatu keputusan tentang pengalokasian data-data akuntansi yang dibuat oleh pihak manajemen. Essays! Auditor juga harus memutuskan apakah laporan keuangan yang telah disajikan telah sesuai atau terdapat salah saji.

Untuk membuat keputusan-keputusan tersebut, auditor tidak dapat membatasi dirinya hanya dengan menggunakan perekaman bukti akuntansi dan rekening-rekening yang ada di dalam organisasi. Dalam kenyataanya, auditor juga harus memperhatikan seluruh hal yang ada di dalam organisasi, karena perilaku organisasi tidak hanya akan mempengaruhi data yang ada, tetapi yang lebih penting lagi, akan mempengaruhi kebijakan manajemen berkaitan dengan akuntansi dan pelaporan data. Nabawi! Menurut Jones dan Bates, terdapat empat faktor yang melatarbelakangi pentingnya audit dalam sektor publik, yaitu: pertumbuhan volume dan kompleksitas transaksi ekonomi, pemisahan sumber dana, rendahnya independensi pihak manajemen, dan pengaruh keputusan organisasi sektor publik terhadap masyarakat (sosial). Persuasive Essays! Pertumbuhan volume dan kompleksitas transaksi ekonomi. Masjid Dome! Pertumbuhan aktivitas sektor publik mengakibatkan level dan kompleksitas aktivitas ekonomi pun meningkat. Examples! Pertumbuhan volume dan kompleksitas tersebut mengakibatkan klasifikasi anggaran, pengukuran dan pelaporan aset, kewajiban, ekuitas dana, pendapatan dan beban menjadi lebih sulit. With Ostrich Feathers! Hal tersebut mengakibatkan kesulitan dalam merancang sistem akuntansi untuk pelaporan transaksi ekonomi secara tepat. Persuasive Examples! Lebih lanjut, aparat pemerintah biasanya tidak terlatih untuk mengerjakan prosedur akuntansi lanjutan. Red Mules With Feathers! Permasalahan tersebut diperburuk oleh peningkatan jumlah standar akuntansi pemerintah. Persuasive Essays! Kombinasi dari peningkatan kompleksitas, sistem akuntansi dan standar akuntansi pemerintah telah membuat perspektif akuntansi profesional semakin dibutuhkan.

Salah satu cara untuk mendapatkan perspektif ini adalah melalui fungsi audit. Pemisahan sumber dana. Red Mules Ostrich! Saat ini, dalam sektor publik terjadi pemisahan antara pihak yang mendanai dengan pihak yang bertanggung jawab untuk mengelola sumber daya. Examples! Pemisahan tersebut disebabkan oleh: jarak yang menyulitkan akses ke sebuah organisasi, perbedaan keahlian teknis antara pihak yang mempunyai dana dan yang mengelola sumber daya, dan perbedaan ukuran organisasi jasa. Red Mules! Lebih lanjut, pemisahan tersebut akan meningkatkan kemungkinan terjadinya kesalahan informasi dan kesalahpahaman baik disengaja maupun tidak. Persuasive Examples! Disinilah audit berperan sebagai alat komunikasi. Inuit History! Rendahnya independensi manajemen pemerintahan. Ketika informasi disajikan oleh pihak yang memiliki kepentingan sendiri terhadap laporannya, pengguna informasi tersebut harus menguji keandalan data yang diberikan. Examples! Suatu informasi diragukan kebenarannya ketika interaksi antara sumber informasi dan penggunanya rendah. How I See The World! Semakin rendah interaksi yang terjadi antara sumber informasi dan pengguna maka semakin penting bagi pengguna informasi untuk menguji reabilitas informasi yang disajikan, dan di saat yang bersamaan pengujian reabilitas semakin sulit.

Rendahnya independensi manajemen dapat dilihat dari berbagai bentuk, yaitu antara lain sebagai berikut. Examples! Perkiraan yang terlalu optimis, contoh: volume aktivitas di masa mendatang, pendapatan pajak, hibah, dan tingkat pertumbuhan ekonomi. Start Essay! Ditetapkan terlalu rendah, contoh: biaya, hutang, permintaan jasa, biaya sosial dan kebutuhan teknologi. Examples! Ditetapkan terlalu tinggi, contoh: pendapatan, keuntungan sosial dan aset. Red Mules With! Kelalaian tidak mecantumkan, contoh: undang-undang masa depan, gangguan administarasi atau lingkungan, kumpulam data yang digunakan untuk mendeteksi program yang tidak efektif atau efisien dan kehilangan pegawai. Persuasive Essays Examples! Pengaruh keputusan organisasi sektor publik terhadap masyarakat. Inuit History! Keputusan pemerintah mempunyai dampak ganda bagi kebutuhan auditing. Pertama, masyarakat perlu mengetahui apakah pengelolaan sumber daya oleh pemerintah pusat maupun daerah telah dilaksanakan secar efektif dan efisien. Examples! Dalam hal ini, terdapat peningkatan kebutuhan auditor sektor publik untuk melaporkan pertanggungjawaban pengelolaan keuangan negara kepada masyarakat. How To Start! Kedua, presiden selaku pemegang kekuasaan pengelolaan keuangan negara perlu mengetahui dampak sosial dari program yang telah dilaksanakan.

Disini lah terjadi peningkatan kebutuhan auditor untuk melaporkan keuangan negara kepada presiden. Persuasive Essays! Pernyataan ini lebih dititikberatkan pada unit pemerintahan. Masjid Nabawi! Tentu saja masyarakat memiliki kepentingan yang tak kalah penting di organisasi publik lainnya. Persuasive Essays! Dengan sumber daya yang terbatas, setiap organisasi publik berkewajiban melaporkan pengelolaan keuangan negara secara akurat. TUJUAN AUDIT SEKTOR PUBLIK. Is This I See Before Me Analysis! Audit sektor publik adalah jasa penyelidikan bagi masyarakat atas organisasi publik dan politikus yang mereka danai. Essays! Hal yang memberikan keuntungan yang lebih besar karena janji yang dibuat oleh para politis dapat diperiksa secara profesional oleh pihak independen. How I See The! Legislatif menegaskan berbagai tingkatan dari pengawas dan pemeriksaan bagi kebanyakan sektor publik. Essays Examples! Tetapi, hukum tidak membahas leboh khusus mengenai standar audit. Of Shopaholics! Kebanyakan audit sktor publik mencagkup interprestasi atas audit orgnisasi sektor publik berkaitan dengan hukum yang terdiri atas standar dan batasan yang tercangkup dalam bagian akuntansi. Essays Examples! Audit secara individual sudah ditetapkan dengan jelas.

Undang-undang atau kesepakatan yang sudah dibuat oleh pemerintah merupakan bagian dari organisasi audit. Start Essay! Audit sektor publik secara jelas menunjukkan perbedaan antara kewajiaban dan tuga, mulai dari sertifikasi akuntan sampai audit terhadap organisasi khusus, penugasan atas pemeriksaan kecurangan, korupsi dan nilai uang dari audit. Auditor tidak tepat menyusun laporanya dalam satu jenis pekerjaan. Persuasive! Kegiatan audit sektor publik meliputi perencanaan, pengendalian, pengumpulan data, pemberian opini dan laporan. See The! Permasalahan pokok dalam proses audit adalah pemeberin sasaran yang jelas dalam pelaksanaanya. Essays! OBJEK AUDIT SEKTOR PUBLIK.

Agar proses audit menjadi suatu bagian yang dapat dipahami, maka diperlukan suatu definisi atas objek audit sektor publik. How I See The World! Auditorsektor publik sangat berkepentingan dengan aktifitas entitas yang dapat dipertanggungjawabkan. Essays Examples! Hal ini merupakan perhatian utama dari auditor sektor publikselama pelaksanaan pekerjaan audit. Objek audit lainnya adalah pengorganisasian entitas. Dome! Pengorganisasian disini meliputi dua aspek, yaitu hubungan eksternal dan hubungan internal yang ada dalam organisasi.

Dalam aspek hubungan eksternal, auditor harus familiar dengan klien-klien organisasi. Essays Examples! Lebih dari itu, auditor harus mengetahui perbedaan dan persamaan antara entitas yang menjadi kliennya dengan entitas-entitas lainnya. An Informative Essay! Auditor juga harus mengetahui aspek-aspek yang menjadi keunikan organisasi. Persuasive Essays Examples! Pemahaman atas aspek hubungan eksternal ini dapat memeberikan kepada auditor data-data yang dapat dipertanggungjawabkan yang disajikan dalam laporan keuangan. Masjid Nabawi! Aspek hubungan internal suatu organisasi atau disebut sebagai struktur organisasi juga menjadi perhatian utama auditor. Essays! Struktur organisasi adalah divisi kerja dalam organisasi dan orang-orang yang melakukan pekerjaan dalam divisi kerja tersebut. Is This I See! Kelemahan dalam struktur organisasi internal dapat menyebabkan terjadinya perekaman akuntansi yang tidak tepat, menyesatkan, dan berpotensi menimbulkan kecurangan. MASALAH-MASALAH UTAMA DI AUDIT SEKTOR PUBLIK. Essays Examples! Prosedur, Bukti, Dan Pernyataan Keuangan Serta Kinerja. How To An Informative Essay! Standar auditing biasanya berbeda dengan prosedur.

Prosedur menjelaskan pekerjaan yang akan dilakukan, sedangkan standar merupakan ukuran kinerja atas pekerjaan yang dilakukan. Persuasive Examples! Empat jenis prosedur audit meliputi inspeksi, observasi, penyelidikan, dan konfirmasi. Start An Informative! Namun, keempat jenis prosedur tersebut hanyalah contoh sehingga perlu diingat bahwa tidak ada satupun nama dan deskripsi prosedur auditing yang bersifat mutlak. Persuasive Essays! Peristiwa Kemudian Dan Kaitannya Dengan Prosedur Auditing. Prosedur audit bukannya suatu peristiwa, tetapi lebih sebagai alat yang digunakan untuk mengidentifikasikan peristiwa selanjutnya.

Peristiwa kemudian terdiri atas data akuntansi yang bersifat pokok dan seluruh kolaborasi informasi yang tersedia untuk auditor. Inuit History! Pernyataan Laporan Keuangan Dan Tujuan Audit. Examples! Pernyataan merupakan representasi pihak manajemen yang terdapat dalam laporan keuangan, meliputi pernyaatan mengenai posisi keuangan dan kegiatan operasi organisasi. Inuit History! Kategori pernyataan terdiri atas: Eksistensi Kelengkapan Hak dan kewajiban Penilaian atau alokasi Penyajian dan pengungkapan. Persuasive Examples! Auditor perlu mengungkapkan peristiwa kemudian yang mendukung masing-masing pernyataan yang bersifat material untuk seluruh komponen laporan keuangan. Of Shopaholics! Suatu komponen laporan keuangan dapat berupa rekening neraca, sekelompok rekening neraca, suatu kelompok transaksi, atau kategori kategori pernyataan luas yang meliputi transaksi dan neraca. Essays Examples! Kode Etik Auditor Sektor Publik. Is This I See Me Analysis! Sudah menjadi sesuatu yang umum di lingkungan BPK RI bahwa para pegawai yang melaksanakan tugas pokok pemeriksaan dan dahulu dikenal dengan istilah pemeriksa sekarang disebut dengan auditor atau lebih tepatnya auditor sector public. Auditor merupakan suatu profesi yang dapat ditumbuhkembangkan.

Untuk itu, dilingkungan BPK, jabatan fungsional auditor telah dikembangkan. Examples! Di dunia internasional, hal serupa juga telah lama berkembang. With Ostrich Feathers! Perkembangan tersebut sesuai dengan situasi dan kondisi dari masing-masing Negara. Persuasive Essays Examples! Salah satu perkembangan dalam bidang auditor di dunia internasional adalah telah diterbitkannya Kode Etik Auditor Sektor Publik oleh INTOSAI, yakni organisasi yang terdiri atas BPK-BPK seluruh dunia pada tahun 1998. Of Shopaholics! Menurut INTOSAI, kode etik auditor merupakan pelengkap atau tambahan penting yang dapat memperkuat standar audit. Essays! Sejak tahun 1994, BPK telah mengeluarkan standar audit pemerintahan yang dikenal dengan istilah SAP, sebagai pedoman bagi semua auditor sector public dalam melaksanakan tugas auditnya. Confession Of Shopaholics! Selain SAP, dilingkungan BPK selama ini juga dikenal Sapta Prasetya Jati BPK dan Ikrar Pemeriksa yang merupakan pedoman bagi pegawai BPK dalam melaksanakan tugas pemeriksaan. Berikut adalah bagian-bagian penting dari kode etik yang dimaksud: Kode etik auditor adalah prinsip dasar atau nilai-nilai yang menjadi acuan dalam melaksanakan kegiatan audit. Essays! Mengingat bahwa budaya suatu bangsa biasanya berbeda dengan bangsa-bangsa lainnya, maka sangat mungkin terjadi bahwa budaya bangsa tersebut ikut mewarnai kode etik yang bersangkutan.

Sesuai dengan anjuran INTOSAI, setiap BPK suatu Negara selaku lembaga pemeriksa eksternal pemerintah bertanggungjawab mengembangkan kode etik yang sesuai dengan budaya, system social, atau lingkungannya masing-masing. Inuit History! Selanjutnya, BPK perlu memastikan bahwa segenap auditor secara mandiri mempelajari nilai-nilai dan prinsip-prinsip yang dimuat dalam kode etik tersebut dan berperilaku sesuai dengan kode etik itu. Persuasive Essays! Dengan mengacu pada kode etik tersebut, perilaku auditor dalam setiap situasi/keadaan atau setiap saat hendaklah merupakan perilaku yang tidak tercela. Inuit History! Apabila terdapat kekurangan dalam perilaku auditor maupun perilaku yang tidak benar dalam kehidupan pribadinya, maka hal yang demikian akan menempatkan integritas auditor, lembaga tempat ia bekerja, kualitas dan validitas tugas pemeriksaannya pada situasi yang tidak menguntungkan dan dapat menimbulkan keraguan terhadap keandalan serta kompetensi lembaga pemeriksa tersebut. Essays! REGULASI AUDIT SEKTOR PUBLIK. How I See The World! Amandemen UUD 1945, Pasal 23 E UUD 1945 UU No.

5 Tahun 1973 Tentang BPK TAP MPR No X/MPR/2001 Tentang Laporan Pelaksanaan Majelis Permusyawaratan Rakyar Republic Indonesia Oleh Lembaga Tinggi Negara Pada Sidang Tahun Majelis Permusyarawatan Rakyar Republic Indonesia Tahun 2001. Persuasive! TAP MPR No VI/MPR/2002 Tentang Rekomendasi Atas Laporan Pelaksanaan Putusan Majeklis Permusyarawatan Rakyat Republic Indonesia Oleh Presiden, DPA, DPR, Dan MA Pada Siding Tahunan Majelis Permusyawaratan Rakyat Republik Indonesia Tahun 2002. How To Start An Informative Essay! UU No 17 Tahun 2003 Tentang Keuangan Negara. Examples! UU No 1 Tahun 2004 Tentang Perbendaharaan UU No 15 Tahun 2004 Tentang Peneriksaan Atas Pengelolaan Dan Tanggung Jawab Keuangan Negara. Red Mules With Ostrich Feathers! PP No 24 Tahun 2005 Tentang Standar Akuntansi Pemerintahan (SAP).

Permendagri No 13 Tahun 2006 Tentang Pedoman Pengelolaan Keuangan Daerah. Persuasive! Rancangan Standar Pemeriksaan Keuangan Negara (SPKN). Red Mules! SAP-BPK Tahun 1995 Generally Accepted Government Auditing Standar (GAGAS) revisi tahun 2003, united states General Accounting Office. Persuasive! PENGKLASIFIKASIKAN BERDASARKAN TUJUAN PENGUJIAN. Inuit History! Dasar pengklasifikasian pengujian audit tergantung pada tujuan pengujian yang dilakukan oleh auditor. Persuasive Examples! Ada dua tujuan dasar pengujian audit, yaitu : Pengujian pengendalian untuk menyediakan bukti-bukti yang berkaitan dengan (1) efektifitas desain kebijakan atau prosedur system akuntansi, prosedur pengendalian atau lingkungan pengendalian, atau dengan (2) efektifitas pelaksanaan kebijakan atau prosedur tersebut . Is This! Pengujian substansial untuk menyediakan bukti-bukti tentang validitas perlakuan akuntansi atas transaksi dan nerca atau sebaiknya, tentang kesalahan atas ketidakberesan yang terjadi. Jenis-jenis pengujian pengendalian. Persuasive Examples! Terdapat dua jenis pengujian pengendalian. How To An Informative Essay! Pengujian pengendalian yang berkaitan langsung dengan efektivitas desain kebijakan atau prosedur dan untuk menentukan apakah kebijakan atau prosedur tersebut benar-benar digunakan dalam kegiatan organisasi. Persuasive Examples! Pengujian pengendalian yang berkaitan dengan efektifitas kebijakan dan prosedur, bagaimana cara penerapannya, konsistensinya dengan penerapan sebelumnya, dan oleh siapa penerapan tersebut dilakukan selama periode audit. World! Jenis-Jenis Pengujian Substasial.

Dua kategori umum pengujian substansial adalah. Essays! Prosedur analisis yang merupakan suatu prosedur dalam menyediakan bukti-bukti tentang validitas perlakuan akuntansi atas transaksi dan neraca, atau sebaliknya tentang kesalahan atau ketidak beresan yang terjadi. Pengujian rincian atas transaksi atau neraca yang merupakan suatu pengujian untuk menyediakan bukti-bukti tentang validitas perlakuan akuntansi atas transaksi dan neraca, atau sebaliknya, tentang kesalahan atau ketidakberesan yang terjadi.

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compliance resume SUBJECT: EEOC COMPLIANCE MANUAL. PURPOSE: This transmittal covers the issuance of Section 12 of the new Compliance Manual on “Religious Discrimination.” The section provides guidance and instructions for investigating and analyzing charges alleging discrimination based on religion. EFFECTIVE DATE: Upon receipt. DISTRIBUTION: EEOC Compliance Manual holders.

OBSOLETE DATA: This Section of the Compliance Manual replaces Section 628: Religious Accommodation , EEOC Compliance Manual, Volume II and its Appendices: Appendix A, Policy Statement on essays, Ansonia Board of Education v. Philbrook and Religious Accommodation ; Appendix B, Policy Guidance On ‘New Age’ Training Programs Which Conflict With Employees’ Religious Beliefs ; and how i see the world, Appendix C, Religious Objections to Unionism . It also replaces the following policy documents: Religious Organizations that Pay Women Less than Men in Accordance with Religious Beliefs ; Religious Organization Exemption Under Title VII of the Civil Rights Act of 1964, as amended ; and Policy Statement on examples, Goldman v. Weinberger (Accommodation of the Wearing of Religious Dress) . The Commission’s Guidelines on Discrimination Because of Religion, 29 C.F.R. Part 1605, remain in effect. SECTION 12: RELIGIOUS DISCRIMINATION. SECTION 12: RELIGIOUS DISCRIMINATION. This Section of the how to essay Compliance Manual focuses on religious discrimination under Title VII of the persuasive examples Civil Rights Act of inuit history 1964 (Title VII). [2] Title VII protects workers from employment discrimination based on their race, color, religion, sex, national origin, or protected activity. Solely with respect to essays religion, Title VII also requires reasonable accommodation of employees’ [3] sincerely held religious beliefs, observances, and practices when requested, unless accommodation would impose an undue hardship on business operations. [4] Undue hardship under Title VII is defined as “more than de minimis ” cost or burden -- a substantially lower standard for employers to satisfy than the “undue hardship” defense under the Americans with Disabilities Act (ADA), which is defined instead as “significant difficulty or expense.” [5] The prohibition on discrimination and the requirement of reasonable accommodation apply whether the religious views in question are mainstream or non-traditional, and even if not recognized by any organized religion. These protections also extend to those who profess no religious beliefs. [6] Questions about religion in see the world the workplace have increased as religious pluralism has increased.

In a 2001 survey of human resource professionals conducted by the Society for essays examples, Human Resource Management and me analysis, the Tanenbaum Center for essays examples, Interreligious Understanding, 36% of human resource professionals who responded reported an i see increase in the religious diversity of their employees in the preceding five years. [7] Further, the number of religious discrimination charges filed with EEOC has more than doubled from 1992 to 2007, although the total number of such charges remains relatively small compared to essays examples charges filed on other bases. [8] Many employers seek legal guidance in managing the issues that arise as religious diversity in the American workplace continues to increase. [9] This Section of the how i world Compliance Manual is designed to be a practical resource for employers, employees, practitioners, and EEOC enforcement staff on persuasive essays examples, Title VII’s prohibition against religious discrimination. The Section defines religious discrimination, discusses typical scenarios in masjid dome which religious discrimination may arise, and essays examples, provides guidance to employers on how to how to essay balance the needs of individuals in a diverse religious climate. [10] The Section is organized by legal topic, as follows: I - Coverage issues , including the definition of “religion” and “sincerely held,” the religious organization exception, and the ministerial exception. Essays? II - Disparate treatment analysis of employment decisions based on religion, including recruitment, hiring, promotion, discipline, and compensation, as well as differential treatment with respect to religious expression; customer preference; security requirements; and see the, bona fide occupational qualifications. III - Harassment analysis , including religious belief or practice as a condition of employment or advancement, hostile work environment, and employer liability issues.

IV - Reasonable accommodation analysis , including notice of the conflict between religion and work, scope of the accommodation requirement and undue hardship defense, and common methods of accommodation. V - Related forms of discrimination , including discrimination based on national origin, race, or color, as well as retaliation. Some charges of religious discrimination may raise multiple claims, for example requiring analysis under disparate treatment, harassment, and essays, denial of me analysis reasonable accommodation theories of liability. In addition, there are some instances where Title VII religious discrimination cases implicate federal constitutional provisions. [11] For example, a government employer may contend that granting a requested religious accommodation would pose an undue hardship because it would constitute government endorsement of religion in violation of the Establishment Clause of the First Amendment. [12] A private sector employer may contend that its own First Amendment rights under the essays Free Exercise or Free Speech Clauses would be violated if it is compelled by Title VII to see the grant a particular accommodation. [13] In addition, government employees often raise claims under the First Amendment parallel to their Title VII accommodation claims. [14] Defining the exact parameters of the First Amendment is persuasive essays examples beyond the confession scope of persuasive examples this document. However, these First Amendment issues are referenced throughout this document in order to with feathers illustrate how they often arise in Title VII cases. [15] Title VII prohibits covered employers, employment agencies, and unions [16] from: (1) treating applicants or employees differently (disparate treatment) based on examples, their religious beliefs or practices or lack thereof in any aspect of employment, including recruitment, hiring, assignments, discipline, promotion, and benefits; (2) subjecting employees to a dagger i see harassment because of their religious beliefs or practices or lack thereof or because of the religious practices or beliefs of persuasive people with whom they associate ( e.g. , relatives, friends, etc.); (3) denying a requested reasonable accommodation of an applicant’s or employee’s sincerely held religious beliefs or practices or lack thereof if an accommodation will not impose an undue hardship on the conduct of the business; [17] and, (4) retaliating against an applicant or employee who has engaged in protected activity, including participation ( e.g. , filing an EEO charge or testifying as a witness in confession of shopaholics someone else’s EEO matter), or opposition relating to alleged religious discrimination ( e.g. Persuasive Essays Examples? , complaining to human resources department about alleged religious discrimination). Although more than one of masjid nabawi dome these theories of liability may apply in persuasive a particular case, they are discussed in how i see the world separate parts of essays this manual for ease of use.

Charges involving religion may give rise to claims for disparate treatment, harassment, denial of reasonable accommodation, and/or retaliation. Therefore, these charges should be investigated and analyzed under all four theories of ostrich liability to the extent applicable, even if the charging party only persuasive essays examples raises one claim. Overview: Religion is very broadly defined under Title VII. Ostrich Feathers? Religious beliefs, practices, and persuasive examples, observances include those that are theistic [18] in nature, as well as non-theistic “moral or ethical beliefs as to what is right and wrong which are sincerely held with the masjid nabawi strength of traditional religious views.” Religious beliefs can include unique views held by a few or even one individual; however, mere personal preferences are not religious beliefs. Title VII requires employers to accommodate religious beliefs, practices, and observances if the persuasive essays beliefs are “sincerely held” and the reasonable accommodation poses no undue hardship on with ostrich feathers, the employer. Title VII defines “religion” to include “all aspects of examples religious observance and practice as well as belief.” [19] Religion includes not only traditional, organized religions such as Christianity, Judaism, Islam, Hinduism, and Buddhism, but also religious beliefs that are new, uncommon, not part of a formal church or sect, only subscribed to by a small number of people, or that seem illogical or unreasonable to with ostrich feathers others. [20] Further, a person’s religious beliefs “need not be confined in persuasive either source or content to traditional or parochial concepts of religion.” [21] A belief is “religious” for Title VII purposes if it is “‘religious’ in the person’s own scheme of things,” [22] i.e. , it is an informative “a sincere and meaningful belief that occupies in the life of its possessor a place parallel to that filled by God.” [23] An employee’s belief or practice can be “religious” under Title VII even if the employee is persuasive essays affiliated with a religious group that does not espouse or recognize that individual’s belief or practice, or if few or no other people adhere to it. [24]

Religious beliefs include theistic beliefs as well as non-theistic “moral or ethical beliefs as to what is nabawi dome right and wrong which are sincerely held with the strength of persuasive essays traditional religious views.” [25] Although courts generally resolve doubts about particular beliefs in favor of finding that they are religious, [26] beliefs are not protected merely because they are strongly held. Rather, religion typically concerns “ultimate ideas” about a dagger i see before “life, purpose, and death.” [27] Social, political, or economic philosophies, as well as mere personal preferences, are not “religious” beliefs protected by Title VII. [28] Religious observances or practices include, for example, attending worship services, praying, wearing religious garb or symbols, displaying religious objects, adhering to certain dietary rules, proselytizing or other forms of religious expression, or refraining from certain activities. Determining whether a practice is religious turns not on the nature of the activity, but on the employee’s motivation. The same practice might be engaged in by one person for religious reasons and by another person for persuasive essays, purely secular reasons.

Whether or not the practice is “religious” is therefore a situational, case-by-case inquiry. [29] For example, one employee might observe certain dietary restrictions for religious reasons while another employee adheres to the very same dietary restrictions but for secular ( e.g. , health or environmental) reasons. An Informative Essay? [30] In that instance, the same practice might in one case be subject to reasonable accommodation under Title VII because an employee engages in examples the practice for religious reasons, and in nabawi another case might not be subject to reasonable accommodation because the practice is engaged in for secular reasons. The following examples illustrate these concepts: Employment Decisions Based on essays examples, “Religion” An otherwise qualified applicant is a dagger i see before me analysis not hired because he is a self-described evangelical Christian. Essays? A qualified non-Jewish employee is how i world denied promotion because the supervisor wishes to persuasive essays examples give a preference based on religion to a fellow Jewish employee. An employer terminates an employee based on dome, his disclosure to persuasive examples the employer that he has recently converted to the Baha’i Faith. Each of these is an example of an employment decision based on the religious affiliation of the applicant or employee, and therefore is is this before based on “religion” within the meaning of Title VII.

Religious Practice versus Secular Practice. A Seventh-day Adventist employee follows a vegetarian diet because she believes it is persuasive essays religiously prescribed by the scriptural passage “[b]ut flesh with the confession of shopaholics life thereof, which is the blood thereof, shall ye not eat,” (Genesis 9:4). Her vegetarianism is a religious practice, even though not all Seventh-day Adventists share this belief or follow this practice, and essays examples, even though many individuals adhere to how i see the world a vegetarian diet for purely secular reasons. Types of essays examples Religious Practice or Observance. A Catholic employee requests a schedule change so that he can attend church services on Good Friday. Ostrich Feathers? A Muslim employee requests an exception to the company’s dress and persuasive essays, grooming code allowing her to inuit history wear her headscarf, or a Hindu employee requests an exception allowing her to wear her bindi (religious forehead marking). An atheist asks to be excused from the religious invocation offered at the beginning of staff meetings. An adherent to Native American spiritual beliefs seeks unpaid leave to attend a ritual ceremony. An employee who identifies as Christian but is not affiliated with a particular sect or denomination requests accommodation of his religious belief that working on his Sabbath is prohibited.

Each of these accommodation requests relates to a “religious” belief or practice within the meaning of persuasive examples Title VII. By contrast, a request for a schedule change to help set up decorations or prepare food for a church event, for instance, typically does not involve a “religious” belief or practice within the meaning of Title VII. [31] Supervisor Considers Belief Illogical. Morgana asks for time off on October 31 to attend the confession “Samhain Sabbat,” the New Year observance of examples Wicca, her religion. Her supervisor refuses, saying that Wicca is not a “real” religion but an confession of shopaholics “illogical conglomeration” of “various aspects of the occult, such as faith healing, self?hypnosis, tarot card reading, and spell casting, which are not religious practices.” The supervisor’s refusal to accommodate her on essays, the ground that he believes her religion is illogical violates Title VII unless the employer can show her request would impose an undue hardship.

The law applies to religious beliefs even though others may find them “incorrect” or “incomprehensible.” [32] Unique Belief Can Be Religious. Edward practices the Kemetic religion, based on ancient Egyptian faith, and is this a dagger i see before, affiliates himself with a tribe numbering fewer than ten members.He states that he believes in various deities, and essays examples, follows the faith’s concept of Ma’at, a guiding principle regarding truth and order that represents physical and moral balance in the universe. During a religious ceremony he received small tattoos encircling his wrist, written in the Coptic language, which express his servitude to Ra, the Egyptian god of the sun. When his employer asks him to cover the is this a dagger before tattoos, he explains that it is a sin to cover them intentionally because doing so would signify a rejection of Ra. These can be religious beliefs and practices even if no one else or few other people subscribe to them. [33] Personal Preference That is Not a Religious Belief. Sylvia wears several tattoos and has recently had her nose and eyebrows pierced. Persuasive Essays? A newly hired manager implements a dress code that requires that employees have no visible piercings or tattoos. How To Start An Informative? Sylvia says that her tattoos and piercings are religious because they reflect her belief in body art as self-expression and should be accommodated.

However, the evidence demonstrates that her tattoos and piercings are not related to any religious belief system. For example, they do not function as a symbol of any religious belief, and do not relate to any “ultimate concerns” such as life, purpose, death, humanity’s place in the universe, or right and persuasive essays examples, wrong, and they are not part of a moral or ethical belief system. Therefore, her belief is inuit history a personal preference that is not religious in nature. [34] Title VII requires employers to accommodate only those religious beliefs that are “sincerely held.” [35] Therefore, whether or not a religious belief is “sincerely held” by an applicant or employee is only relevant to religious accommodation, not to persuasive essays claims of disparate treatment or harassment because of religion. In those claims, it is the motivation of the inuit history discriminating official, not the persuasive essays examples actual beliefs of the individual alleging discrimination, that are typically relevant in confession of shopaholics determining if the discrimination that occurred was because of religion. A detailed discussion of reasonable accommodation of sincerely held religious beliefs appears in § IV, but the meaning of “sincerely held” is addressed here. Like the “religious” nature of a belief or practice, the “sincerity” of an employee’s stated religious belief is usually not in dispute. Nevertheless, there are some circumstances in which an employer may assert as a defense that it was not required to provide accommodation because the persuasive examples employee’s asserted religious belief was not sincerely held.

Factors that either alone or in combination might undermine an employee’s assertion that he sincerely holds the religious belief at issue include: whether the employee has behaved in a manner markedly inconsistent with the professed belief; [36] whether the confession of shopaholics accommodation sought is a particularly desirable benefit that is likely to be sought for secular reasons; whether the essays timing of the request renders it suspect ( e.g. , it follows an inuit history earlier request by the employee for the same benefit for secular reasons); and whether the employer otherwise has reason to believe the accommodation is not sought for religious reasons. Examples? However, none of these factors is dispositive. With Ostrich? For example, although prior inconsistent conduct is relevant to the question of sincerity, an essays individual’s beliefs or degree of adherence may change over time, and therefore an ostrich feathers employee’s newly adopted or inconsistently observed religious practice may nevertheless be sincerely held. [37] An employer also should not assume that an employee is insincere simply because some of his or her practices deviate from the persuasive essays examples commonly followed tenets of his or her religion. [38] 3. Employer Inquiries into Religious Nature or Sincerity of a dagger i see before me analysis Belief. Because the definition of religion is broad and protects beliefs and practices with which the employer may be unfamiliar, the employer should ordinarily assume that an persuasive essays employee’s request for religious accommodation is nabawi based on persuasive essays examples, a sincerely-held religious belief. If, however, an of shopaholics employee requests religious accommodation, and an employer has an objective basis for questioning either the religious nature or the sincerity of a particular belief or practice, the employer would be justified in seeking additional supporting information. See infra § IV-A-2. If the persuasive essays examples Respondent (R) disputes that the Charging Party’s (“CP’s”) belief is “religious,” consider the following: Begin with the CP’s statements. What religious belief or practice does the CP claim to have? In some cases, the of shopaholics CP’s credible testimony regarding his belief or practice will be sufficient to demonstrate that it is religious.

In other cases, however, the investigator may need to ask follow-up questions about the nature and tenets of the asserted religious beliefs, and/or any associated practices, rituals, clergy, observances, etc., in order to identify a specific religious belief or practice or determine if one is at essays examples, issue. Since religious beliefs can be unique to an individual, evidence from others is not always necessary. However, if the start an informative essay CP believes such evidence will support his or her claim, the investigator should seek evidence such as oral statements, affidavits, or other documents from CP’s religious leader(s) if applicable, or others whom CP identifies as knowledgeable regarding the religious belief or practice in question. Remember, where an alleged religious practice or belief is at persuasive examples, issue, a case-by-case analysis is required. Investigators should not make assumptions about a religious practice or belief. In some cases, to a dagger i see before me analysis determine whether CP’s asserted practice or belief is “religious” as defined under Title VII, the investigator’s general knowledge will be insufficient, and persuasive essays examples, additional objective information will have to be obtained, while nevertheless recognizing the intensely personal characteristics of adherence to a religious belief. If the Respondent disputes that CP’s belief is “sincerely held,” the following evidence may be relevant:

Oral statements, an is this a dagger me analysis affidavit, or other documents from CP describing his or her beliefs and practices, including information regarding when CP embraced the belief or practice, as well as when, where, and how CP has adhered to the belief or practice; and/or, Oral statements, affidavits, or other documents from potential witnesses identified by CP or R as having knowledge of whether CP adheres or does not adhere to the belief or practice at issue ( e.g ., CP’s religious leader (if applicable), fellow adherents (if applicable), family, friends, neighbors, managers, or co-workers who may have observed his past adherence or lack thereof, or discussed it with him). Overview: Title VII jurisdictional rules apply to all religious discrimination claims under the statute. However, specially-defined “religious organizations” and persuasive, “religious educational institutions” are exempt from certain religious discrimination provisions, and a “ministerial exception” bars Title VII claims by employees who serve in clergy roles. Title VII’s prohibitions apply to employers, employment agencies, and unions, [39] subject to inuit history the statute’s jurisdictional requirements.

See EEOC Compliance Manual, “Threshold Issues,” https://www.eeoc.gov/policy/docs/threshold.html. Those covered entities must carry out essays examples, their activities in a nondiscriminatory manner and provide reasonable accommodation unless doing so would impose an undue hardship. [40] Unions also can be liable if they knowingly acquiesce in employment discrimination against how to start essay their members, join or tolerate employers’ discriminatory practices, or discriminatorily refuse to persuasive examples represent employees’ interests. [41] Under Title VII, religious organizations are permitted to give employment preference to members of their own religion. [42] The exception applies only to those institutions whose “purpose and with, character are primarily religious.” [43] That determination is to examples be based on “[a]ll significant religious and secular characteristics.” [44] Although no one factor is dispositive, significant factors to consider that would indicate whether an entity is religious include: Do its articles of ostrich incorporation state a religious purpose? Are its day-to-day operations religious ( e.g. , are the persuasive examples services the red mules with entity performs, the product it produces, or the educational curriculum it provides directed toward propagation of the religion)? Is it not-for-profit? Is it affiliated with or supported by a church or other religious organization? [45] This exception is not limited to religious activities of the organization. [46] However, it only allows religious organizations to persuasive prefer to employ individuals who share their religion. [47] The exception does not allow religious organizations otherwise to discriminate in employment on how i see the world, protected bases other than religion, such as race, color, national origin, sex, age, or disability. Persuasive Essays Examples? [48] Thus, a religious organization is not permitted to engage in racially discriminatory hiring by asserting that a tenet of its religious beliefs is not associating with people of other races. Similarly, a religious organization is world not permitted to deny fringe benefits to married women but not to married men by persuasive asserting a religiously based view that only men can be the head of a household. Sex Discrimination Not Excused.

Justina works at Tots Day Care Center. Tots is run by a religious organization that believes that, while women may work outside of the home if they are single or have their husband’s permission, men should be the is this i see heads of persuasive examples their households and the primary providers for their families. Believing that men shoulder a greater financial responsibility than women, the organization pays female teachers less than male teachers. Masjid? The organization’s practice of unequal pay based on sex constitutes unlawful discrimination. [49] Courts have held, based on First Amendment constitutional considerations, that clergy members cannot bring claims under the federal employment discrimination laws, including Title VII, the Age Discrimination in Employment Act, the Equal Pay Act, and the Americans with Disabilities Act, because “[t]he relationship between an organized church and its ministers is its lifeblood.” [50] This “ministerial exception” comes not from the text of the statutes, but from the persuasive essays First Amendment principle that governmental regulation of church administration, including the appointment of clergy, impedes the free exercise of religion and masjid nabawi, constitutes impermissible government entanglement with church authority. [51] Thus, courts will not ordinarily consider whether a church’s employment decision concerning one of its ministers was based on discriminatory grounds, although some courts have allowed ministers to bring sexual harassment claims. [52] The ministerial exception applies only to those employees who perform essentially religious functions, namely those whose primary duties consist of engaging in church governance, supervising a religious order, or conducting religious ritual, worship, or instruction. [53] The exception is not limited to persuasive ordained clergy, [54] and with ostrich, has been applied by courts to others involved in clergy-like roles who conduct services or provide pastoral counseling. However, the exception does not necessarily apply to everyone with a title typically conferred upon clergy ( e.g. , minister). [55] In short, in examples each case it is necessary to make a factual determination of how i whether the function of the position is one to which the persuasive essays exception applies. Title VII’s prohibition against disparate treatment based on religion generally functions like its prohibition against disparate treatment based on race, color, sex, or national origin.

Disparate treatment violates the statute whether motivated by bias against or preference toward an applicant or employee due to his religious beliefs, practices, or observances or lack thereof. Thus, for example, except to the extent permitted by the religious organization and ministerial exceptions, an employer may not refuse to recruit, hire, or promote individuals of a certain religion, may not impose stricter promotion requirements for persons of a certain religion, and inuit history, may not impose more or different work requirements on an employee because of that employee’s religious beliefs or practices. [56] The following sub-sections address work scenarios that may lead to persuasive essays claims of religious discrimination. 1. Recruitment, Hiring, and Promotion. Employers that are not religious organizations may neither recruit individuals of a particular religion nor adopt recruitment practices, such as word-of-mouth recruitment, that have the purpose or effect of discriminating based on religion. Start An Informative Essay? Title VII permits employers that are not religious organizations to essays hire and start, employ employees on the basis of religion only if religion is “a bona fide occupational qualification reasonably necessary to the normal operation of that particular business or enterprise.” [57]

For example, an employer may not refuse to hire an applicant simply because he does not share the essays employer’s religious beliefs, and a dagger i see before me analysis, conversely may not select one applicant over essays examples another based on a preference for employees of a particular religion. [58] Similarly, employment agencies may not comply with requests from employers to engage in how to an informative essay discriminatory recruitment or referral practices, for example by screening out applicants who have names often associated with a particular religion ( e.g., Mohammed). Moreover, an examples employer may not exclude an applicant from hire merely because he or she may need a reasonable accommodation that could be provided absent undue hardship. [59] Charles, the president of a company that owns several gas stations, needs managers for the new convenience stores he has decided to add to the stations. Is This A Dagger I See? He posts a job announcement at the Hindu Temple he attends and persuasive, asks other members of the temple to refer only a dagger Hindu friends or family members who may be interested in the position. He does no other recruitment. By limiting his recruitment to Hindus, Charles is engaging in unlawful discrimination. Mary is a human resources officer who is filling a vacant administrative position at her company. Persuasive Essays? During the application process, she performs an Internet search on the candidates and feathers, learns that one applicant, Jonathan, has written an article for the local chapter of the Ethical Society setting forth his view that religion has been historically divisive and explaining why he subscribes to no religious beliefs or practices.

Although Mary believes he is the most qualified candidate, she does not hire him because she knows that many current company employees are observant Christians like her, and she believes they would be more comfortable working with someone like-minded. By not hiring Jonathan because of his lack of religious identification, the company violated Title VII. Darpak, who practices Buddhism, holds a Ph.D. degree in engineering and applied for a managerial position at the research firm where he has worked for ten years. He was rejected in favor of a non-Buddhist candidate who was less qualified. The company vice president who made the promotion decision advised Darpak that he was not selected because “we decided to go in a different direction.” However, the vice president confided to co-workers at a social function that he did not select Darpak because he thought a Christian manager could make better personal connections with the firm’s clients, many of essays examples whom are Christian. The vice president’s statement, combined with the lack of any legitimate non-discriminatory reason for selecting the less qualified candidate, as well as the of shopaholics evidence that Darpak was the examples best qualified candidate for the position, suggests that the proffered reason was a pretext for discrimination against Darpak because of his religious views. [60] Title VII also prohibits employers from masjid dome disciplining or discharging employees because of their religion. [61] Joanne, a retail store clerk, is frequently 10-15 minutes late for her shift on several days per week when she attends Mass at a Catholic Church across town. Her manager, Donald, has never disciplined her for this tardiness, and persuasive essays, instead filled in for her at the cash register until she arrived, stating that he understood her situation. On the other hand, Yusef, a newly hired clerk who is Muslim, is disciplined by Donald for arriving 10 minutes late for his shift even though Donald knows it is due to inuit history his attendance at services at essays examples, the local Mosque.

While Donald can require all similarly situated employees to be punctual, he is engaging in disparate treatment based on religion by disciplining only Yusef and not Joanne absent a legitimate nondiscriminatory reason for treating them differently. A charge alleging the above facts might also present a claim for confession of shopaholics, denial of reasonable accommodation. While the employer may require employees to be punctual, it may have to accommodate an employee who seeks leave or a schedule change to resolve the conflict between religious services and persuasive, a work schedule, unless the accommodation would pose an start undue hardship. [62] 3. Compensation and essays examples, Other Terms, Conditions, or Privileges of Employment. Title VII prohibits discrimination on a protected basis “with respect to . . Dome? . compensation, terms, conditions, or privileges of employment,” for example, setting or adjusting wages, granting benefits, and/or providing leave in a discriminatory fashion. [63] Wages and Benefits. Janet, who practices Native American spirituality, is a newly hired social worker for an agency. As a benefit to persuasive examples its employees, the confession of shopaholics agency provides tuition reimbursement for professional continuing education courses offered by selected providers. Janet applied for tuition reimbursement for an approved course that was within permitted cost limit. Janet’s supervisor denied her request for tuition reimbursement, stating that since Janet believes in “voodoo” she “won’t make a very good caseworker.” By refusing, because of Janet’s religious beliefs, to provide the tuition reimbursement to essays which Janet was otherwise entitled as a benefit of her employment, Janet’s supervisor has discriminated against Janet on the basis of religion. Title VII’s prohibition on disparate treatment based on religious beliefs also can apply to disparate treatment of religious expression in the workplace. Is This Me Analysis? [64]

Eve is a secretary who displays a Bible on her desk at work. Xavier, a secretary in the same workplace, begins displaying a Quran on his desk at work. Their supervisor allows Eve to retain the Bible but directs Xavier to put the Quran out of view because, he states, co-workers “will think you are making a political statement, and with everything going on in the world right now we don’t need that around here.” This differential treatment of similarly situated employees with respect to the display of a religious item at work constitutes disparate treatment based on religion in violation of Title VII. Persuasive Examples? [65] Charges involving religious expression may present claims not only of disparate treatment, but also of harassment and/or denial of reasonable accommodation. Investigation of claims of harassment and denial of reasonable accommodation are addressed respectively in §§ III and confession, IV of this document. Persuasive? As discussed in greater detail in those sections, Title VII requires employers to accommodate expression that is based on a sincerely held religious practice or belief, unless it threatens to constitute harassment or otherwise poses an undue hardship on the conduct of the business. Thus, for example, an employer can restrict religious expression where it would cause customers or co-workers reasonably to perceive the materials to express the employer’s own message, or where the essay item or message in question is essays harassing or otherwise disruptive. [66] For further discussion of how to analyze when accommodation of religious expression would pose an undue hardship, refer to the sections on Harassment at § III-C and is this a dagger i see me analysis, Accommodation at § IV-C-6. If an employer takes an action based on the discriminatory preferences of others, including co-workers or clients, the employer is unlawfully discriminating. Employment Decision Based on Customer Preference. Harinder, who wears a turban as part of his Sikh religion, is hired to work at the counter in a coffee shop. A few weeks after Harinder begins working, the manager notices that the work crew from the persuasive essays construction site near the shop no longer comes in for coffee in how to start an informative essay the mornings.

When he inquires, the crew complains that Harinder, whom they mistakenly believe is Muslim, makes them uncomfortable in light of the September 11 th attacks. Persuasive Essays? The manager tells Harinder that he has to let him go because the customers’ discomfort is inuit history understandable. Essays? The manager has subjected Harinder to see the unlawful religious discrimination by taking an adverse action based on essays examples, customers’ preference not to have a cashier of masjid nabawi Harinder’s perceived religion. Harinder’s termination based on customer preference would violate Title VII regardless of examples whether he was Muslim, Sikh, or any other religion. In general, an masjid dome employer may adopt security requirements for its employees or applicants, provided they are adopted for nondiscriminatory reasons and are applied in a nondiscriminatory manner. For example, an employer may not require Muslim applicants to undergo a background investigation or more extensive security procedures because of their religion while not imposing the same requirements on similarly situated applicants who are non-Muslim, unless such job requirements are imposed by federal statute or Executive Order in the interest of national security. [67]

D. Bona Fide Occupational Qualification. Title VII permits employers to hire and employ employees on the basis of religion if religion is “a bona fide occupational qualification [“BFOQ”] reasonably necessary to the normal operation of that particular business or enterprise.” [68] Religious organizations do not typically need to rely on this BFOQ defense, however, because the “religious organization” exception in Title VII permits them to prefer their co-religionists. See supra § I-C. It is well settled that for essays, employers that are not religious organizations and therefore seek to rely on the BFOQ defense to justify a religious preference, the defense is a narrow one and can rarely be successfully invoked. [69] Employers can reduce the i see risk of discriminatory employment decisions by establishing written objective criteria for essays examples, evaluating candidates for hire or promotion and me analysis, applying those criteria consistently to all candidates. Essays Examples? In conducting job interviews, employers can ensure nondiscriminatory treatment by asking the how i same questions of all applicants for a particular job or category of job and inquiring about matters directly related to persuasive essays the position in question. Employers can reduce the risk of religious discrimination claims by is this a dagger i see before me analysis carefully and essays examples, timely recording the accurate business reasons for disciplinary or performance?related actions and sharing these reasons with the affected employees. When management decisions require the i see me analysis exercise of essays subjective judgment, employers can reduce the risk of discriminatory decisions by of shopaholics providing training to inexperienced managers and encouraging them to consult with more experienced managers or human resources personnel when addressing difficult issues.

If an employer is persuasive essays examples confronted with customer biases, e.g., an adverse reaction to being served by an employee due to religious garb, the how to start essay employer should consider engaging with and educating the customers regarding any misperceptions they may have and/or the equal employment opportunity laws. Overview: Religious harassment is analyzed and proved in the same manner as harassment on other Title VII bases, e.g., race, color, sex, or national origin. [70] However, the facts of religious harassment cases may present unique considerations, especially where the alleged harassment is persuasive examples based on another employee’s religious practices a situation that may require an employer to reconcile its dual obligations to take prompt remedial action in inuit history response to alleged harassment and to accommodate certain employee religious expression. Religious harassment in violation of Title VII occurs when employees are: (1) required or coerced to abandon, alter, or adopt a religious practice as a condition of employment (this type of “quid pro quo” harassment may also give rise to a disparate treatment or denial of accommodation claim in some circumstances), [71] or (2) subjected to persuasive essays unwelcome statements or conduct that is based on religion and is this i see, is so severe or pervasive that the individual being harassed reasonably finds the work environment to be hostile or abusive, and there is persuasive a basis for holding the employer liable. [72] 1. How To Start An Informative? Religious Coercion That Constitutes a Tangible Employment Action. Title VII is violated when an employer or supervisor explicitly or implicitly coerces an employee to abandon, alter, or adopt a religious practice as a condition of receiving a job benefit or avoiding an adverse action. [73] Religious Conformance Required for Promotion. Wamiq was raised as a Muslim but no longer practices Islam. His supervisor, Arif, is persuasive a very devout Muslim who tries to inuit history persuade Wamiq not to abandon Islam and advises him to follow the teachings of the Quran. Arif also says that if Wamiq expects to essays advance in the company, he should join Arif and other Muslims for weekly prayer sessions in is this i see Arif’s office. Notwithstanding this pressure to conform his religious practices in order to be promoted, Wamiq refused to attend the weekly prayer sessions, and was subsequently denied the promotion for persuasive essays, which he applies even though he was the most qualified. Arif’s conduct indicates that the masjid nabawi promotion would have been granted if Wamiq had participated in the prayer sessions and had become an observant Muslim.

Absent contrary evidence, the employer will be liable for harassment for persuasive examples, conditioning Wamiq’s promotion on his adherence to how i Arif’s views of appropriate religious practice. [74] This would also be actionable as disparate treatment based on religion. In addition, if the prayer sessions were made mandatory and Wamiq had asked to be excused on religious grounds, Arif would have been required to excuse him from the prayer sessions as a reasonable accommodation. A claim of harassment based on coerced religious participation or non-participation, however, only arises where it was intended to make the essays employee conform to with ostrich feathers or abandon a religious belief or practice. By contrast, an employer would not be engaging in persuasive examples coercion if it required an employee to participate in a workplace activity that conflicts with the employee’s sincerely held religious belief, so long as the how to start employer demonstrates that it would impose an undue hardship to accommodate the employee’s request to persuasive be excused. However, the same fact pattern may give rise to claims of confession of shopaholics disparate treatment, harassment, and/or denial of accommodation. For example, terminating rather than accommodating an employee may give rise to both denial of accommodation and discriminatory discharge claims. [75] For discussion of the accommodation issue, see § IV, infra .[76] Title VII’s prohibition against religious discrimination can also be violated if the employee is subjected to a hostile work environment because of religion. [77] An unlawful hostile environment based on essays examples, religion might take the form of either verbal or physical harassment or unwelcome imposition of religious views or practices on an employee. A hostile work environment is created when the “workplace is is this permeated with discriminatory intimidation, ridicule, and insult that is sufficiently severe or pervasive to alter the conditions of the victim’s employment and essays examples, create an a dagger me analysis abusive working environment.” [78] To establish a case of religious harassment, an employee must show that the harassment was: (1) based on persuasive essays examples, his religion; (2) unwelcome; (3) sufficiently severe or pervasive to alter the conditions of employment by creating an intimidating, hostile, or offensive work environment; and, (4) that there is a basis for employer liability. [79] To support a religious harassment claim, the inuit history adverse treatment must be based on religion. [80] This standard can be satisfied regardless of whether the harassment is motivated by persuasive examples the religious belief or observance or lack thereof of either the harasser or the targeted employee.

Moreover, while verbally harassing conduct clearly is based on of shopaholics, religion if it has religious content, harassment can also be based on religion even if religion is not explicitly mentioned. [81] Harassing Conduct Based on Religion Religion Mentioned. Mohammed is an Indian-born Muslim employed at persuasive examples, a car dealership. How To Essay? Because he takes scheduled prayer breaks during the work day and observes Muslim dietary restrictions, his co-workers are aware of his religious beliefs. Upset about the 9/11 terrorist attacks, his co-workers and managers began making mocking comments about his religious dietary restrictions and need to pray during the workday. They repeatedly referred to essays him as “Taliban” or “Arab” and asked him “why don’t you just go back where you came from since you believe what you believe?” When Mohammed questioned why it was mandatory for of shopaholics, all employees to attend a United Way meeting, his supervisor said: “This is America.

That’s the way things work over persuasive examples here. This is not the Islamic country where you come from.” After this confrontation, the masjid nabawi dome supervisor issued Mohammed a written warning stating that he “was acting like a Muslim extremist” and that the supervisor could not work with him because of his “militant stance.” This harassment is “based on” religion and national origin. [82] Harassing Conduct Based on Religion Religion Not Mentioned. Shoshanna is examples a Seventh-day Adventist whose work schedule was adjusted to feathers accommodate her Sabbath observance, which begins at sundown each Friday. Persuasive Essays Examples? When Nicholas , the before new head of Shoshanna’s department, was informed that he must accommodate her, he told a colleague that “anybody who cannot work regular hours should work elsewhere.” Nicholas then moved the essays examples regular Monday morning staff meetings to late Friday afternoon, repeatedly scheduled staff and client meetings on Friday afternoons, and often marked Shoshanna AWOL when she was not scheduled to work.

In addition, Nicholas treated her differently than her colleagues by, for example, denying her training opportunities and loudly berating her with little or no provocation. Although Nicholas did not mention Shoshanna’s religion, the an informative evidence shows that his conduct was because of Shoshanna’s need for religious accommodation, and therefore was “based on” religion. [83] To be unlawful, harassing conduct must be unwelcome. Essays? Conduct is masjid nabawi “unwelcome” when the employee did not solicit or incite it and regards it as undesirable or offensive. [84] It is necessary to evaluate all of the surrounding circumstances to determine whether or not particular conduct or remarks are unwelcome. [85] For example, where an employee is persuasive upset by repeated mocking use of derogatory terms or comments [86] about his religious beliefs or observance by a colleague, it may be evident that the conduct is unwelcome. This would stand in stark contrast to a situation where the same two employees were engaged in a consensual conversation that involves a spirited debate of religious views, and neither employee indicates that he was upset by it. The distinction between welcome and world, unwelcome conduct is especially important in the religious context in situations involving proselytizing of employees who have not invited such conduct. [87] Where a religious employee attempts to persuade a non-religious employee of the persuasive correctness of his belief, or vice versa, the conduct may or may not be welcome. When an employee objects to particular religious expression, unwelcomeness is evident. [88] Beth’s colleague, Bill, repeatedly talked to her at work about her prospects for salvation. For several months, she did not object and discussed the matter with him. When he persisted even after she told him that he had “crossed the confession of shopaholics line” and should stop having non-work related conversations with her, the persuasive conduct was clearly unwelcome. [89] Even unwelcome religiously motivated conduct is not unlawful unless “the victim . . . subjectively perceive[s] the environment to be abusive” and the conduct is “severe or pervasive enough to create an inuit history objectively hostile or abusive work environment -- an environment that a reasonable person would find hostile or abusive.” [90] Whether a reasonable person would perceive the conduct as abusive turns on common sense and context, looking at the totality of the circumstances. Persuasive Essays Examples? [91] Relevant factors include whether the conduct was abusive, derogatory, or offensive; [92] whether the conduct was frequent; [93] and whether the red mules with conduct was humiliating or physically threatening. [94]

Reasonable Person Perceives Conduct To Be Hostile. Although he hired employees of all religions, the persuasive essays Director of is this a dagger “Get Drug Free Today” required employees to sign a statement that they would support the values of the Church of Scientology. He regularly chastised those whose conduct did not conform to those values. A reasonable person would perceive this to be a religiously hostile work environment. Persuasive Essays Examples? [95] To “alter the confession of shopaholics conditions of employment,” conduct need not cause economic or psychological harm. [96] It need not impair work performance, discourage employees from remaining on persuasive, the job, or impede their advancement. [97] The presence of one or more of those factors would buttress the claim, but is not required. [98] However, Title VII is not a general civility code, and does not render all insensitive or offensive comments, petty slights, and annoyances illegal. [99] Offhand or isolated incidents (unless extremely serious) will not rise to is this before the level of illegality. [100] Insensitive Comments Not Enough To Constitute Hostile Environment. Marvin is an Orthodox Jew who was hired as a radio show host. When he started work, a co-worker, Stacy, pointed to his yarmulke and asked, “Will your headset fit over that?” On a few occasions, Stacy, made other remarks about the yarmulke, such as: “Nice hat. Persuasive Examples? Is that a beanie?” and “Do they come in different colors?” Although the co-worker’s comments about his yarmulke were insensitive, they were not sufficiently severe or pervasive to create a hostile work environment for Marvin. [101] Isolated Comments Not Enough to Constitute Hostile Environment.

Bob, a supervisor, occasionally allowed spontaneous and voluntary prayers by employees during office meetings. Is This A Dagger Before Me Analysis? During one meeting, he referenced Bible passages related to “slothfulness” and persuasive essays examples, “work ethics.” Amy complained that Bob’s comments and the few instances of allowing voluntary prayers during office meetings created a hostile environment. The comments do not create an actionable harassment claim. They were not severe, and because they occurred infrequently, they were not sufficiently pervasive to state a claim. [102] The severity and pervasiveness factors operate inversely. The more severe the harassment, the less frequently the see the world incidents need to recur. At the same time, incidents that may not, individually, be severe may become unlawful if they occur frequently or in close proximity. [103] Although a single incident will seldom create an unlawfully hostile environment, it may do so if it is unusually severe, particularly if it involves physical threat. [104] One Instance of Physically Threatening Conduct Is Enough to Constitute Hostile Environment. Ihsaan is persuasive examples a Muslim.

Shortly after the terrorist attacks on September 11, 2001, Ihsaan came to work and found the words “You terrorists go back where you came from! We will avenge the victims!! Your life is next!” scrawled in red marker on his office door. Because of the timing of the confession of shopaholics statement and the direct physical threat, this incident, alone, is sufficiently severe to constitute hostile environment harassment based on religion and national origin. [105] Persistent Offensive Remarks Constitute Hostile Environment. Betty is a Mormon. During a disagreement regarding a joint project, a co-worker, Julian, tells Betty that she doesn’t know what she is talking about and that she should “go back to Salt Lake City.” When Betty subsequently proposes a different approach to the project, Julian tells her that her suggestions are as “flaky” as he would expect from essays “her kind.” When Betty tries to resolve the conflict, Julian tells her that if she is uncomfortable working with him, she can either ask to be transferred, or she can “just pray about it.” Over the next six months, Julian regularly makes similar negative references to ostrich Betty’s religion. Essays Examples? His persistent offensive remarks create a hostile environment. Religious expression that is repeatedly directed at an employee can become severe or pervasive, whether or not the see the content is intended to essays be insulting or abusive. Thus, for example, persistently reiterating atheist views to confession a religious employee who has asked that it stop can create a hostile environment. However, the essays extent to which the expression is directed at how i, a particular employee is relevant to determining whether or when it could reasonably be perceived to be severe or pervasive by that employee. Persuasive Essays Examples? [106] For example, although it is red mules with ostrich conceivable that one employee may allege that he is offended by a colleague’s wearing of religious garb, expressing one’s religion by wearing religious garb is not religious harassment.

It merely expresses an essays examples individual’s religious affiliation and does not demean other religious views. As such, it is not objectively hostile. Nor is it directed at any particular individual. Similarly, workplace displays of red mules with feathers religious artifacts or posters that do not demean other religious views generally would not constitute religious harassment. No Hostile Environment from Comments That Are Not Abusive and Not Directed at Complaining Employee. While eating lunch in the company cafeteria, Clarence often overhears conversations between his co-workers Dharma and Khema. Dharma, a Buddhist, is discussing meditation techniques with Khema, who is interested in Buddhism. Essays? Clarence strongly believes that meditation is an occult practice that leads to devil worship and complains to their supervisor that Dharma and Khema are creating a hostile environment for a dagger i see before me analysis, him.

Such conversations do not constitute severe or pervasive religious harassment of Clarence because they do not insult other religions and they were not directed at him. Overview: An employer is always liable for a supervisor’s harassment if it results in a tangible employment action. However, if it does not, the employer may be able to avoid liability or limit damages by establishing an affirmative defense that includes two necessary elements: (a) the essays employer exercised reasonable care to prevent and correct promptly any harassing behavior, and is this me analysis, (b) the persuasive essays examples employee unreasonably failed to take advantage of any preventive or corrective opportunities provided by the employer or to avoid harm otherwise. In cases of harassment by i see me analysis a co-worker or a third party over whom the employer had some control, an employer is liable if it knew or should have known about the harassment and failed to persuasive take immediate and appropriate corrective action. 1. Red Mules With? Harassment by Supervisors or Managers. Employers are automatically liable for supervisory harassment that results in a tangible employment action such as a denial of promotion, demotion, discharge, or constructive discharge. If the harassment does not result in a tangible employment action, the employer can attempt to essays examples prove, as an affirmative defense to liability, that: (1) the nabawi dome employer exercised reasonable care to prevent and promptly correct any harassing behavior, and (2) the employee unreasonably failed to take advantage of any preventive or corrective opportunities provided by the employer or to otherwise avoid harm. [107] Supervisory Harassment with Tangible Employment Action. George, a high level official in a state agency, is an atheist who has frequently been heard to say that he thinks anyone who is deeply religious is a zealot with his own agenda and cannot be trusted to act in examples the best interests of the with feathers public.

George particularly ridicules Debra, a devoutly observant Jehovah’s Witness, and consistently withholds the most desirable assignments from her. He denies her request for a promotion to a more prestigious job in another division, saying that he can’t let her “spread that religious poppycock any further.” Debra files a religious harassment charge. Respondent asserts in its position statement that it is not liable because Debra never made a complaint under its internal anti-harassment policy and complaint procedures. Because the harassment culminated in a tangible employment action (failure to promote), the persuasive employer is masjid liable for the harassment even if it has an effective anti-harassment policy, and even if Debra never complained. Additionally, the essays examples denial of promotion would be actionable as disparate treatment based on religion. Supervisory Harassment Without Tangible Employment Action. Jennifer’s employer, XYZ, had an anti-harassment policy and complaint procedure that covered religious harassment.

All employees were aware of it, because XYZ widely and regularly publicized it. Despite his knowledge of the policy, Jennifer’s supervisor frequently mocked her religious beliefs. When Jennifer told him that his comments bothered her, he told her that he was just kidding and of shopaholics, she should not take everything so seriously. Jennifer never reported the problem. When one of essays examples Jennifer’s co-workers eventually reported the supervisor’s harassing conduct, the employer promptly investigated, and acted effectively to stop the supervisor’s conduct. Jennifer then filed a religious harassment charge. Because the confession harassment of Jennifer did not culminate in a tangible employment action, XYZ may assert as an affirmative defense that it is not liable because Jennifer failed to persuasive essays examples make a complaint under its internal anti-harassment policy and how i world, complaint procedures. Persuasive Examples? On these facts, XYZ will not be liable for the harassment because Jennifer unreasonably failed to utilize XYZ’s available, effective complaint mechanisms, and because XYZ took prompt and reasonable corrective measures once it did learn of the harassment. An employer is confession of shopaholics liable for harassment by co-workers where it: knew or should have known about the harassment, and essays examples, failed to inuit history take prompt and appropriate corrective action. Persuasive Essays? [108] Harassment by Co-Workers.

John, who is a Christian Scientist, shares an office with Rick, a Mormon. Rick repeatedly tells John that he is practicing a false religion, and that he should study Mormon literature. Feathers? Despite John’s protestations that he is very happy with his religion and has no desire to convert, Rick regularly leaves religious pamphlets on John’s desk and tries to talk to him about religion. After vainly asking Rick to stop the behavior, John complains to their immediate supervisor, who dismisses John’s complaint on examples, the ground that Rick is a nice person who believes that he is just being helpful. How To An Informative Essay? If the harassment continues, the employer is liable because it knew, through the supervisor, about Rick’s harassing conduct but failed to take immediate and appropriate corrective action. [109] An employer is liable for harassment by essays examples non-employees where it: knew or should have known about the harassment, could control the harasser’s conduct or otherwise protect the employee, and failed to take prompt and appropriate corrective action. [110] Harassment by a Contractor. Tristan works for XYZ, a contractor that manages Crossroads Corporation’s mail room. When Tristan delivers the mail to Julia, the Crossroads receptionist, he gives her religious tracts, attempts to is this a dagger i see before convert her to essays his religion, and persists even after she tells him to how i stop. Julia reports Tristan’s conduct to persuasive essays her supervisor, who tells her that he cannot do anything because Tristan does not work for inuit history, Crossroads. If the harassment continues, the essays supervisor’s failure to act will subject Crossroads to see the liability because Tristan’s conduct is pervasive and Crossroads refused to take preventive action within its control.

Options available to Julia’s supervisor or the persuasive appropriate individual in the supervisor’s chain of command might include initiating a meeting with Tristan and XYZ management regarding the harassment and demanding that it cease, that appropriate disciplinary action be taken if it continues, and/or that a different mail carrier be assigned to Julia’s route. C. Special Considerations for Employers When Balancing Anti-Harassment and Accommodation Obligations With Respect to how i see the Religious Expression. While some employees believe that religion is intensely personal and private, others are open about their religion. [111] There are employees who may believe that they have a religious obligation to essays share their views and to of shopaholics try to essays examples persuade co-workers of the truth of masjid their religious beliefs, i.e. , to proselytize. Some employers, too, may wish to examples express their religious views and share their religion with their employees. [112] As noted above, however, some employees may perceive proselytizing or other religious expression as unwelcome harassment based on their own religious beliefs and observances, or lack thereof. This mix of masjid dome divergent beliefs and persuasive, practices can give rise to conflicts requiring employers to balance the rights of employees who wish to express their religious beliefs with the masjid nabawi rights of other employees to be free from religious harassment under the foregoing Title VII harassment standards. [113] As discussed in more detail in § IV-C-6 of this document, an employer never has to persuasive essays accommodate expression of before a religious belief in essays examples the workplace where such an accommodation could potentially constitute harassment of co-workers, because that would pose an undue hardship for the employer. Therefore, while Title VII requires employers to confession accommodate an employee’s sincerely held religious belief in essays examples engaging in religious expression ( e.g. , proselytizing) in the workplace, an employer does not have to allow such expression if it imposes an undue hardship on the operation of the business. For example, it would be an undue hardship for how to start essay, an employer to accommodate proselytizing by examples an employee if it constituted potentially unlawful religious harassment of a co-worker who found it unwelcome, or if it otherwise interfered with the red mules with feathers operation of the business. [114] Because employers are responsible for maintaining a nondiscriminatory work environment, they are liable for perpetrating or tolerating religious harassment of their employees. An employer can reduce the chance that employees will engage in conduct that rises to the level of unlawful harassment by implementing an anti-harassment policy and an effective procedure for reporting, investigating, and persuasive essays, correcting harassing conduct. [115] Even if the policy does not prevent all such conduct, it will likely limit the employer’s liability where the affected employee allows the conduct to rise to the level of a dagger me analysis illegality by failing to report it. However, Title VII violations may result if an employer tries to avoid potential co-worker objections to employee religious expression by preemptively banning all religious communications in persuasive essays the workplace, since Title VII requires that employees’ sincerely held religious practices and beliefs be accommodated as long as no undue hardship is posed.

Employers should have a well-publicized and consistently applied anti-harassment policy that: (1) covers religious harassment; (2) clearly explains what is prohibited; (3) describes procedures for bringing harassment to management’s attention; and, (4) contains an assurance that complainants will be protected against retaliation. The procedures should include a complaint mechanism that includes multiple avenues for complaint; prompt, thorough, and impartial investigations; and prompt and appropriate corrective action. Red Mules With? Employers should allow religious expression among employees to the same extent that they allow other types of personal expression that are not harassing or disruptive. Once an employer is on notice that an employee objects to religious conduct that is directed at him or her, the employer should take steps to end the conduct because even conduct that the employer does not regard as abusive can become sufficiently severe or pervasive to persuasive examples affect the conditions of is this a dagger before employment if allowed to essays persist in the face of the of shopaholics employee’s objection. If harassment is perpetrated by a non-employee assigned by a contractor, the supervisor or other appropriate individual in the chain of command should initiate a meeting with the contractor regarding the harassment and persuasive, demand that it cease, that appropriate disciplinary action be taken if it continues, and/or that a different individual be assigned by the contractor.

To prevent conflicts from escalating to the level of a Title VII violation, employers should immediately intervene when they become aware of objectively abusive or insulting conduct, even absent a complaint. Employers should encourage managers to intervene proactively and discuss with subordinates whether particular religious expression is welcome if the manager believes the expression might be construed as harassing to a reasonable person. While supervisors are permitted to engage in see the certain religious expression, they should avoid expression that might due to their supervisory authority reasonably be perceived by examples subordinates as coercive, even when not so intended. Employees who are the recipients of unwelcome religious conduct should inform the individual engaging in red mules with the conduct that they wish it to stop. If the conduct does not stop, employees should report it to their supervisor or other appropriate company official in accordance with the procedures established in persuasive examples the company’s anti-harassment policy. Employees who do not wish to with feathers personally confront an individual who is directing unwelcome religious or anti-religious conduct towards them should report the essays conduct to their supervisor or other appropriate company official in accordance with the company’s anti-harassment policy. Overview: Title VII requires an employer, once on notice, to reasonably accommodate an employee whose sincerely held religious belief, practice, or observance conflicts with a work requirement, unless providing the accommodation would create an undue hardship. [116] However, the Title VII “undue hardship” defense is ostrich defined very differently than the persuasive essays examples “undue hardship” defense for disability accommodation under the Americans with Disabilities Act (ADA). Under Title VII, the undue hardship defense to providing religious accommodation requires a showing that the proposed accommodation in a particular case poses a “more than de minimis” cost or burden, which is a far lower standard for how to start an informative, an employer to meet than undue hardship under the essays examples ADA, which is defined in that statute as “significant difficulty or expense.” [117] A religious accommodation claim is distinct from a disparate treatment claim, in which the question is confession of shopaholics whether employees are treated equally. An individual alleging denial of religious accommodation is seeking an adjustment to persuasive essays examples a neutral work rule that infringes on the employee’s ability to masjid nabawi practice his religion. The accommodation requirement is “plainly intended to relieve individuals of the burden of choosing between their jobs and their religious convictions, where such relief will not unduly burden others.” [118]

A reasonable religious accommodation is any adjustment to the work environment that will allow the persuasive essays employee to comply with his or her religious beliefs. However, it is subject to the limit of more than de minimis cost or burden. The need for how i see the world, religious accommodation most frequently arises where an individual’s religious beliefs, observances, or practices conflict with a specific task or requirement of the job or the application process. The employer’s duty to essays accommodate will usually entail making a special exception from, or adjustment to, the masjid dome particular requirement so that the persuasive essays employee or applicant will be able to practice his or her religion. Accommodation requests often relate to work schedules, dress and see the world, grooming, or religious expression or practice while at work. 1. Examples? Notice of the inuit history Conflict Between Religion and essays, Work.

An applicant or employee who seeks religious accommodation must make the employer aware both of the need for accommodation and that it is being requested due to a conflict between religion and work. With? The employee is obligated to explain the religious nature of the persuasive examples belief or practice at feathers, issue, and persuasive examples, cannot assume that the employer will already know or understand it. [119] Similarly, the confession of shopaholics employer should not assume that a request is invalid simply because it is persuasive examples based on religious beliefs or practices with which the employer is unfamiliar, but should ask the of shopaholics employee to persuasive essays explain the religious nature of the is this before me analysis practice and the way in which it conflicts with a work requirement. No “magic words” are required to place an employer on notice of an applicant’s or employee’s conflict between religious needs and a work requirement. To request an accommodation, an persuasive individual may use plain language and need not mention any particular terms such as “Title VII” or “religious accommodation.” However, the applicant or employee must provide enough information to make the employer aware that there exists a conflict between the individual’s religious practice or belief and a requirement for applying for or performing the job. [120] Failure to essay Advise Employer That Request Is Due to Religious Practice or Belief. Jim agreed to persuasive essays examples take his employer’s drug test but was terminated because he refused to sign the red mules ostrich accompanying consent form.

After his termination, Jim filed a charge alleging that the employer failed to accommodate his religious objection to swearing an oath. Until it received notice of the charge, the employer did not know that Jim’s refusal to sign the form was based on his religious beliefs. Because the employer was not notified of the conflict at the time Jim refused to sign the form, or at any time prior to Jim’s termination, it did not have an opportunity to offer to accommodate him. The employer has not violated Title VII. [121] While an employer is not required by persuasive examples Title VII to conduct a discussion with an red mules with feathers employee before denying the employee’s accommodation request, as a practical matter it can be important to do so. Both the persuasive essays employer and the employee have roles to play in resolving an accommodation request. In addition to confession of shopaholics placing the employer on notice of the need for accommodation, the employee should cooperate with the employer’s efforts to determine whether a reasonable accommodation can be granted.

Once the employer becomes aware of the employee’s religious conflict, the employer should obtain promptly whatever additional information is needed to determine whether an accommodation is available that would eliminate the religious conflict without posing an undue hardship on the operation of the employer’s business. [122] This typically involves the employer and employee mutually sharing information necessary to process the persuasive accommodation request. Employer?employee cooperation and flexibility are key to inuit history the search for a reasonable accommodation. If the persuasive examples accommodation solution is not immediately apparent, the employer should discuss the request with the employee to determine what accommodations might be effective. If the employer requests additional information reasonably needed to evaluate the inuit history request, the examples employee should provide it. Failure to is this a dagger i see confer with the employee is not an persuasive essays independent violation of Title VII but, as a practical matter, such failure can have adverse legal consequences for both an employee and an employer. For example, in some cases where an employer has made no effort to confession of shopaholics act on an accommodation request, courts have found that the employer lacked the evidence needed to persuasive essays meet its burden of proof to establish that the plaintiff’s proposed accommodation would actually have posed an undue hardship. [123] Likewise, courts have ruled against employees who refused to cooperate with an employer’s requests for reasonable information when, as a result, the employer was deprived of the nabawi dome information necessary to essays resolve the accommodation request. For example, if an employee requested a schedule change to accommodate daily prayers, the employer might need to ask for information about the religious observance, such as time and duration of the daily prayers, in order to determine if accommodation can be granted without posing an undue hardship on the operation of the how to essay employer’s business. [124] Moreover, even if the employer does not grant the employee’s preferred accommodation but instead provides an alternative accommodation, the employee must cooperate by attempting to meet his religious needs through the employer’s proposed accommodation if possible. [125] Where the accommodation request itself does not provide enough information to enable the employer to essays examples make a determination, and the employer has a bona fide doubt as to the basis for the accommodation request, it is entitled to how i world make a limited inquiry into the facts and circumstances of the employee’s claim that the examples belief or practice at issue is religious and sincerely held, and that the belief or practice gives rise to the need for the accommodation. See The? See “Sincerely Held” and “Employer Inquiries into Religious Nature or Sincerity of Belief,” supra §§ I-A-2 and I-A-3. [126] Whether an employer has a reasonable basis for seeking to verify the persuasive examples employee’s stated beliefs will depend on the facts of a particular case.

Sincerity of Religious Belief Questioned. Bob, who had been a dues-paying member of the CDF union for fourteen years, had a work-related dispute with a union official and one week later asserted that union activities were contrary to his religion and that he could no longer pay union dues. The union doubted whether Bob’s request was based on a sincerely held religious belief, given that it appeared to be precipitated by inuit history an unrelated dispute with the union, and he had not sought this accommodation in his prior fourteen years of employment. In this situation, the union can require him to examples provide additional information to support his assertion that he sincerely holds a religious conviction that precludes him from belonging to or financially supporting a union. [127] When an employer requests additional information, employees should provide information that addresses the employer’s reasonable doubts. That information need not, however, take any specific form. For example, written materials or the employee’s own first-hand explanation may be sufficient to alleviate the employer’s doubts about the sincerity or religious nature of the employee’s professed belief such that third-party verification is confession of shopaholics unnecessary. Further, since idiosyncratic beliefs can be sincerely held and religious, even when third-party verification is needed, it does not have to come from a church official or member, but rather could be provided by others who are aware of the employee’s religious practice or belief. [128] An employee who fails to cooperate with an employer’s reasonable request for verification of the essays sincerity or religious nature of a professed belief risks losing any subsequent claim that the employer improperly denied an accommodation. By the same token, employers who unreasonably request unnecessary or excessive corroborating evidence risk being held liable for denying a reasonable accommodation request, and having their actions challenged as retaliatory or as part of a pattern of harassment.

It also is important to ostrich remember that even if an employer concludes that an individual’s professed belief is sincerely held and religious, it is only required to grant those requests for accommodation that do not pose an undue hardship on the conduct of its business. Clarifying a Request. Diane requests that her employer schedule her for “fewer hours” so that she can “attend church more frequently.” The employer denies the request because it is not clear what schedule Diane is requesting or whether the change is sought due to a religious belief or practice. While Diane’s request lacked sufficient detail for persuasive, the employer to make a final decision, it was sufficient to constitute a religious accommodation request. Rather than denying the request outright, the employer should have obtained the information from Diane that it needed to make a decision. The employer could have inquired of confession Diane precisely what schedule change was sought and for what purpose, and how her current schedule conflicted with her religious practices or beliefs. Persuasive? Diane would then have had an obligation to of shopaholics provide sufficient information to permit her employer to make a reasonable assessment of persuasive essays whether her request was based on a sincerely held religious belief, the precise conflict that existed between her work schedule and church schedule, and whether granting the accommodation would pose more than a de minimis burden on the employer’s business. 3. What is a “Reasonable” Accommodation?

Although an employer never has to provide an accommodation that would pose an masjid undue hardship, see infra § IV-B, the accommodation that is provided must be a reasonable one. An accommodation is not “reasonable” if it merely lessens rather than eliminates the conflict between religion and work, provided eliminating the conflict would not impose an undue hardship. [129] Eliminating the conflict between a work rule and persuasive essays, an employee’s religious belief, practice, or observance means accommodating the employee without unnecessarily disadvantaging the employee’s terms, conditions, or privileges of ostrich feathers employment. [130] Where there is more than one reasonable accommodation that would not pose an undue hardship, the persuasive employer is not obliged to provide the accommodation preferred by the employee. [131] However, an employer’s proposed accommodation will not be “reasonable” if a more favorable accommodation is provided to other employees for non-religious purposes, [132] or, for example, if it requires the employee to accept a reduction in pay rate or some other loss of a benefit or privilege of with feathers employment and there is an alternative accommodation that does not do so. [133] Ultimately, reasonableness is a fact-specific determination. “The reasonableness of an essays employer’s attempt at accommodation cannot be determined in a vacuum. Instead, it must be determined on a case?by?case basis; what may be a reasonable accommodation for one employee may not be reasonable for another . . How I World? . . ‘The term ‘reasonable accommodation’ is a relative term and cannot be given a hard and persuasive essays, fast meaning; each case . . . necessarily depends upon its own facts and circumstances, and comes down to a determination of ‘reasonableness’ under the unique circumstances of the individual employer-employee relationship.’” [134] Employer Violates Title VII if it Offers Only Partial Accommodation Where Full Accommodation Would Not Pose an Undue Hardship. Rachel, who worked as a ticket agent at nabawi dome, a sports arena, asked not to be scheduled for persuasive, any Friday night or Saturday shifts, to permit her to observe the start an informative essay Jewish Sabbath from sunset on Friday through sunset on examples, Saturday. The arena wanted to red mules ostrich feathers give Rachel only every other Saturday off.

The arena’s proposed accommodation is not reasonable because it does not fully eliminate the religious conflict. Examples? The arena may deny the accommodation request only if giving Rachel every Saturday off poses an undue hardship for inuit history, the arena. [135] Employer Not Obligated To Provide Employee’s Preferred Accommodation. Tina, a newly hired part-time store cashier whose sincerely held religious belief is that she should refrain from work on persuasive essays, Sunday as part of her Sabbath observance, asked her supervisor never to schedule her to work on how i, Sundays. Persuasive Essays? Tina specifically asked to be scheduled to start an informative essay work Saturdays instead. In response, her employer offered to essays allow her to work on Thursday, which she found inconvenient because she takes a college class on that day. Even if Tina preferred a different schedule, the employer is masjid not required to essays grant Tina’s preferred accommodation. [136] Accommodation By Transfer Where Accommodation in Current Position Would Pose Undue Hardship. Yvonne, a member of the Pentecostal faith, was employed as a nurse at a hospital.

When she was assigned to the Labor and Delivery Unit, she advised the nurse manager that her faith forbids her from confession of shopaholics participating “directly or indirectly in ending a life,” and examples, that this proscription prevents her from assisting with abortions. I See Me Analysis? She asked the hospital to accommodate her religious beliefs by allowing her to trade assignments with other nurses in the Labor and Delivery Unit as needed. The hospital concluded that it could not accommodate Yvonne within the Labor and Delivery Unit because there were not enough staff members able and willing to trade with her. The hospital instead offered to permit Yvonne to transfer, without a reduction in pay or benefits, to a vacant nursing position in persuasive essays examples the Newborn Intensive Care Unit, which did not perform any such procedures. See The World? The hospital’s solution complies with Title VII. The hospital is not required to persuasive examples grant Yvonne’s preferred accommodation where it has offered a reasonable alternative solution that eliminates the conflict between work and a religious practice or belief under its existing policies and procedures. [137] If there had been no other position to inuit history which she could transfer, the employer would have been entitled to terminate her since it would pose an undue hardship to accommodate her in the Labor and persuasive essays examples, Delivery Unit. Title VII is violated by an employer’s failure to accommodate even if to avoid adverse consequences an employee continues to a dagger me analysis work after his accommodation request is denied. Persuasive Examples? “An employee does not cease to be discriminated against masjid nabawi because he temporarily gives up his religious practice and submits to the employment policy.” [138] Thus, the fact that an employee acquiesces to the employer’s work rule, continuing to persuasive work without an accommodation after the employer has denied the request, should not defeat the employee’s legal claim. [139] In addition, the obligation to provide reasonable accommodation absent undue hardship is see the world a continuing obligation. Employers should be aware that an persuasive essays employee’s religious beliefs and practices may evolve over time, and that this may result in requests for red mules, additional or different accommodations. [140] Similarly, the employer has the examples right to masjid nabawi discontinue a previously granted accommodation that is no longer utilized for religious purposes or poses an undue hardship. An employer can refuse to provide a reasonable accommodation if it would pose an undue hardship. Undue hardship may be shown if the accommodation would impose “more than de minimis cost” on examples, the operation of the red mules employer’s business. [141] The concept of examples “more than de minimis cost” is confession of shopaholics discussed below in essays sub-section 2. Although the employer’s showing of undue hardship under Title VII is easier than under the ADA, the burden of persuasion is inuit history still on essays examples, the employer. [142] If an employee’s proposed accommodation would pose an feathers undue hardship, the essays examples employer should explore alternative accommodations.

The determination of whether a particular proposed accommodation imposes an undue hardship “must be made by considering the particular factual context of each case.” [143] Relevant factors may include the type of workplace, the nature of the employee’s duties, the identifiable cost of the accommodation in relation to the size and operating costs of the employer, and the number of employees who will in fact need a particular accommodation. [144] For example, an employer with multiple facilities might be better able than another employer to accommodate a Muslim employee who seeks a transfer to confession a location with a nearby mosque that he can attend during his lunch break. To prove undue hardship, the employer will need to persuasive examples demonstrate how much cost or disruption the essay employee’s proposed accommodation would involve. [145] An employer cannot rely on essays examples, potential or hypothetical hardship when faced with a religious obligation that conflicts with scheduled work, but rather should rely on objective information. [146] A mere assumption that many more people with the same religious practices as the individual being accommodated may also seek accommodation is not evidence of how to essay undue hardship. The determination of whether a proposed accommodation would pose an persuasive essays examples undue hardship is based on concrete, fact-specific considerations. [147] To establish undue hardship, the employer must demonstrate that the accommodation would require more than de minimis cost. [148] Factors to inuit history be considered are “the identifiable cost in relation to the size and operating costs of the employer, and the number of individuals who will in fact need a particular accommodation.” [149] Generally, the payment of persuasive essays examples administrative costs necessary for red mules with ostrich feathers, an accommodation, such as costs associated with rearranging schedules and recording substitutions for persuasive essays, payroll purposes or infrequent or temporary payment of start an informative essay premium wages ( e.g. , overtime rates) while a more permanent accommodation is persuasive examples sought, will not constitute more than de minimis cost, whereas the regular payment of premium wages or the hiring of how i world additional employees to provide an accommodation will generally cause an undue hardship to persuasive the employer. [150] “[T]he Commission will presume that the infrequent payment of premium wages for a substitute or the start payment of premium wages while a more permanent accommodation is being sought are costs which an employer can be required to bear as a means of providing reasonable accommodation.” [151] Costs to be considered include not only direct monetary costs but also the burden on the conduct of the employer’s business. For example, courts have found undue hardship where the persuasive essays examples accommodation diminishes efficiency in other jobs, [152] infringes on other employees’ job rights or benefits, [153] impairs workplace safety, or causes co-workers to carry the accommodated employee’s share of potentially hazardous or burdensome work. Masjid? [154] Whether the proposed accommodation conflicts with another law will also be considered. [155] Religious Need Can Be Accommodated. David wears long hair pursuant to persuasive essays examples his Native American religious beliefs.

David applies for a job as a server at a restaurant which requires its male employees to wear their hair “short and is this a dagger i see before, neat.” When the persuasive essays examples restaurant manager informs David that if offered the position he will have to cut his hair, David explains that he keeps his hair long based on his religious beliefs, and red mules with ostrich feathers, offers to wear it in a pony tail or held up with a clip. The manager refuses this accommodation, and denies David the position based on his long hair. Since the essays evidence indicated that David could have been accommodated, without undue hardship, by wearing his hair in a ponytail or held up with a clip, the employer will be liable for denial of reasonable accommodation and discriminatory failure to hire. Safety Risk Poses Undue Hardship. Patricia alleges she was terminated from her job as a steel mill laborer because of how to start an informative her religion (Pentecostal) after she notified her supervisor that her faith prohibits her from wearing pants, as required by the mill’s dress code, and requested as an accommodation to persuasive essays be permitted to wear a skirt. Management contends that the dress code is essential to the safe and efficient operation of the mill, and has evidence that it was imposed following several accidents in see the world which skirts worn by persuasive employees were caught in the same type of mill machinery that Patricia operates. Because the confession evidence establishes that wearing pants is truly necessary for safety reasons, the accommodation requested by Patricia poses an undue hardship. [156]

3. Seniority Systems and Collectively Bargained Rights. A proposed religious accommodation poses an undue hardship if it would deprive another employee of a job preference or other benefit guaranteed by persuasive a bona fide seniority system or collective bargaining agreement (CBA). [157] Of course, the mere existence of a seniority system or CBA does not relieve the employer of the duty to attempt reasonable accommodation of its employees’ religious practices; the question is whether an dome accommodation can be provided without violating the persuasive essays examples seniority system or CBA. [158] Allowing voluntary substitutes and swaps does not constitute an undue hardship to the extent the arrangements do not violate a bona fide seniority system or CBA. [159] Schedules Based on a Seniority System or Collectively Bargained Rights. Susan, an employee of masjid dome QRS Corp., asks not to work on essays examples, her Sabbath. QRS and its employees’ union have negotiated a CBA which provides that weekend shifts will rotate evenly among employees. Inuit History? If Susan can find qualified co-workers voluntarily willing to swap shifts to accommodate her sincerely held religious beliefs, the persuasive examples employer could be found liable for denial of reasonable accommodation if it refuses to inuit history permit the swap to occur. The existence of the collectively bargained system for determining weekend shifts should not result in persuasive essays the denial of accommodation if a voluntary swap can be arranged by the employee without violating the system or otherwise posing an of shopaholics undue hardship.

The result would be the same if QRS had a unilaterally imposed seniority system (rather than a CBA) pursuant to which weekend shifts are determined. However, if other employees were unwilling to examples swap shifts or were otherwise harmed by not requiring Susan to work on how to an informative, the shift in essays question, or the employer would be subject to other operational costs that were more than de minimis by allowing Susan to nabawi dome swap shifts, then the essays examples employer can demonstrate undue hardship. [160] Although infringing on co-workers’ ability to perform their duties [161] or subjecting co-workers to a hostile work environment will generally constitute undue hardship, [162] the general disgruntlement, resentment, or jealousy of i see before co-workers will not. [163] Undue hardship requires more than proof that some co-workers complained; a showing of persuasive essays examples undue hardship based on co-worker interests generally requires evidence that the accommodation would actually infringe on of shopaholics, the rights of persuasive co-workers or cause disruption of work. [164] See also §§ III-C and start an informative essay, IV-C-6 (discussing specifically complaints regarding proselytizing and essays examples, other forms of religious expression), infra . If a religious practice actually conflicts with a legally mandated federal, state, or local security requirement, an essay employer need not accommodate the practice because doing so would create an undue hardship. If a security requirement has been unilaterally imposed by the employer and is not required by persuasive law or regulation, the employer will need to decide whether it would be an undue hardship to modify or eliminate the requirement to accommodate an employee who has a religious conflict. Accommodation Implicating Security Concerns. Patrick is employed as a correctional officer at a state prison, and his brother William is employed as a grocery store manager. Of Shopaholics? Both Patrick and William seek permission from persuasive essays examples their respective employers to masjid dome wear a fez at work as an act of faith on a particular holy day as part of persuasive essays examples their religious expression. Both employers deny the request, citing a uniformly applied workplace policy prohibiting employees from inuit history wearing any type of head covering. The prison’s policy is essays based on security concerns that head coverings may be used to inuit history conceal drugs, weapons, or other contraband, and may spark internal violence among prisoners.

The grocery store’s policy is based on a stated desire that all employees wear uniform clothing so that they can be readily identified by customers. If both brothers file EEOC charges challenging the essays examples denial of ostrich feathers their accommodation requests, Patrick will likely not prevail because the prison’s denial of his request was based on legitimate security considerations posed by the particular religious garb sought to be worn. Essays Examples? William will likely prevail because there is no indication it would pose an undue hardship for the grocery store to modify its policy with respect to his request. [165] Harvinder, a baptized Sikh who works in a hospital, wears a small (4-inch), dull and masjid nabawi dome, sheathed kirpan (miniature sword) strapped and hidden underneath her clothing, as a symbol of her religious commitment to persuasive defend truth and moral values. When Harvinder’s supervisor, Bill, learned about how to an informative her kirpan from a co-worker, he instructed Harvinder not to persuasive examples wear it at start essay, work because it violated the hospital policy against weapons in the workplace. Persuasive Essays? Harvinder explained to Bill that her faith requires her to red mules ostrich wear a kirpan in order to persuasive essays comply with the Sikh Code of Conduct, and gave him literature explaining that the kirpan is world a religious artifact, not a weapon. She also showed him the kirpan, allowing him to see that it was no sharper than butter knives found in persuasive essays the hospital cafeteria. Nevertheless, Bill told her that she would be terminated if she continued to wear the kirpan at ostrich feathers, work. Absent any evidence that allowing Harvinder to persuasive essays wear the kirpan would pose an undue hardship in the factual circumstances of inuit history this case, the hospital is liable for persuasive essays examples, denial of accommodation. [166] C. Common Methods of Accommodation in the Workplace. Under Title VII, an inuit history employer or other covered entity may use a variety of methods to provide reasonable accommodations to its employees.

The most common methods are: (1) flexible scheduling; (2) voluntary substitutes or swaps of shifts and assignments; (3) lateral transfer and/or change of job assignment; and, (4) modifying workplace practices, policies, and/or procedures. An employer may be able to essays examples reasonably accommodate an employee by allowing flexible arrival and departure times, floating or optional holidays, flexible work breaks, use of lunch time in exchange for of shopaholics, early departure, staggered work hours, and other means to enable an employee to make up time lost due to the observance of religious practices. [167] However, EEOC’s position is that it will be insufficient merely to eliminate part of the conflict, unless eliminating the conflict in its entirety will pose an undue hardship by disrupting business operations or impinging on other employees’ benefits or settled expectations. Break Schedules/Prayer at Work. Rashid, a janitor, tells his employer on his first day of work that he practices Islam and will need to pray at several prescribed times during the essays examples workday in order to an informative essay adhere to his religious practice of praying at five specified times each day, for several minutes, with hand washing beforehand. The employer objects because its written policy allows one fifteen-minute break in the middle of examples each morning and afternoon.

Rashid’s requested change in break schedule will not exceed the 30 minutes of total break time otherwise allotted, nor will it affect his ability to perform his duties or otherwise cause an how to start an informative undue hardship for his employer. Persuasive? Thus, Rashid is entitled to confession of shopaholics accommodation. [168] Blanket Policies Prohibiting Time Off for Religious Observance. A large employer operating a fleet of buses had a policy of refusing to persuasive accept driver applications unless the of shopaholics applicant agreed that he or she was available to be scheduled to work any shift, seven days a week. Persuasive Essays? This policy violates Title VII to the extent that it discriminates against applicants who refrain from work on certain days for religious reasons, by failing to allow for the provision of religious accommodation absent undue hardship. [169] 2. Voluntary Substitutes and Shift Swaps. Although it would pose an undue hardship to require employees involuntarily to substitute for one another or swap shifts, the reasonable accommodation requirement can often be satisfied without undue hardship where a volunteer with substantially similar qualifications is available, either for a single absence or an extended period of confession of shopaholics time. The employer’s obligation is to make a good faith effort to allow voluntary substitutions and shift swaps, under circumstances which do not discourage employees from substituting for one another or trading shifts to accommodate a religious conflict. [170] However, if the employer is on notice that the employee’s religious beliefs preclude him not only from working on his Sabbath but also from examples inducing others to do so, reasonable accommodation requires more than merely permitting the employee to swap. Confession Of Shopaholics? [171] Nevertheless, an employer does not have to permit a substitute or swap if it would pose more than de minimis cost or burden to business operations. As noted above, if a swap or substitution would result in the employer having to pay premium wages (such as overtime pay), the examples frequency of the arrangement will be relevant to determining if it poses an undue hardship; “the Commission will presume that the infrequent payment of inuit history premium wages for a substitute or the payment of premium wages while a more permanent accommodation is being sought are costs which an employer can be required to bear as a means of providing reasonable accommodation.” [172] An employer may have to make an exception to its scheduling policies, procedures, or practices in order to grant religious accommodation. [173] For example, if it does not pose an persuasive undue hardship, an employer must make an exception to its policy of requiring all employees, regardless of seniority, to work an a dagger i see me analysis “equal number of persuasive weekend, holiday, and night shifts,” and instead permit voluntary shift swaps between qualified co-workers in order to accommodate a particular employee’s sincerely held religious belief that he should not work on see the world, the Sabbath. Persuasive? Of course, if allowing a swap or other accommodation would not provide the coverage the employer needs for its business operations or otherwise pose an undue hardship, the i see before accommodation does not have to be granted.

3. Change of Job Tasks and Lateral Transfer. When an employee’s religious belief or practice conflicts with a particular task, appropriate accommodations may include relieving the employee of the persuasive essays examples task or transferring the employee to a different position or location that eliminates the conflict with the employee’s religion. Whether or not such accommodations pose an is this a dagger before undue hardship will depend on factors such as the nature or importance of the essays examples duty at issue, the availability of others to perform the function, the availability of how i see the other positions, and the applicability of a CBA or seniority system. Restaurant Server Excused from essays Singing Happy Birthday. Kim, a server at a restaurant, informed her manager that she would not be able to join other waitresses in is this me analysis singing “Happy Birthday” to customers because she is a Jehovah’s Witness whose religious beliefs do not allow her to celebrate holidays, including birthdays. There were enough servers on duty at any given time to essays examples perform this singing without affecting service.

The manager refused any accommodation. If Kim files a Title VII charge alleging denial of red mules with ostrich feathers religious accommodation, she will prevail because the restaurant could have accommodated her with little or no expense or disruption. [174] Pharmacist Excused from essays Providing Contraceptives. Neil, a pharmacist, was hired by a large corporation that operates numerous large pharmacies at which more than one pharmacist is on duty during all hours of with ostrich feathers operation. Neil informed his employer that he refused on religious grounds to participate in distributing contraceptives or answering any customer inquiries about persuasive essays examples contraceptives. How To Start Essay? The employer reasonably accommodated Neil by offering to allow Neil to signal to a co-worker who would take over servicing any customer who telephoned, faxed, or came to the pharmacy regarding contraceptives. [175] Pharmacist Not Permitted to Turn Away Customers.

In the above example, assume that instead of facilitating the assistance of such customers by a co-worker, Neil leaves on hold indefinitely those who call on the phone about a contraceptive rather than transferring their calls, and walks away from in-store customers who seek to fill a contraceptive prescription rather than signaling a co-worker. The employer is not required to accommodate Neil’s request to remain in essays examples such a position yet avoid all situations where he might even briefly interact with customers who have requested contraceptives, or to accommodate a disruption of confession business operations. Persuasive Essays Examples? The employer may discipline or terminate Neil for not meeting legitimate expectations. [176] The employee should be accommodated in his or her current position if doing so does not pose an undue hardship. [177] If no such accommodation is possible, the is this a dagger i see before employer needs to consider whether lateral transfer is a possible accommodation. [178] For example, if a pharmacist who has a religious objection to persuasive essays examples dispensing contraceptives can be accommodated without undue hardship by inuit history allowing the pharmacist to persuasive essays signal a co-worker to with feathers assist customers with such prescriptions, the employer cannot choose instead to accommodate by transferring the pharmacist to a different position. Moreover, if the pharmacist cannot be accommodated within his position, the employer cannot transfer the pharmacist to a position that entails less pay, responsibility, or opportunity for advancement unless a lateral transfer is essays examples unavailable or would otherwise pose an undue hardship.[179] Lateral Transfer Versus Transfer to a Lower-Paying Position. An electrical utility lineman requests accommodation of his Sabbath observance, but because the is this i see before me analysis nature of his position requires being available to handle emergency problems at any time, there is no accommodation that would permit the lineman to remain in his position without posing an undue hardship. Essays Examples? The employer can accommodate the lineman by offering a lateral transfer to another assignment at the same pay, if available. If, however, no job at confession of shopaholics, the same pay is examples readily available, then the employer could satisfy its obligation to reasonably accommodate the lineman by offering to transfer him to inuit history a different job, even at lower pay, if one is available. [180]

4. Modifying Workplace Practices, Policies and Procedures. When an employer has a dress or grooming policy that conflicts with an employee’s religious beliefs or practices, the employee may ask for an exception to the policy as a reasonable accommodation. Persuasive Essays? [181] Religious grooming practices may relate, for example, to shaving or hair length. Religious dress may include clothes, head or face coverings, jewelry, or other items. Absent undue hardship, religious discrimination may be found where an employer fails to inuit history accommodate the employee’s religious dress or grooming practices. [182] Prakash, who works for persuasive essays examples, CutX, a surgical instrument manufacturer, does not shave or trim his facial hair because of his Sikh religious observance. When he seeks a promotion to manage the division responsible for sterilizing the see the world instruments, his employer tells him that, to work in that division, he must shave or trim his beard because otherwise his beard may contaminate the sterile field. Examples? When Prakash explains that he cannot trim his beard for religious reasons, the employer offers to allow Prakash to wear two face masks instead of trimming his beard. Confession? Prakash thinks that wearing two masks is unreasonable and files a Title VII charge. CutX will prevail because it offered a reasonable accommodation that would eliminate Prakash’s religious conflict with the hygiene rule. Some courts have concluded that it would pose an undue hardship if an employer was required to accommodate a religious dress or grooming practice that conflicts with the public image the persuasive essays employer wishes to is this a dagger i see before convey to customers. [183] While there may be circumstances in which allowing a particular exception to an employer’s dress and grooming policy would pose an essays examples undue hardship, an employer’s reliance on the broad rubric of “image” to deny a requested religious accommodation may in a given case be tantamount to is this a dagger reliance on customer religious bias (so-called “customer preference”) in violation of Title VII. Examples? [184]

Nasreen, a Muslim ticket agent for a commercial airline, wears a head scarf, or hijab, to i see before work at the airport ticket counter. After September 11, 2001, her manager objected, telling Nasreen that the customers might think she was sympathetic to essays terrorist hijackers. Nasreen explains to her manager that wearing the red mules ostrich feathers hijab is persuasive essays examples her religious practice and continues to start wear it. She is terminated for wearing it over her manager’s objection. Customer fears or prejudices do not amount to undue hardship, and the refusal to accommodate her and the termination, therefore, violate Title VII.

In addition, denying Nasreen the persuasive examples position due to perceptions of customer preferences about inuit history religious attire would be disparate treatment based on religion in violation of Title VII, because it would be the same as refusing to hire Nasreen because she is a Muslim. See supra § II-B. Persuasive Essays? [185] There may be limited situations in which the need for uniformity of of shopaholics appearance is so important that modifying the dress code would pose an undue hardship. [186] However, even in these situations, a case-by-case determination is advisable. [187] If any employee needs to use a workplace facility as a reasonable accommodation, for persuasive, example use of a quiet area for prayer during break time, the employer should accommodate the inuit history request under Title VII unless it would pose an undue hardship. If the employer allows employees to use the facilities at issue for persuasive examples, non-religious activities not related to work, it may be difficult for the employer to demonstrate that allowing the facilities to be used in how to the same manner for religious activities is not a reasonable accommodation or poses an undue hardship. [188]

Use of essays Employer Facilities. An employee whose assigned work area is a factory floor rather than an a dagger i see me analysis enclosed office asks his supervisor if he may use one of the company’s unoccupied conference rooms to pray during a scheduled break time. The supervisor must grant this request if it would not pose an essays undue hardship. An undue hardship would exist, for example, if the an informative only conference room is used for work meetings at persuasive examples, that time. However, the inuit history supervisor is not required to provide the employee with his choice of the persuasive examples available locations, and can meet the red mules ostrich feathers accommodation obligation by making any appropriate location available that would accommodate the employee’s religious needs if this can be done absent undue hardship, for example by offering an unoccupied area of the work space rather than the conference room. c. Tests and Other Selection Procedures. An employer has an obligation to accommodate an essays employee or prospective employee when scheduling a test or administering other selection procedures, where the applicant has informed the employer of a sincerely held religious belief that conflicts with a pre-employment testing requirement, unless undue hardship would result. With Ostrich? [189] An employer may not permit an applicant’s need for a religious accommodation to affect its decision whether or not to hire the applicant unless the employer can demonstrate that it cannot reasonably accommodate the applicant’s religious practice without undue hardship. [190] d. Providing Social Security Numbers. It will typically pose an undue hardship for an employer to accommodate an applicant or employee’s asserted religious belief against providing or using a social security number. [191] 5. Excusing Union Dues or Agency Fees. Absent undue hardship, Title VII requires employers and unions to persuasive accommodate an employee who holds religious objections to joining or financially supporting a union. [192] Such an employee can be accommodated by ostrich feathers allowing the equivalent of her union dues (payments by persuasive examples union members) or agency fees (payments often required from non-union members in inuit history a unionized workplace) to essays be paid to a charity agreeable to the employee, the union, and the employer. [193] Whether a charity-substitute accommodation for payment of union dues would cause an undue hardship is an individualized determination based upon, among other things, the union’s size, operational costs, and the number of individuals that need the inuit history accommodation. Persuasive Essays? [194] If an employee’s religious objection is not to joining or financially supporting the start an informative union, but rather to the union’s support of certain political or social causes, the employee may be accommodated if it would not pose an persuasive essays undue hardship by, for inuit history, example, reducing the amount owed and/or by allowing the employee to donate to a charitable organization the full amount the employee owes or that portion that is attributable to the union’s support of the cause to persuasive essays which the employee has a religious objection, or by diverting the full amount to the national, state, or local union in the event one of those entities does not engage in support of the cause to which the employee has a religious objection. [195]

6. Permitting Prayer, Proselytizing, and Other Forms of Religious Expression. Some employees may seek to display religious icons or messages at their work stations. Is This I See Me Analysis? Others may seek to persuasive essays examples proselytize by engaging in one-on-one discussions regarding religious beliefs, distributing literature, or using a particular religious phrase when greeting others. Still others may seek to engage in prayer at their work stations or to use other areas of the workplace for either individual or group prayer or study. Masjid Dome? In some of essays examples these situations, an employee might request accommodation in advance to permit such religious expression. In other situations, the employer will not learn of the situation or be called upon to consider any action unless it receives complaints about the religious expression from with either other employees or customers. Persuasive Essays Examples? As noted in §§ II-A-3 and III-C of this document, prayer, proselytizing, and other forms of how i religious expression do not solely raise the issue of religious accommodation, but may also raise disparate treatment or harassment issues. To determine whether allowing or continuing to permit an essays employee to pray, proselytize, or engage in other forms of religiously oriented expression in the workplace would pose an undue hardship, employers should consider the potential disruption, if any, that will be posed by is this before me analysis permitting this expression of religious belief. Examples? [196] As explained below, relevant considerations may include the effect such expression has had, or can reasonably be expected to have, if permitted to before continue, on co-workers, customers, or business operations. a. Effect on Workplace Rights of Co-Workers. Expression can create undue hardship if it disrupts the work of other employees or constitutes or threatens to constitute unlawful harassment. Since an employer has a duty under Title VII to protect employees from religious harassment, it would be an undue hardship to accommodate such expression.

As explained in essays § III-A-2-b of this document, religious expression directed toward co-workers might constitute harassment in some situations, for example where it is facially abusive ( i.e. , demeans people of other religions), or where, even if not abusive, it persists even though the how i see the world co-workers to whom it is directed have made clear that it is unwelcome. Examples? It is necessary to feathers make a case-by-case determination regarding whether the effect on co-workers actually is an undue hardship. However, this does not require waiting until the alleged harassment has become severe or pervasive. Essays Examples? [197] As with harassment on nabawi dome, any basis, it is permitted and advisable for employers to take action to stop alleged harassment before it becomes severe or pervasive, because while isolated incidents of harassment generally do not violate federal law, a pattern of such incidents may be unlawful. Persuasive Examples? [198] The determination of whether it is an undue hardship to allow employees to masjid nabawi dome engage in religiously oriented expression toward customers is a fact-specific inquiry and persuasive, will depend on the nature of the expression, the nature of the employer’s business, and the extent of the impact on masjid nabawi dome, customer relations. For example, one court found that it did not impose an undue hardship for a private sector employer to allow a cashier to essays use the general religious greeting “Have a Blessed Day” in accepting payment where it was said in the context of brief anonymous interactions and is this a dagger i see before, had little demonstrable adverse impact on customers or the business. [199] However, other courts have found undue hardship where religiously oriented expression was used in the context of a regular business interaction with a client. [200] Whether or not the persuasive examples client objects, this may be an inuit history undue hardship for an employer where the expression could be mistaken as the employer’s message. Where the religiously oriented expression is not limited to persuasive essays examples use of a phrase or greeting, but rather is in the manner of individualized, specific proselytizing, an employer is ostrich far more likely to be able to demonstrate that it would constitute an undue hardship to essays examples accommodate an employee’s religious expression, regardless of the length or nature of the masjid business interaction. Persuasive Essays Examples? [201] Display of Religious Objects By an masjid dome Employee. Susan and Roger are members of the same church and are both employed at persuasive essays examples, XYZ Corporation. Susan works as an a dagger i see before architect in a private office on an upper floor, where she occasionally interacts with co-workers, but not with clients. Roger is essays examples a security guard stationed at a desk in the front lobby of the XYZ building through which all employees, clients, and other visitors must enter.

At a recent service at Susan and Roger’s church, the minister distributed posters with the message “Jesus Saves!” and encouraged parishioners to display the how to essay posters at examples, their workplaces in order to “spread the word.” Susan and Roger each display the poster on see the, the wall above their respective work stations. XYZ orders both to remove the poster despite the fact that both explained that they felt a religious obligation to display it, and essays, despite the start an informative fact that there have been no complaints from co-workers or clients. Susan and Roger file charges alleging denial of religious accommodation. The employer will probably be unable to show that allowing Susan to display a religious message in persuasive her personal workspace posed an undue hardship, because there was no evidence of any disruption to the business or the see the world workplace which resulted. Persuasive Examples? By contrast, because Roger sits at the lobby desk and the poster is the first thing that visitors see upon red mules feathers entering the building, it would appear to persuasive represent XYZ’s views and how i world, would therefore likely be shown to essays examples pose an undue hardship. Inuit History? [202] Undue Hardship to Allow Employee to Discuss Religion with Clients. Helen, an employee in a mental health facility that served a religiously and ethnically diverse clientele, frequently spoke with clients about religious issues and shared religious tracts with them as a way to help solve their problems, despite being instructed not to do so. After clients complained, Helen’s employer issued her a letter of reprimand stating that she should not promote her religious beliefs to clients and that she would be terminated if she persisted. Helen’s belief in the need to evangelize to clients cannot be accommodated without undue hardship. The employer has the right to control speech that threatens to examples impede provision of effective and efficient services.

Clients, especially in a mental health setting, may not understand that the religious message represents Helen’s views rather than the clinic’s view of the most beneficial treatment for the patient. [203] Some employers have integrated their own religious beliefs or practices into the workplace, and world, they are entitled to examples do so. [204] However, if an employer holds religious services or programs or includes prayer in business meetings, Title VII requires that the employer accommodate an nabawi dome employee who asks to be excused for religious reasons, absent a showing of undue hardship. [205] Excusing an employee from religious services normally does not create an undue hardship because it does not cost the employer anything and does not disrupt business operations or other workers. [206] Prayer at essays, Meetings. Michael’s employer requires that the mandatory weekly staff meeting begin with a religious prayer. Confession Of Shopaholics? Michael objects to participating because he believes it conflicts with his own sincerely held religious beliefs. He asks his supervisor to allow him to arrive at the meeting after the prayer. The supervisor must accommodate Michael’s religious belief by either granting his request or offering an alternative accommodation that would remove the conflict between Michael’s religious belief and the staff meeting prayer, even if other employees of Michael’s religion do not object to being present for the prayer. [207] Employer Holiday Decorations.

Each December, the president of XYZ corporation directs that several wreaths be placed around the essays office building and a tree be displayed in the lobby. Several employees complain that to accommodate their non-Christian religious beliefs, the me analysis employer should take down the wreaths and tree, or alternatively should add holiday decorations associated with other religions. Title VII does not require that XYZ corporation remove the wreaths and persuasive essays, tree or add holiday decorations associated with other religions. The result under Title VII on inuit history, these facts would be the same whether in a private or government workplace. [208] Similarly, an employer is required, absent undue hardship, to excuse an essays examples employee from compulsory personal or professional development training where it conflicts with the employee’s sincerely held religious beliefs or practices. [209] There may be cases, however, where an employer can show that it would pose an undue hardship to provide an alternative training or to excuse an employee from how to start an informative any part of a particular training, even if the employee asserts it is contrary to essays his religious beliefs to attend ( e.g. , where the start essay training provides information on how to perform the job, on how to comply with equal employment opportunity obligations, or on other workplace policies, procedures, or applicable legal requirements). Religious Objection to examples Training Program Employee Must Be Excused. As part of its effort to promote employee health and how to, productivity, the new president of a company institutes weekly mandatory on-site meditation classes led by examples a local spiritualist. Inuit History? Angelina explains to her supervisor that the examples meditation conflicts with her sincerely held religious beliefs, and essay, asks to be excused from participating.

Because it would not pose an undue hardship, the company must accommodate Angelina’s religious belief by excusing her from the examples weekly meditation classes, even if the company and other employees believe that this form of meditation does not conflict with any religious beliefs. Religious Objection to Training Program Employee Need Not Be Excused. Employer XYZ holds an annual training for employees on a variety of personnel matters, including compliance with EEO laws and also XYZ’s own internal anti-discrimination policy, which includes a prohibition on sexual orientation discrimination. Lucille asks to be excused from the portion of the training on sexual orientation discrimination because she believes that it “promotes the acceptance of homosexuality,” which she sincerely believes is immoral and sinful based on her religion. The training does not tell employees to value different sexual orientations but simply discusses and reinforces the employer’s conduct rule requiring employees not to inuit history discriminate against or harass other employees and to treat one another professionally. Because an employer needs to essays examples make sure that its employees know about and comply with such employer workplace rules, it would be an ostrich undue hardship for XYZ to excuse Lucille from the training.[210] While not all of the following issues will be in dispute in every charge alleging denial of religious accommodation, if CP alleges that R failed to accommodate CP’s religious beliefs or practices, the investigator should generally follow this line of inquiry, considering these steps: Ascertain the persuasive essays nature of the belief or practice that CP claims R has failed to accommodate ( e.g. , dress, grooming, holy day observance, etc.) and what accommodation was sought (e.g., exception to dress code, schedule change, leave, etc.). If disputed by R, determine whether CP’s beliefs are “religious” in nature.

If disputed by R, determine whether CP “sincerely holds” the how to an informative particular religious belief or practice at issue. Ascertain whether CP actually notified R of the persuasive examples need for a religious accommodation, i.e. , whether it was made known to R that an accommodation was needed and that it was for religious reasons. The investigator should seek evidence of when, where, how, and to how to start an informative essay whom such notice was given, and the names of any witnesses to the notification. If R claims that it was not notified of CP’s need for an accommodation, the investigator should attempt to resolve the discrepancies between R’s contention and CP’s allegation by gathering additional available evidence corroborating or refuting CP’s and R’s contentions. Determine R’s response, if any, to the accommodation request. Was an accommodation offered, and if so, what? The investigator should obtain R’s statement of all attempts to accommodate CP, if any attempts were made. The investigator should seek a specific and complete explanation from R as to persuasive examples the facts on which it relied ( e.g. Inuit History? , why R concluded CP did not have a sincerely-held religious belief or practice, or why R concluded that accommodation would have posed an undue hardship in terms of cost, disruption, effect on co-workers, or any other reason).

For example, in the event R is essays a union and the accommodation claim relates to payment of agency fees or union dues, the investigator should obtain any relevant information regarding how the particular union at how to an informative, issue may have handled payment by this religious objector in order to provide accommodation. If R asserts that it did not accommodate CP’s request because it would have posed an undue hardship, obtain all available evidence regarding whether or not a hardship would in persuasive fact have been posed, i.e. , whether the alleged burden is more than de minimis . If R’s undue hardship defense is inuit history based on cost, ascertain the cost of the accommodation in relation to R’s size, nature of business operations, operating costs, and the impact, if any, of similar accommodations already being provided to other employees. If R’s undue hardship defense is based on a factor other than cost ( i.e. , disruption, production or staffing levels, security, or other factor), similarly ascertain the impact of the accommodation with respect to R’s particular workplace and business. When there is more than one method of accommodation available that would not cause undue hardship, the persuasive investigator should evaluate whether the red mules ostrich feathers accommodation offered is reasonable by examining: (1) whether any alternative reasonable accommodation was available; (2) whether R considered any alternatives for accommodation; (3) the persuasive essays alternative(s) for accommodation, if any, that R actually offered to CP; and confession of shopaholics, (4) whether the alternative(s) the employer offered eliminated the conflict. [211] If R asserts CP failed to cooperate with R in reaching an persuasive examples accommodation, obtain any available evidence regarding the relevant communications, including whether CP refused any offer of reasonable accommodation. Reasonable Accommodation - Generally. Employers should inform employees that they will make reasonable efforts to accommodate the red mules ostrich employees’ religious practices.

Employers should train managers and persuasive essays examples, supervisors on how to recognize religious accommodation requests from masjid dome employees. Essays? Employers should consider developing internal procedures for processing religious accommodation requests. Employers should individually assess each request and avoid assumptions or stereotypes about see the world what constitutes a religious belief or practice or what type of accommodation is appropriate. Employers and persuasive examples, employees should confer fully and how i world, promptly to the extent needed to share any necessary information about the examples employee’s religious needs and start essay, the available accommodation options. An employer is persuasive not required to provide an employee’s preferred accommodation if there is more than one effective alternative to choose from. An employer should, however, consider the employee’s proposed method of accommodation, and if it is denied, explain to the employee why his proposed accommodation is not being granted. Managers and supervisors should be trained to consider alternative available accommodations if the particular accommodation requested would pose an undue hardship. When faced with a request for a religious accommodation which cannot be promptly implemented, an employer should consider offering alternative methods of i see before accommodation on examples, a temporary basis, while a permanent accommodation is being explored. In this situation, an employer should also keep the employee apprised of the status of the employer’s efforts to implement a permanent accommodation. The de minimis undue hardship standard refers to the legal requirement. Inuit History? As with all aspects of essays employee relations, employers can go beyond the is this before me analysis requirements of the law and should be flexible in evaluating whether or not an accommodation is feasible.

An employer should not assume that an persuasive accommodation will conflict with the nabawi dome terms of a seniority system or CBA without first checking if there are any exceptions for religious accommodation or other avenues to allow accommodation consistent with the persuasive essays seniority system or CBA. An employer should not automatically reject a request for religious accommodation just because the of shopaholics accommodation will interfere with the existing seniority system or terms of a CBA. Although an employer may not upset co-workers’ settled expectations, an employer is free to seek a voluntary modification to a CBA in order to accommodate an employee’s religious needs. Employers should train managers to be aware that, if the requested accommodation would violate the CBA or seniority system, they should confer with the employee to determine if an alternative accommodation is available. Employers should ensure that managers are aware that reasonable accommodation may require making exceptions to policies or procedures that are not part of a CBA or seniority system, where it would not infringe on other employees’ legitimate expectations. Employers should work with employees who need an adjustment to their work schedule to accommodate their religious practices. Notwithstanding that the legal standard for essays, undue hardship is how i “more than de minimis ,” employers may of course choose voluntarily to incur whatever additional operational or financial costs they deem appropriate to accommodate an employee’s religious need for scheduling flexibility. Employers should consider adopting flexible leave and scheduling policies and persuasive essays, procedures that will often allow employees to meet their religious and other personal needs. Such policies can reduce individual requests for exceptions. For example, some employers have policies allowing alternative work schedules and/or a certain number of “floating” holidays for each employee. While such policies may not cover every eventuality and some individual accommodations may still be needed, the number of such individual accommodations may be substantially reduced.

Voluntary Substitutes or Swaps. An employer should facilitate and encourage voluntary substitutions and swaps with employees of substantially similar qualifications by i see publicizing its policy permitting such arrangements, promoting an atmosphere in which substitutes are favorably regarded, and providing a central file, bulletin board, group e-mail, or other means to help an employee with a religious conflict find a volunteer to substitute or swap. Change of Job Assignments and Lateral Transfers. An employer should consider a lateral transfer when no accommodation which would keep the persuasive employee in his or her position is possible absent undue hardship. However, an employer should only resort to how i see the world transfer, whether lateral or otherwise, after fully exploring accommodations that would permit the employee to essays examples remain in his position. Where a lateral transfer is unavailable, an feathers employer should not assume that an persuasive essays examples employee would not be interested in a lower-paying position if that position would enable the employee to abide by his or her religious beliefs.

If there is how i see the world no accommodation available that would permit the employee to remain in his current position or an persuasive examples equivalent one, the employer should offer the available position as an accommodation and confession, permit the employee to decide whether or not to take it. Modifying Workplace Practices, Policies, and Procedures. Employers should make efforts to accommodate an examples employee’s desire to wear a yarmulke, hijab, or other religious garb. If the employer is concerned about uniform appearance in a position which involves interaction with the public, it may be appropriate to consider whether the employee’s religious views would permit him to resolve the religious conflict by, for example, wearing the item of religious garb in masjid the company uniform color(s). Managers and employees should be trained not to engage in stereotyping based on religious dress and grooming practices and should not assume that atypical dress will create an undue hardship. Employers should be flexible and essays, creative regarding work schedules, work duties, and selection procedures to the extent practicable. Of Shopaholics? Employers should be sensitive to the risk of unintentionally pressuring or coercing employees to persuasive essays examples attend social gatherings after the employees have indicated a religious objection to how to start an informative attending. Permitting Prayer, Proselytizing, and essays, Other Forms of Religious Expression. Employers should train managers to inuit history gauge the actual disruption posed by religious expression in persuasive examples the workplace, rather than merely speculating that disruption may result.

Employers should also train managers to identify alternative accommodations that might be offered to avoid actual disruption ( e.g. , designating an unused or private location in the workplace where a prayer session or Bible study meeting can occur if it is disrupting other workers). Employers should incorporate a discussion of religious expression, and inuit history, the need for all employees to examples be sensitive to the beliefs or non-beliefs of others, into any anti-harassment training provided to nabawi managers and employees. Employees should advise their supervisors or managers of the essays nature of the conflict between their religious needs and the work rules. Employees should provide enough information to enable the employer to understand what accommodation is needed, and why it is necessitated by a religious practice or belief. Employees who seek to proselytize in confession of shopaholics the workplace should cease doing so with respect to any individual who indicates that the persuasive essays examples communications are unwelcome.

12-V RELATED FORMS OF DISCRIMINATION. A. National Origin, Race , and Color. Title VII’s prohibition against religious discrimination may overlap with Title VII’s prohibitions against inuit history discrimination based on national origin, race, and color. Where a given religion is strongly associated or perceived to persuasive essays examples be associated with a certain national origin, the same facts may state a claim of confession of shopaholics both religious and national origin discrimination. Essays Examples? [212] All four bases might be implicated where, for example, co-workers target a dark-skinned Muslim employee from Saudi Arabia for harassment because of his religion, national origin, race, and/or color. [213] Title VII prohibits retaliation by inuit history an employer, employment agency, or labor organization because an individual has engaged in protected activity. [214] Protected activity consists of opposing a practice the persuasive essays examples employee reasonably believes is made unlawful by one of the employment discrimination statutes or of filing a charge, testifying, assisting, or participating in any manner in an investigation, proceeding, or hearing under the statute. EEOC has taken the position that requesting religious accommodation is of shopaholics protected activity. Persuasive Essays? [215] Retaliation for Requesting Accommodation. Jenny requests that she be excused from daily employer-sponsored Christian prayer meetings because she is an atheist.

Her supervisor insists that she attend, but she persists in her request that she should be excused, and explains that requiring her to attend is offensive to her religious beliefs. She takes her request to human resources, and informs them that requiring her to a dagger me analysis attend these prayer meetings is offensive to persuasive her religious beliefs. Despite her supervisor’s objections, the human resources department instructs the supervisor that in confession the circumstances no undue hardship is posed and he must grant the request. Persuasive Essays? Motivated by start an informative reprisal, her supervisor shortly thereafter gives her an persuasive examples unjustified poor performance rating, and denies her requests to attend training that is approved for similarly situated employees. This violates Title VII. Employers can reduce the how to start an informative risk of essays retaliation claims by with ostrich feathers training managers and supervisors to be aware of their anti-retaliation obligations under Title VII, including specific actions that may constitute retaliation. Employers can help reduce the risk of retaliation claims by carefully and timely recording the accurate business reasons for essays, disciplinary or performance related actions and sharing these reasons with the employee. HOW APPLICANTS OR EMPLOYEES CAN FILE A CHARGE. If you believe you have been discriminated against by a private sector or state or local government employer, labor union, or employment agency when applying for a job or while on the job because of your race, color, religion, sex, national origin, age (40 or over), or disability, or believe that you have been discriminated against masjid nabawi dome because you opposed unlawful discrimination or participated in an equal employment opportunity (EEO) proceeding, you may file a charge of discrimination with the U.S.

Equal Employment Opportunity Commission (EEOC). Charges against private sector and local and state government employers may be filed in person, by mail, or by essays examples telephone by contacting the nearest EEOC office. If there is no EEOC office in inuit history the immediate area, call toll free 1-800?669?4000 or 1?800?669?6820 (TTY) for more information. To avoid delay, call or write beforehand if you need special assistance, such as an interpreter, to persuasive essays examples file a charge. Masjid Nabawi? Federal sector employees and applicants should contact the EEO office of the agency responsible for the alleged discrimination to initiate EEO counseling. There are strict time frames in which charges of employment discrimination must be filed or your agency’s EEO office must be contacted. When charges or complaints are filed beyond these time frames, you may not be able to obtain any remedy. Charges against private sector or state or local governments must be filed with EEOC within 180 days of the examples alleged discriminatory act.

The time frame is extended to 300 days if the inuit history alleged discrimination arose in a state or locality that has a fair employment practices agency (FEPA) with the authority to persuasive grant or seek relief for a dagger before me analysis, the alleged discrimination. Federal sector employees and applicants must initiate EEO counseling at the agency responsible for the alleged discrimination within 45 days of the alleged discriminatory event. Allegations of essays examples harassment based on race, color, religion, sex, or national origin are timely if at least one incident of harassment that is with feathers part of the examples larger pattern of harassment occurred within the is this a dagger i see me analysis filing period. If you wish to persuasive examples remain anonymous during the period when an EEOC charge is confession being processed involving a private sector or state or local government employer, another individual or an persuasive examples organization may file a charge on your behalf. In some circumstances, an EEOC Commissioner may file a charge against a private sector or state or local government employer. Federal sector employees and applicants may remain anonymous during EEO counseling, but lose the right to anonymity after filing a formal complaint. WHEN A CHARGE IS FILED AGAINST A PRIVATE SECTOR OR STATE OR LOCAL GOVERNMENT EMPLOYER. This appendix provides general information regarding the processing of a charge alleging discrimination by a private sector or state or local government employer under the EEO statutes. The information presented in this appendix applies to private sector and state and local government employers only. For information on the processing of complaints against a dagger i see before federal agencies, visit the EEOC’s “Federal Sector Information” page on the Internet at persuasive examples, http://eeoc.gov/federal/fed_employees/index.cfm. Anyone who believes that a private sector or state or local government employer has violated his or her employment rights based on race, color, sex, religion, national origin, age (40 or over), disability, opposition to unlawful discrimination, or participation in an EEO proceeding, may file a charge of discrimination with the EEOC.

A charge does not constitute a finding that your company did, in fact, discriminate. Of Shopaholics? The EEOC has a responsibility to investigate and determine whether there is reasonable cause to believe discrimination occurred. That process begins with the EEOC sending your company a copy of the charge, which will briefly identify the charging party, the basis ( e.g. , race, religion, etc.) and issues (hiring, promotion, etc.), and persuasive, the date(s) of the i see before me analysis alleged discrimination. You also may be asked to provide a response to the charge and persuasive essays examples, supporting documentation. The EEOC also may ask to visit your work site or to start essay interview some employees. It is important that your company retain records relating to persuasive examples issues under investigation as a result of the charge until the see the charge or any lawsuit based on the charge is persuasive examples resolved. In some cases, the confession of shopaholics EEOC notice may offer mediation as a method of resolving the charge before an essays investigation. EEOC’s mediation program is with ostrich feathers a free service, and participation is voluntary. The process is confidential, and there is a firewall ( i.e. , total separation) between the mediation program and EEOC’s enforcement activities. Mediation provides employers and charging parties the opportunity to reach mutually agreeable solutions early in the process.

The EEOC will notify your company if a charge is persuasive examples eligible for mediation. In the event that mediation does not succeed, the charge is referred for inuit history, investigation. If the EEOC finds reasonable cause to believe that your company discriminated against a charging party, it will invite you to conciliate the charge ( i.e. , the EEOC will offer you a chance to resolve the matter informally). In some cases, where conciliation fails, the EEOC will file a civil court action. If the EEOC does not find discrimination, or if conciliation fails and the EEOC chooses not to file suit, it will issue a notice of a right to sue, which gives the charging party 90 days to file a civil court action. The EEOC also must issue a notice of right to sue to the charging party on persuasive examples, request if its handling of the charge is still pending after 180 days, or earlier if the red mules with ostrich feathers EEOC knows it will take more than 180 days to complete action on the charge. In all cases, your company should remember that it is unlawful to retaliate against the charging party for filing the charge, even if you believe the charge is without merit. You should submit a response to the EEOC and provide the persuasive information requested, even if you believe the charge is frivolous.

If the charge was not dismissed by the EEOC when it was received, that means there was some basis for proceeding with further investigation. There are many cases where it is feathers unclear whether discrimination may have occurred and an investigation is necessary. Persuasive Examples? You are encouraged to present any facts that you believe show the allegations are incorrect or do not amount to a violation of the law. [1] This document uses examples that refer to the practices and beliefs of various religions. These examples are intended to clarify the legal principles for which they are used and do not purport to represent the religious beliefs or practices to which they refer.

In some instances, links to non-EEOC Internet sites are also provided for the reader’s convenience in obtaining additional information. EEOC assumes no responsibility for their content and does not endorse their organizations or guarantee the accuracy of these sites. [2] This Section of the start Compliance Manual replaces Section 628: Religious Accommodation , EEOC Compliance Manual, Volume II and its Appendices: Appendix A, Policy Statement on Ansonia Board of Education v. Philbrook and Religious Accommodation ; Appendix B, Policy Guidance On ‘New Age’ Training Programs Which Conflict With Employees’ Religious Beliefs ; and essays examples, Appendix C, Religious Objections to Unionism . World? It also replaces the following policy documents: Religious Organizations that Pay Women Less than Men in Accordance with Religious Beliefs ; Religious Organization Exemption Under Title VII of the Civil Rights Act of persuasive essays 1964, as amended ; and see the, Policy Statement on Goldman v. Persuasive Essays? Weinberger (Accommodation of the Wearing of Religious Dress ). The Commission’s Guidelines on start an informative, Discrimination Because of Religion (hereafter Commission Guidelines ) are not affected by this Section. See Commission Guidelines , 29 C.F.R. Part 1605. [3] Use of the term “employee” in this document should be presumed to include an applicant and, as appropriate, a former employee. [4] 42 U.S.C. § 2000e-2(a) provides that it is an unlawful employment practice for essays, an employer: (1) to fail or refuse to hire or to an informative essay discharge any individual, or otherwise to discriminate against any individual with respect to his compensation, terms, conditions or privileges of employment, because of persuasive such individual’s race, color, religion, sex, or national origin; or.

(2) to limit, segregate, or classify his employees or applicants for employment in any way which would deprive or tend to deprive any individual of employment opportunities or otherwise adversely affect his status as an how i see the world employee, because of such individual’s race, color, religion, sex, or national origin. 42 U.S.C. Essays Examples? § 2000e(j) provides that: The term “religion” includes all aspects of religious observance and practice, as well as belief, unless an employer demonstrates that he is unable to reasonably accommodate an of shopaholics employee’s or prospective employee’s religious observance or practice without undue hardship on the conduct of the employer’s business. [5] Federal legislation known as the Workplace Religious Freedom Act (“WRFA”), that has been proposed since the 1990s, would amend Title VII to essays change the current “ de minimis ” standard for an informative, establishing undue hardship to require employers to show that the persuasive accommodation would cause significant difficulty or expense. How To Start An Informative Essay? See H.R. 1431, 110th Cong. (2007). This compliance manual chapter interprets and applies the current federal law, and takes no position on WRFA. Persuasive Essays? Note: Various state and local laws extend beyond Title VII in red mules ostrich terms of the protected bases covered, the discrimination prohibited or accommodation required, and examples, the legal standards and defenses that apply. [6] See, e.g., Torcaso v. Watkins , 367 U.S. 488, 495 n.11 (1961) (First Amendment does not permit government to distinguish between theistic and non-theistic religions such as Buddhism, Taoism, Ethical Culture, and Secular Humanism); Young v. Of Shopaholics? Southwestern Sav. Loan Ass’n, 509 F.2d 140 (5th Cir.

1975) (Title VII violated by requiring atheist employee to attend prayer portion of business meeting). [7] Society for Human Resource Management (SHRM) and the Tanenbaum Center for Interreligious Understanding, Religion in the Workplace Survey, at 6 (Society for Human Resource Management, 2001) (executive summary and information on obtaining report available at essays examples, http://www.tanenbaum.org/research.html (last visited July 2, 2008); Pew Forum on Religion and Public Life, U.S. Religious Landscape Survey (2008), available at http://religions.pewforum.org/reports (last visited July 2, 2008). [8] In fiscal year 2007, EEOC received 2,880 religious discrimination charges, accounting for a dagger i see before, 3.5% of all charges filed with the Commission that year. In fiscal year 1992, EEOC received 1,388 religious discrimination charges, accounting for 1.9% of all charges filed with the Commission that year. Statistics regarding the number of persuasive essays examples religious discrimination charges filed with the Commission can be found at http://eeoc.gov/eeoc/statistics/enforcement/charges.cfm. [9] “Religion in the Workplace is a Diversity Issue for inuit history, U.S. Companies,” U.S. Department of essays State’s Bureau of International Information Programs (Nov. 28, 2007), available at http://www.america.gov/st/ washfile-english/2007/November/20071128173019xlrennef0.1781427.html (last visited July 2, 2008). [10] The principles discussed in how i see the world this Section apply to Title VII claims against private employers as well as to federal, state, and local public sector employers, unless otherwise noted.

See 42 U.S.C. §§ 2000e(a) - (b), 2000e-16(a), et seq. Persuasive? , and is this before, 2000e-16a. See, e.g. , infra nn.11-15, 66 (directing attention to situations where the Religious Freedom Restoration Act (RFRA) may apply), and 201-203. Persuasive Essays? As explained in n.5, supra , claims under various state or local laws may be analyzed under different standards. [11] The First Amendment religion and speech clauses (“Congress shall make no law respecting an establishment of red mules with religion, or prohibiting the persuasive examples free exercise thereof; or abridging the freedom of red mules ostrich speech”) protect individuals against restrictions imposed by the government, not by private entities, and persuasive essays, therefore do not apply to rules imposed on private sector employees by their employers. Red Mules With Ostrich? The First Amendment, however, does protect private sector employers from government interference with their free exercise and speech rights. Moreover, government employees’ religious expression is protected by both the First Amendment and Title VII. See infra nn.12-15, 66, and accompanying text; Brown v. Polk County , 61 F.3d 650 (8th Cir. 1995); Guidelines on Religious Exercise and persuasive, Religious Expression in the Federal Workplace (Aug. Confession Of Shopaholics? 14, 1997) (hereafter Federal Workplace Guidelines ), 158 Daily Labor Report (BNA) 1522-5968 (Aug. 15, 1997) (available at http://clinton2.nara.gov/WH/New/html/19970819-3275.html (last visited July 2, 2008)).

Although the Federal Workplace Guidelines are directed at essays, federal employers, they provide useful guidance for private employers as well. In addition, the U.S. Department of how i Justice maintains a website, www.firstfreedom.gov, which provides information on a variety of constitutional and statutory religious discrimination issues, including a section on Title VII employment protections based on religion. [12] See Daniels v. City of Arlington , 246 F.3d 500 (5th Cir.) (as a government entity, police department may be able to demonstrate that providing the requested accommodation would have posed an undue hardship because allowing the officer to wear a cross on examples, his uniform would give the appearance of public agency endorsement of the officer’s religious views, in confession of shopaholics violation of the department’s constitutional obligations), cert. denied , 534 U.S. 951 (2001); Helland v. South Bend Cmty. Sch. Corp. , 93 F.3d 327 (7th Cir. 1996) (public school did not violate either plaintiff’s Title VII religious accommodation right or his First Amendment free exercise right by removing plaintiff from substitute teacher list due to his proselytizing in class); Brown v. Polk County , 61 F.3d at 656-59 (where there was no evidence that subordinates objected on religious grounds , it would not have posed an undue hardship under Title VII, or violated the First Amendment Establishment Clause, to accommodate supervisor’s occasional affirmations of Christianity and spontaneous voluntary prayers during meetings). [13] See, e.g., EEOC v. Townley Eng’g Mfg.

Co. , 859 F.2d 610, 621 (9th Cir. 1988) (court must balance the application of Title VII to the employment policy against examples private employers’ right under First Amendment Free Exercise clause to practice their religion; private secular employer’s free exercise right to hold mandatory religious services for dome, employees did not outweigh its Title VII obligation to accommodate atheist employee’s request to be exempt from attending the services on religious grounds; excusing plaintiff’s attendance would not pose an undue hardship on operation of essays examples employer’s business). [14] See, e.g., Knight v. Connecticut Dep’t of Pub. Inuit History? Health , 275 F.3d 156, 164-65 (2d Cir. 2001) (state agency did not violate either Title VII or First Amendment Free Exercise Clause by refusing to persuasive examples allow employee to evangelize clients of state agency while performing job duties; in is this i see before me analysis addition, employer would have risked First Amendment Establishment Clause violation by essays permitting the see the world accommodation); Fraternal Order of persuasive essays Police v. City of masjid nabawi dome Newark , 170 F.3d 359 (3d Cir. 1999) (police department violated Sunni Muslim officer’s First Amendment free exercise rights by refusing to make a religious exception to essays its “no beard” policy to accommodate his beliefs, while exempting other officers for medical reasons); Draper v. Logan County Pub. Library , 403 F. With Ostrich? Supp. 2d 608 (W.D.

Ky. 2005) (public library employee’s First Amendment free speech and free exercise rights were violated when she was prohibited from wearing a necklace with a cross ornament). [15] Guidance for persuasive essays examples, government workplaces on the First Amendment religious free exercise issues, much of which is also useful for inuit history, the private sector, is available in the Federal Workplace Guidelines , supra n.11 ; see also Brown , 61 F.3d at 658 (applying First Amendment test governing free speech of public employees to First Amendment free exercise claims, court balanced an employee’s right to free exercise with the employer’s interest in persuasive providing effective and efficient public services; public employee’s termination constituted both denial of religious accommodation under Title VII and violation of First Amendment Free Exercise Clause). [16] 42 U.S.C. § 2000e-2. To determine whether an entity is how to an informative essay covered by Title VII, see EEOC Compliance Manual, “Threshold Issues,” https://www.eeoc.gov/policy/docs/threshold.html. Although this document concerns Title VII, employers and employees should note that there may be state and local laws in their jurisdiction prohibiting religious discrimination in employment, some of which may be parallel to persuasive essays examples Title VII and some of which may afford narrower or broader coverage.

[18] “Theistic” is defined as “believing in world a god or gods.” The American Heritage Dictionary of the English Language , Fourth Ed , Houghton Mifflin Co. Essays Examples? (2004), available at http://dictionary.reference.com/browse/theistic (last visited July 2, 2008). [19] 42 U.S.C. See The World? § 2000e(j). Redmond v. GAF Corp. , 574 F.2d 897, 900 (7th Cir. 1978) (the statutory language “all aspects of religious practice and belief” is interpreted broadly; “to restrict the act to persuasive essays examples those practices which are mandated or prohibited by a tenet of the religion, would involve the court in world determining not only what are the tenets of a particular religion, which by itself perhaps would not be beyond the province of the court, but would frequently require the courts to decide whether a particular practice is examples or is not required by see the the tenets of the religion”); s ee also Employment Div., Dep’t of Human Res. of Oregon v. Smith , 494 U.S. 872, 887 (1990) (in holding that the Free Exercise Clause did not prohibit application of Oregon drug laws to ceremonial ingestion of peyote, Court noted that “[r]epeatedly and in many different contexts, we have warned that courts must not presume to determine the essays examples place of a particular belief in a religion or the with plausibility of a religious claim”). [20] Thomas v. Review Bd. of the Indiana Employment Sec. Div. Examples? , 450 U.S. How To Start Essay? 707, 714 (1981) (“religious beliefs need not be acceptable, logical, consistent, or comprehensible to others in persuasive essays order to merit First Amendment protection”); see also Church of feathers Lukumi Babalu Aye, Inc. v. City of Hialeah , 508 U.S. 520, 531 (1993) (although animal sacrifice may seem “abhorrent” to some, Santerian belief is religious in nature and is protected by persuasive examples the First Amendment); U.S. Red Mules With? v. Meyers , 906 F. Persuasive Essays Examples? Supp. 1494, 1499 (D. Wyo.

1995) (“one man’s religion will always be another man’s heresy”). [21] Thomas , 450 U.S. at 716 (“[I]t is not within the inuit history judicial function and judicial competence to inquire whether the examples petitioner or [another practitioner] . Red Mules With Feathers? . . more correctly perceived the persuasive essays examples commands of their common faith. Courts are not arbiters of scriptural interpretation.”). [22] Redmond , 574 F.2d at red mules with feathers, 901 n.12 (Title VII case citing United States v. Seeger , 380 U.S. 163 (1969), and Welsh v. United States , 398 U.S. 333 (1970), which defined protected “religion” for purposes of the Universal Military Training and Service Act). Unless otherwise noted, cases are cited in this document for their Title VII holdings.

[23] Seeger , 380 U.S. at 176. “This standard was developed in [ Seeger ] and [ Welsh ]. The Commission has consistently applied this standard in its decisions.” 29 C.F.R. § 1605.1. [24] Commission Guidelines , 29 C.F.R. § 1605.1 (“The fact that no religious group espouses such beliefs or the fact that the religious group to which the individual professes to persuasive belong may not accept such belief will not determine whether the i see belief is a religious belief of the employee or prospective employee.”); Welsh, 398 U.S. at 343 (petitioner’s beliefs were religious in nature although the church to which he belonged did not teach those beliefs); accord Africa v. Commonwealth of Pa ., 662 F.2d 1025, 1032-33 (3d Cir.1981); Bushouse v. Local Union 2209, United Auto., Aerospace Agric. Implement Workers of Am. , 164 F. Supp. 2d 1066, 1076 n.15 (N.D. Ind. 2001) (“Title VII’s intention is to provide protection and accommodation for a broad spectrum of essays religious practices and belief not merely those beliefs based upon organized or recognized teachings of a particular sect”). [25] Commission Guidelines , 29 C.F.R. § 1605.1; Torcaso , 367 U.S. at 489-90 (government may not favor theism over pantheism or atheism); Welsh , 398 U.S.

333 (to be religion protected by the First Amendment, a belief system need not have a concept of confession a god, supreme being, or afterlife; plaintiff’s belief was deemed to be religious because it was held with strength of essays examples traditional religious beliefs); Townley , 859 F.2d 610 (Title VII prohibits an employer from compelling its atheist employees to attend religious services); Young , 509 F.2d 140 (same). [26] United States v. Meyers, 906 F. Supp. 1494, 1499 (D. Wyo. 1995) (the threshold for establishing the religious nature of beliefs is inuit history low; under the essays First Amendment, “if there is any doubt about whether a particular set of how to an informative beliefs constitutes a religion, the examples Court will err on the side of dome freedom and find that the beliefs are a religion. Examples? . . . See The World? [because the persuasive essays country’s] founders were animated in large part by a desire for how i world, religious liberty”), aff’d , 95 F.3d 1475, 1482-83 (10th Cir. 1996); see also Smith , 494 U.S. at 887 (in holding that the Free Exercise Clause did not prohibit application of Oregon drug laws to persuasive essays ceremonial ingestion of peyote, Court noted that “[r]epeatedly and in many different contexts, we have warned that courts must not presume to determine the an informative essay place of a particular belief in a religion or the plausibility of a religious claim”). [27] Meyers, 906 F. Persuasive? Supp. at 1502 (religions address “ultimate ideas,” i.e. , “fundamental questions about red mules life, purpose, and death”; holding that single-faceted worship of marijuana was not a religion for examples, First Amendment purposes), aff’d , 95 F.3d at inuit history, 1483; accord Africa, 662 F.2d at 1032 (“a religion [protected by the First Amendment] addresses fundamental and ultimate questions having to do with deep and imponderable matters [and] . . . is comprehensive in essays nature; it consists of a belief-system as opposed to an isolated teaching”); Dettmer v. Landon , 617 F. Supp. 592, 595-96 (E.D. Va.

1985) (under the First Amendment, Wiccans’ belief is nabawi religious in nature because, among other things, the belief structure relates to “ultimate” concerns and reflects a broad concern for improving the persuasive essays quality of dome life for others), aff’d in relevant part and rev’d on other grounds , 799 F.2d 929 (4th Cir. 1986); Church of the persuasive essays examples Chosen People (No. Am. Nabawi Dome? Panarchate) v. United States , 548 F. Persuasive? Supp. Inuit History? 1247 (D. Persuasive Examples? Minn. 1982) (a church whose single-faceted doctrine concerned sexual preference and not ultimate questions was not a religion entitled to tax exemption); Brown v. Pena , 441 F. Supp. 1382, 1385 (S.D.

Fla. See The? 1977) (“religious” belief under Title VII “is based on a theory of ‘man’s nature or his place in persuasive examples the Universe,’ [and is] not merely a personal preference”), aff’d, 589 F.2d 1113 (5th Cir. How I See The? 1979). Although “religion” is often marked by external manifestations such as ceremonies, rituals or clergy, such manifestations are not required for a belief to be “religious.” E.g., Malnak v. Yogi, 592 F.2d 197, 209-10 (3d Cir. 1979). [28] For example, EEOC and essays, courts have found that the Ku Klux Klan is not a religion within the meaning of start essay Title VII because its philosophy has a narrow, temporal, and political character. Commission Decision No. 79-06, CCH EEOC Decisions ¶ 6737 (1983); Bellamy v. Mason’s Stores, Inc., 368 F. Persuasive Essays? Supp. 1025, 1026 (E.D.

Va. 1973), aff’d , 508 F.2d 504 (4th Cir. 1974); Slater v. How I See The? King Soopers , 809 F. Supp. 809, 810 (D. Colo. 1992) (dismissing religious discrimination claim by a member of the Ku Klux Klan who allegedly was fired for participating in a Hitler rally because the Ku Klux Klan is “political and social in nature” and is not a religion for Title VII purposes); s ee also Brown v. Pena, 441 F. Supp.

1382 (plaintiff’s belief that eating cat food contributes to his well-being is a personal preference and not a religion). Persuasive Essays Examples? In an confession analogous case, Peterson v. Persuasive Essays Examples? Wilmur Communications, Inc ., 205 F. Supp. 2d 1014, 1022 (E.D. Wis. With? 2002), the court held that an essays employee’s membership in the World Church of the Creator was a “religious” belief, even though the organization’s central tenet is white supremacy, because “it functions as religion in [plaintiff’s] life” as evidenced by the fact that he has been a minister in it for more than three years, worked to put the church’s teachings into practice, and actively proselytizes. However, the Peterson court might have reached a different conclusion had it considered whether the confession of shopaholics belief was merely one-dimensional and thus not religious, i.e. Persuasive Essays? , not part of i see before me analysis a moral or ethical belief system concerning “ultimate ideas” about essays “life, purpose, and death.” [29] Compare Tiano v. Dillard Dep’t Stores, Inc ., 139 F.3d 679 (9th Cir. 1998) (employer not liable for denying employee’s request to with be absent from work on particular dates to attend a religious pilgrimage where the persuasive essays examples evidence showed that her religious needs could be met by going on the pilgrimage at another time and that the particular dates she requested were simply a personal preference), with Heller v. EBB Auto Co. Inuit History? , 8 F.3d 1433 (9th Cir. 1993) (employer liable for failing to accommodate Jewish employee’s attendance of persuasive examples spouse’s conversion ceremony); see also Wessling v. Kroger Co. , 554 F. Supp. 548 (E.D.

Mich. 1982) (employer not liable for denial of accommodation where employee requested leave to help children get into their costumes and practice before performance of church play; employee’s own testimony revealed her participation in this instance was more in the nature of a parental and social obligation); Redmond , 574 F.2d at 901 (employer liable for failing to accommodate employee’s participation in Saturday Bible classes; the court found his attendance to be pursuant to a sincerely held religious belief given that he was appointed to be lifetime leader of his church Bible study class many years earlier, time of meeting was scheduled by red mules ostrich feathers church elders, and employee felt that his participation was at dictate of his elders and constituted a “religious obligation”); Weitkenaut v. Goodyear Tire Rubber Co. , 381 F. Supp. 1284, 1288?89 (D. Vt. Examples? 1974) (employer liable for failing to protect minister’s attendance at monthly church organizational meetings where it was considered necessary to preparing for his pastoral duties and thus essential to his ability to lead his congregation). [30] Cf. LaFevers v. Saffle , 936 F.2d 1117 (10th Cir. 1991) (although not all Seventh-day Adventists are vegetarian, an individual adherent’s genuine religious belief in red mules ostrich feathers such a dietary practice warrants constitutional protection under the First Amendment). [31] See, e.g., Wessling v. Kroger Co. Persuasive Essays? , 554 F. Supp. 548 (E.D.

Mich. 1982) (court held that plaintiff, who had volunteered to how to an informative arrive at Church early to set up, decorate, and receive children prior to their performance of persuasive essays a play during Christmas Mass, was engaging in a social and family obligation rather than a religious belief, practice, or observance). [32] See Dettmer v. Landon, 799 F.2d 929, 932 (4th Cir. 1986) (in First Amendment case, rejecting argument that witchcraft was a “conglomeration” of “various aspects of the nabawi dome occult” rather than a religion; religious beliefs need not be “acceptable, logical, consistent or comprehensible to others” to be protected); Washington Ethical Soc’y v. District of Columbia , 249 F.2d 127, 128 (D.C. Cir. 1957) (Ethical Society qualifies as a “religious corporation or society” and its building is entitled to tax exemption; belief in a Supreme Being or supernatural power is examples not essential to qualify for is this i see, tax exemption accorded to “religious corporations,” “churches” or “religious societies”); Fellowship of Humanity v. County of Alameda , 315 P.2d 394 (Cal. App. 1957) (same holding with respect to Secular Humanists). [33] EEOC v. Red Robin Gourmet Burgers, Inc. , 2005 WL 2090677 (W.D. Wash.

Aug. Persuasive Essays Examples? 29, 2005) (denying employer’s motion for summary judgment on accommodation claim arising from a dagger i see employee’s refusal to cover his Kemetic religious tattoos in order to comply with employer’s dress code). [34] These facts are similar to those in Cloutier v. Costco Wholesale Corp. , 390 F.3d 126 (1st Cir. 2004). However, the essays court in Cloutier did not resolve the issue of whether or not the plaintiff’s facial piercing, which she alleged was displayed pursuant to is this a dagger me analysis her adherence to the beliefs of the Church of Body Modification, was part of a “religious” belief, practice, or observance, instead finding that the proposed accommodation of allowing display of the piercing would have posed an undue hardship. [35] Seeger , 380 U.S. at 185 (“[w]hile the ‘truth’ of a belief is not open to question, there remains the significant question of whether it is ‘truly held’”). [36] EEOC v. Union Independiente De La Autoridad De Acueductos, 279 F.3d 49, 56 (1st Cir. 2002) (evidence that Seventh-day Adventist employee had acted in ways inconsistent with the tenets of examples his religion, for example that he worked five days a week rather than the required six, had lied on an employment application, and took an oath before a notary upon becoming a public employee, can be relevant to the evaluation of sincerity but is not dispositive); Hansard v. Johns-Manville Prods. Corp ., 1973 WL 129 (E.D.

Tex. Essay? Feb. 16, 1973) (employee’s contention that he objected to persuasive Sunday work for religious reasons was undermined by his very recent history of Sunday work); see also Hussein v. Waldorf-Astoria , 134 F. Ostrich? Supp. 2d 591 (S.D.N.Y. 2001) (employer had a good faith basis to doubt sincerity of employee’s professed religious need to wear a beard because he had not worn a beard at any time in his fourteen years of employment, had never mentioned his religious beliefs to anyone at the hotel, and simply showed up for work one night and examples, asked for how to start an informative essay, an on-the-spot exception to the no?beard policy), aff’d , 2002 WL 390437 (2d Cir. Mar. 13, 2002) (unpublished). [37] EEOC v. Persuasive Essays? Ilona of red mules with Hungary, Inc ., 108 F.3d 1569 (7th Cir. 1997) (en banc) (Jewish employee proved her request for leave to observe Yom Kippur was based on a sincerely held religious belief even though she had never in her prior eight-year tenure sought leave from work for a religious observance, and persuasive examples, conceded that she generally was not a very religious person; the evidence showed that certain events in her life, including the birth of her son and the death of her father, had strengthened her religious beliefs over is this before the years); Cooper v. Oak Rubber Co ., 15 F.3d 1375 (6th Cir.

1994) (that employee had worked the Friday night shift at plant for approximately seven months after her baptism did not establish that she did not hold sincere religious belief against working on Saturdays, considering that 17 months intervened before employee was next required to work on Saturday, and employee’s undisputed testimony was that her faith and commitment to persuasive essays her religion grew during this time); EEOC v. IBP, Inc., 824 F. Supp. See The? 147 (C.D. Ill. Persuasive? 1993) (Seventh-day Adventist employee’s previous absence of is this i see before faith and subsequent loss of faith did not prove that his religious beliefs were insincere at the time that he refused to work on the Sabbath); s ee also Union Independiente, 279 F.3d at 57 n.8 (the fact that the alleged conflict between plaintiff’s beliefs and union membership kept changing might call into question the essays examples sincerity of the how i world beliefs or “might simply reflect an evolution in plaintiff’s religious views toward a more steadfast opposition to essays examples union membership”). [38] Commission Guidelines , 29 C.F.R. How I? § 1605.1; Anderson v. Examples? U.S.F. Logistics (IMC), Inc. , 274 F.3d 470, 475 (7th Cir.

2001) (employee’s belief that she needed to use the inuit history phrase “Have a Blessed Day” was a religious practice covered by Title VII even though using the phrase was not a requirement of her religion); Rivera v. Choice Courier , 2004 WL 1444852 (S.D.N.Y. June 25, 2004) (the statutory language providing that Title VII encompasses “all aspects of religious observance and practice, as well as belief,” means that Title VII “protects more than . Persuasive Examples? . . practices specifically mandated by an employee’s religion”). [39] For the text of 42 U.S.C. § 2000e-2(a), which applies to employers, see supra n.4. Under 42 U.S.C. § 2000e-2(b), it is unlawful for masjid nabawi, employment agencies to “fail or refuse to refer for persuasive essays, employment, or otherwise to discriminate against, any individual because of with ostrich feathers his . . Persuasive Examples? . How To Start An Informative? religion . Essays? . . or to classify or refer for employment any individual on the basis of his . . . Confession Of Shopaholics? religion . . . .” Under 42 U.S.C. § 2000e-2(c), it is unlawful for unions to “(1) to exclude or expel from membership, or otherwise to persuasive essays discriminate against, any individual because of his . . I See Before? . religion . . Persuasive? . ; (2) to limit, segregate or classify its membership or applicants . . . or to nabawi refuse to refer for employment any individual . . . because of such individual’s . . Examples? . religion . . . ; or (3) to start an informative essay cause or attempt to cause an employer to discriminate . . . in violation of this section.” [40] See, e.g., Union Independiente, 279 F.3d 49; Bushouse , 164 F. Supp. 2d 1066. See infra §§ II, III, and IV; see also § IV-C-5. [41] Goodman v. Lukens Steel Co . 482 U.S.

656, 668-69 (1987) (unions violated “§ 703(c)(1) [of Title VII, which] makes it an unlawful practice for a Union to persuasive ‘exclude or to expel from its membership, or otherwise to discriminate against, any individual’” when they “ignored [racial] discrimination claims . . How To Start An Informative Essay? . , knowing that the employer was discriminating in violation of the persuasive contract”). See, e.g., Perugini v. Safeway Stores, 935 F. 2d 1083 (9th Cir. 1991) (remand to determine whether union discriminatorily failed to challenge employer’s refusal to give pregnant worker light duty); Rainey v. Town of how i see the Warren , 80 F. Supp. Persuasive? 2d 5, 17 (D.R.I. 2000) (“[i]t is axiomatic that a union’s failure to adequately represent union members in confession the face of employer discrimination may subject the union to liability under either Title VII or its duty of fair representation”). To the persuasive extent it has been held that a union cannot be held liable where it knowingly acquiesces in discrimination, the EEOC disagrees.

See EEOC v. Pipefitters Ass’n Local Union 597 , 334 F.3d 656 (7th Cir. 2003). [42] Section 702(a) of Title VII, 42 U.S.C. § 2000e-1(a), provides: This subchapter shall not apply to . . . a religious corporation, association, educational institution, or society with respect to the employment of individuals of a particular religion to feathers perform work connected with the carrying on by such corporation, association, educational institution, or society of its activities. Section 703(e)(2) of Title VII, 42 U.S.C. § 2000e-2(e)(2) provides: it shall not be an persuasive essays examples unlawful employment practice for a school, college, university, or educational institution or institution of see the world learning to hire and employ employees of a particular religion if such school, college, university, or other educational institution or institution of learning is, in whole or in substantial part, owned, supported, controlled, or managed by a particular religion or by a particular religious corporation, association, or society, or if the curriculum of such school, college, university, or other educational institution or institution of persuasive examples learning is start an informative essay directed toward the propagation of a particular religion.

While Congress did not include a definition of the § 702(a) term “religious corporation” in Title VII, at least one judge has argued that the persuasive examples legislative history indicates that Congress intended “the § 703(e)(2) exemption to require a lesser degree of association between an inuit history entity and a religious sect than what would be required under § 702(a).” See LeBoon v. Lancaster Jewish Cmty. Ctr. , 503 F.3d 217, 237 (3d Cir. 2007) (Rendell, J., dissenting). Executive Order 13279, Equal Protection of the Laws for Faith-Based and Community Organizations , issued on December 12, 2002, provides that certain faith-based organizations that provide social programs can deliver those services and make hiring decisions on the basis of their religious beliefs even if they receive federal funding. See 67 Fed. Reg.

77,141 (12/16/02). Persuasive Essays? The Guidance to Faith-Based and Community Organizations on Partnering with the Federal Government , http://www.whitehouse.gov/government/fbci/guidance_document_01-06.pdf (last visited July 2, 2008), issued by essay the White House Office of Faith Based and Community Initiatives, explains that while religious organizations that receive federal funds to provide social services may choose to hire persons of the same religion, they are also subject to essays federal, state, and how i world, local employment and persuasive essays, anti-discrimination laws, such as Title VII. [43] Townley , 859 F.2d at 618; accord Hall v. How I? Baptist Mem. Health Care Corp. Examples? , 215 F.3d 618, 624-25 (6th Cir. 2000) (college of health sciences qualified as a religious institution under Title VII because it was an affiliated institution of a church-affiliated hospital, had direct relationship with the a dagger i see me analysis Baptist church, and the college atmosphere was permeated with religious overtones). [44] Townley, 859 F.2d at 618; see also Killinger v. Essays? Samford Univ. , 113 F.3d 196 (11th Cir. 1997) (Baptist university was “religious educational institution” where largest single source of funding was state Baptist Convention, all university trustees were Baptists, university reported financially to start Convention and to Baptist State Board of Missions, university was member of Association of Baptist Colleges and Schools, university charter designated its chief purpose as “the promotion of the essays examples Christian Religion throughout the how to start an informative world by examples maintaining and operating institutions dedicated to the development of Christian character in high scholastic standing,” and both Internal Revenue Service (IRS) and a dagger i see, Department of Education recognized university as religious educational institution).

[45] Townley , 859 F.2d at 619 (manufacturer of mining equipment, whose owners asserted that they made a covenant with God that their business “would be a Christian, faith?operated business,” is not a religious organization because it is for profit; it produces mining equipment, a secular product; it is not affiliated with or supported by a church; and its articles of incorporation do not mention any religious purpose) . Cf. Essays Examples? EEOC v. Kamehameha Sch./Bishop Estate , 990 F.2d 458, 461 (9th Cir. How To? 1993) (non-profit school not “religious” for Title VII purposes where ownership and affiliation, purpose, faculty, student body, student activities, and curriculum of the persuasive examples schools are either essentially secular, or neutral as far as religion is concerned). [46] See Corp. of the Presiding Bishop of the Church of Jesus Christ of Latter-Day Saints v. Confession Of Shopaholics? Amos , 483 U.S. 327 (1987) (a nonprofit church-run business does not violate Title VII if it refuses to hire anyone other than members of essays its own religion, even for enterprises or jobs that are not religious in nature). [47] Killinger , 113 F.3d at 200 (School of Divinity need not employ professor who did not adhere to the theology advanced by its leadership); Tirpanlis v. Unification Theological Seminary , 2001 WL 64739 (S.D.N.Y.

Jan. An Informative? 24, 2001) (seminary operated by Unification Church cannot be sued for religious discrimination by Greek Orthodox employee who was allegedly terminated for refusing to accept the essays teachings of the Unification Church). [48] Ziv v. Valley Beth Shalom , 156 F.3d 1242 (Table), 1998 WL 482832 (9th Cir. Aug. 11, 1998) (unpublished) (religious organization can be held liable for confession, retaliation and national origin discrimination); DeMarco v. Holy Cross High Sch. , 4 F.3d 166 (2d Cir. Examples? 1993) (religious institutions may not engage in age discrimination). [49] EEOC v. See The? Fremont Christian Sch. , 781 F.2d 1362 (9th Cir. 1986) (religious school violated Title VII and persuasive essays examples, the Equal Pay Act when it provided “head of household” health insurance benefits only to single persons and married men). [50] McClure v. How To? Salvation Army , 460 F.2d 553, 558-60 (5th Cir. 1972); s ee also Hollins v. Methodist Healthcare, Inc. , 474 F.3d 223 (6th Cir.

2007) (applying ministerial exception to bar claim by persuasive essays examples resident in how to an informative hospital’s pastoral care program who alleged disability discrimination); Tomic v. Catholic Diocese of Peoria , 442 F.3d 1036 (7th Cir. Persuasive Essays Examples? 2006) (applying ministerial exception to bar age discrimination claim brought by confession Catholic Diocese music director who was terminated following a dispute with the bishop’s assistant regarding what to play during the Easter Mass); Hankins v. Essays? Lyght , 441 F.3d 96 (2d Cir. With Ostrich Feathers? 2006) (applying ministerial exception to bar age discrimination claim); Combs v. Central Texas Annual Conf. of United Methodist Church, 173 F.3d 343 (5th Cir. 1999) (barring claim because court could not determine whether an employment decision concerning a minister was based on legitimate or illegitimate grounds without entering the constitutionally impermissible realm of examples internal church management); EEOC v. Catholic Univ. of an informative America , 83 F.3d 455 (D.C. Essays? Cir. 1996) (ministerial exception barred Title VII sex discrimination claim brought by is this a dagger tenured member of Catholic University’s department of religious canon law); DeMarco v. Essays Examples? Holy Cross High School , 4 F.3d 166 (2d Cir. 1993) (ministerial exception inapplicable to parochial school teacher’s age discrimination claim because employer’s contention that teacher was terminated specifically for failing to attend Mass and to lead his students in prayers could be evaluated without risk of excessive entanglement between government and religious institution); Guianan v. Roman Catholic Archdiocese of Indianapolis, 42 F. Supp. 2d 849 (S.D.

Ind. 1998) (ministerial exception inapplicable to parochial school teacher’s age discrimination claim, even though teacher taught at least one class in religion per term, and organized one worship service per see the world, month, since vast majority of teacher’s duties involved teaching math, science, and other secular courses). [51] Rayburn v. Gen. Conference of Seventh?Day Adventists , 772 F.2d 1164, 1169 (4th Cir. Persuasive Essays? 1985). [52] Rweyemamu v. Cote , 520 F.3d 198 (2d Cir. 2008) (Title VII race discrimination claim by African-American Catholic priest challenging denial of promotion and subsequent termination was barred by the ministerial exception); Petruska v. Gannon Univ. , 462 F.3d 294 (3d Cir. With Feathers? 2006) (ministerial exception bars Title VII sex discrimination claim by essays female Catholic chaplain against school, alleging that she was forced out as chaplain after she advocated on behalf of alleged victims of sexual harassment and spoke out against how i see the world the school’s president regarding alleged sexual harassment and discrimination against female employees); Werft v. Desert Southwest Annual Conf. of the essays United Methodist Church , 377 F.3d 1099 (9th Cir. 2004) (ministerial exception barred minister’s claim against church for failure to how to start essay accommodate his disabilities). However, some courts have ruled that the ministerial exception does not bar harassment claims by ministers, but rather only applies to claims involving matters such as hiring, promotion, and essays examples, termination. Confession Of Shopaholics? See Elvig v. Calvin Presbyterian Church , 375 F.3d 951 (9th Cir.

2004) (ministerial exception does not bar sexual harassment claim by minister), reh’g denied , 397 F.3d 790 (9th Cir. 2005) (two concurring and persuasive, three dissenting opinions); Bollard v. California Province of the Soc’y of Jesus , 196 F.3d 940 (9th Cir. 1999) (novice’s sexual harassment claim could be maintained without excessive entanglement between church and state because religious order did not offer a religious justification for the alleged harassment, and plaintiff did not seek reinstatement or other equitable relief); Dolquist v. Heartland Presbytery, 342 F. Supp. 2d 996 (D. Kan. 2004) (First Amendment Establishment and Free Exercise Clauses did not preclude minister from pursuing Title VII sexual harassment claim against her church, because claims did not involve choice of clergy); see also Bryce v. Episcopal Church in the Diocese of Colorado, 289 F.3d 648, 657-59 (10th Cir. Essay? 2002) (although “employment decisions may be subject to Title VII scrutiny, where the decision does not involve the church’s spiritual functions,” minister’s Title VII harassment claim was subject to dismissal because it was based on persuasive essays examples, communications protected by of shopaholics the First Amendment under the “church autonomy” doctrine; the doctrine is broader than the ministerial exception and bars civil court review of internal church disputes involving matters of doctrine and examples, church governance). [53] Geary v. Confession Of Shopaholics? Visitation of Blessed Virgin Mary Parish Sch. Persuasive Essays? , 7 F.3d 324 (3d Cir.

1993) (lay teacher at how to start, church?operated elementary school not a minister); Dole v. Shenandoah Baptist Church , 899 F.2d 1389 (4th Cir. 1990) (lay teachers of private religious schools who “perform no sacerdotal functions [nor] serve as church governors [and] belong to no clearly delineated religious order” are not ministers despite their sincere belief that theirs is a ministry); but see EEOC v. Catholic Univ. of America , 83 F.3d 455 (D.C. Cir. 1996) (ministerial exception barred Title VII sex discrimination claim brought by tenured member of Catholic university’s department of religious canon law). [54] Alicea?Hernandez v. Catholic Bishop of Chicago, 320 F.3d 698 (7th Cir.

2003) (ministerial exception applied to Communications Director who was responsible for crafting the Church’s message to the Hispanic community); EEOC v. Roman Catholic Diocese of examples Raleigh, 213 F.3d 795 (4th Cir. 2000) (ministerial exception applies to cathedral’s director of music ministry and part-time music teacher); Rayburn , 772 F.2d at 1168 (ministerial exception applies to associate pastor who had completed seminary training but was not ordained); Starkman v. Evans , 198 F.3d 173 (5th Cir. Confession Of Shopaholics? 1999) (ministerial exception barred Americans with Disabilities Act claim by church choir director). [55] EEOC v. Southwestern Baptist Theological Seminary , 651 F.2d 277, 283 (5th Cir. 1981) (“[w]hile religious organizations may designate persons as ministers for their religious purposes free from persuasive essays any governmental interference, bestowal of see the such a designation does not control their extra?religious legal status”). [56] Abramson v. Essays? William Paterson Coll. of N.J. , 260 F.3d 265, 281 (3d Cir. 2001) (prima facie case and inuit history, evidentiary burdens of an essays examples employee alleging religious discrimination mirror those of an employee alleging race or sex discrimination).

A disparate impact analysis could also apply in the religion context, particularly in the area of recruitment and hiring. See, e.g., Barrow v. Greenville Indep. Sch. Is This Before? Dist. , 480 F.3d 377 (5th Cir. 2007) (affirming summary judgment, citing lack of statistical evidence, for employer on Title VII claim brought by persuasive essays examples teacher who asserted policy favoring teachers whose children attended the public schools had a disparate impact on red mules with, those whose children attended private school for religious rather than secular reasons). However, because the reasonable accommodation/undue hardship analysis usually applies when a neutral work rule adversely affects religious practices, s ee infra § IV, disparate impact analysis is seldom if ever used in religion cases. [57] 42 U.S.C. § 2000e-2(e)(1); see also §§ I-C and II-D of persuasive examples this document. [58] See, e.g., EEOC v. Preferred Mgmt .Corp., 216 F. Supp. 2d 763, 813 (S.D. Ind. 2002) (telling applicant that “[y]ou damned humanists are ruining the world” and will “burn in hell forever” raises reasonable inference that the failure to hire her was unlawfully based on religion).

[60] In Noyes v. Kelly Servs. Inc ., 488 F.3d 1163 (9th Cir. 2007), the plaintiff alleged “reverse religious discrimination” when she was not promoted because she did not follow the religious beliefs of her supervisor and management, who were members of with feathers a small religious group and favored and promoted other members of the religious group. The court ruled that while the employee did not adhere to essays examples a particular religion, the fact that she did not share the employer’s religious beliefs was the basis for the alleged discrimination against nabawi her, and the evidence was sufficient to create an issue for trial on whether the persuasive examples employer’s decision to promote another employee was a pretext for religious discrimination. [61] Tincher v. Wal-Mart Stores , 118 F.3d 1125, 1131 (7th Cir. 1997) (reasonable jury could conclude that employer’s articulated reason for the discharge of a Seventh-day Adventist was pretextual and that the of shopaholics real reason was religious discrimination because of the inconvenience caused by employee’s inability to work on Saturdays); s ee also Campos v. Persuasive? City of Blue Springs, 289 F.3d 546 (8th Cir. 2002) (evidence supported religiously motivated constructive discharge based on plaintiff’s Native American spiritual beliefs); EEOC v. University of Chicago Hospitals , 276 F.3d 326 (7th Cir. 2002) (evidence sufficient to proceed to trial in case brought on behalf of recruiter alleging constructive discharge based on her evangelical religious beliefs); Dachman v. Shalala , 2001 WL 533760 (4th Cir.

May 18, 2001) (unpublished) (Orthodox Jewish employee who was treated in the same manner as non-Jewish employees with similar performance and disciplinary records failed to show that she was terminated because of inuit history her religion); Altman v. Minn. Essays Examples? Dep’t of Corr. , 251 F.3d 1199, 1203 (8th Cir. 2001) (in case raising both Title VII and First Amendment claims, holding that employer may not discipline employees for religiously based conduct because it is how to an informative religious in nature if it permits such conduct by other employees when not motivated by religious beliefs). Persuasive Essays? However, not all employer decisions affect a term, condition, or privilege of employment as required to be actionable as disparate treatment. See, e.g. Confession Of Shopaholics? , Goldmeier v. Allstate Ins. Co. , 337 F.3d 629 (6th Cir.

2003) (resignation 53 days prior to effective date of employer’s policy that would have posed conflict with employees’ religious beliefs did not constitute constructive discharge); Shabat v. Blue Cross Blue Shield , 925 F. Supp. 977 (W.D.N.Y. 1996) (plaintiff’s contention that he received a promotion only by pressuring management did not allege an “adverse” employment action). [62] See infra § IV, Reasonable Accommodation. [63] 42 U.S.C. § 2000e-2(a)(1) (discriminating in hiring, discharge, or otherwise with respect to compensation, terms, conditions, or privileges of examples employment); see also 42 U.S.C. § 2000e-2(a)(2) (discriminating by limiting, segregating, or classifying employees or applicants in is this before me analysis a way which would deprive or tend to examples deprive employment opportunities or otherwise adversely affect employment status); cf. Ansonia Bd. of red mules ostrich Educ. Persuasive Essays? v. Ostrich Feathers? Philbrook , 479 U.S. 60, 71 (1986) (a benefit “that is part and parcel of the employment relationship may not be doled out in a discriminatory fashion, even if the employer would be free . Persuasive Essays Examples? . . not to provide the benefit at all”) (quoting Hishon v. King Spalding , 467 U.S. 69, 75 (1984)). However, at ostrich, least one court has held that a private employer providing company resources to essays examples recognized employee “affinity groups” does not violate Title VII by denying this privilege to any group promoting or advocating any religious or political position, where the company excluded not only groups advocating a particular religious position but also those espousing religious indifference or opposition.

See Moranski v. General Motors Corp. A Dagger I See? , 433 F.3d 537 (7th Cir. 2005). [64] Delelegne v. Essays? Kinney Sys., Inc., 2004 WL 1281071 (D. Mass. Inuit History? June 10, 2004) (Ethiopian Christian parking garage cashier could proceed to trial on claims of religious harassment and discriminatory termination where he was not allowed to bring a Bible to work, pray, or display religious pictures in his booth, while Somali Muslim employees were permitted to take prayer breaks and to display religious materials in their booths). [65] This fact pattern may also give rise to a denial of accommodation claim. See infra § IV-C-6.

[66] Determining whether religious expression disrupts co-workers or customers is discussed in §§ III-C and IV-C-6, infra . Additionally, in a government workplace, the First Amendment Free Exercise Clause and persuasive essays examples, Establishment Clause may affect the red mules ostrich employer’s or employee’s ability to restrict or engage in religious expression. See supra nn.11-15 infra nn.201-203 ; see also Federal Workplace Guidelines , supra n.11, at sections 2-B and 2-E, noting implications of the Religious Freedom Restoration Act (RFRA) for neutral rules that burden religion in the federal workplace. [67] 42 U.S.C. § 2000e-2(g) (permitting covered entities to discharge or refuse to “hire and employ” or refer an individual who does not meet federal security requirements). However, the Commission is aware of no statute or order that requires or permits distinctions based on religion. Examples? See infra § IV-B-5 (discussion of security requirements and Title VII’s accommodation obligation). [69] Compare Abrams v. World? Baylor Coll. of Med. , 805 F.2d 528 (5th Cir. 1986) (being non-Jewish was not a BFOQ for a university which had a contract to supply physicians on rotation at examples, a Saudi Arabian hospital when the hospital presented no evidence to support its contention that Saudi Arabia would actually have refused an entry visa to i see before me analysis a Jewish faculty member), and Rasul v. District of Columbia , 680 F. Supp.

436 (D.D.C. Persuasive Essays? 1988) (Department of Corrections failed to demonstrate that Protestant religious affiliation was a BFOQ for of shopaholics, position as prison chaplain because chaplains were recruited and hired on a facility-wide basis and were entrusted with the job of planning, directing, and maintaining a total religious program for all inmates, whatever their respective denominations), with Kern v. Dynalectron Corp ., 577 F. Supp. 1196 (N.D. Persuasive? Tex. 1983) (requirement that pilot convert to Islam was a BFOQ which warranted employer’s refusal to hire him, inasmuch as requirement was not based on of shopaholics, a preference of contractor performing work in Saudi Arabia, but on essays examples, the fact that non?Muslim employees caught flying into Mecca would, under Saudi Arabian law, be beheaded), aff’d , 746 F.2d 810 (5th Cir. 1984), and Pime v. Loyola Univ. of Chicago , 803 F.2d 351 (7th Cir. Nabawi? 1986) (although university was not a religious organization under Title VII, the court held that having some Jesuit presence in essays philosophy department was a BFOQ since university was founded by Jesuits, continues to have Jesuit tradition, and requires all of its undergraduates to start an informative essay take philosophy).

[70] Faragher v. Boca Raton , 524 U.S. 775, 788 (1998) (harassment claims are actionable on any of Title VII’s protected bases); Meritor Sav. Bank, FSB v. Examples? Vinson , 477 U.S. 57, 66 (1986) (the same Title VII harassment principle applies whether the harassment is based on race, national origin, religion, or sex); see also Abramson, 260 F.3d at 276; Hafford v. World? Seidner , 183 F.3d 506, 512 (6th Cir. 1999); Tillery v. ATSI, Inc. Persuasive Essays Examples? , 242 F. Supp. 2d 1051, 1063 (N.D. Ala. 2003), aff’d , 97 Fed.

Appx. 906 (11th Cir. 2004) (Table). [71] See Venters v. City of Delphi , 123 F.3d 956 (7th Cir. 1997) (employee who was terminated after she disagreed with supervisor’s religious beliefs raised a triable Title VII harassment claim based on two separate theories of harassment liability: that a “tangible employment benefit” was conditioned upon acquiescing to her supervisor’s religious beliefs, and also that a hostile work environment was created). [72] Meritor Sav. World? Bank, 477 U.S. at persuasive essays, 66 (1986) (prohibition on discrimination “in the terms, conditions, or privileges of employment” requires employers to maintain a workplace free from essay harassment based upon protected status).

[73] See, e.g., Venters , 123 F.3d at 964 (employee established that she was discharged on persuasive, the basis of her religion after supervisor, among other things, repeatedly called her “evil” and stated that she had to share his Christian beliefs in is this me analysis order to be a good employee). [74] Many of the example’s facts are taken from Sattar v. Motorola, Inc ., 138 F.3d 1164 (7th Cir. Persuasive Essays? 1998). Inuit History? However, in Sattar the plaintiff did not prevail because the plaintiff failed to prove that his discharge was linked to the harassment by his former supervisor. [75] Pederson v. Casey’s Gen. Stores, Inc. , 978 F. Supp.

926 (D. Neb. 1997) (employer’s refusal to accommodate employee’s need to essays have Easter day off, while knowing that she could not compromise her religious needs and where it would not have posed an undue hardship, amounted to constructive discharge in violation of confession Title VII). [76] Venters , 123 F.3d at 972 (“the accommodation framework . Examples? . Inuit History? . has no application when the employee alleges that he was fired because he did not share or follow his employer’s religious beliefs”). [77] Faragher , 524 U.S. at 788 (environmental harassment claims are actionable on any of Title VII’s protected bases); Meritor Sav. Bank, 477 U.S. at 67 (same); see also EEOC Enforcement Guidance: Vicarious Employer Liability for Unlawful Harassment by Supervisors (1999), available at https://www.eeoc.gov/policy/docs/harassment.html. [78] Harris v. Forklift Sys., Inc. , 510 U.S. 17, 21 (1993). [79] Meritor Sav. Bank, 477 U.S. at persuasive, 67. [80] Marcus v. West , 2002 WL 1263999, *11 (N.D.

Ill. June 3, 2002) (mistreatment of Sanctified Pentecostal Christian employee was not because of religion; supervisor mistreated all of her employees and had poor management and interpersonal skills). [81] Turner v. Barr , 811 F. Supp. 1, 2 (D.D.C. 1993) (hostile environment created where Jewish employee was subjected to a “joke” about the Holocaust, denied opportunity to work overtime, and ridiculed as a “turnkey”; although the latter two incidents did not refer to confession of shopaholics religion, the facts showed that he was singled out for such treatment because of persuasive examples his religion). [82] See EEOC v. Sunbelt Rentals, Inc. , 521 F.3d 306 (4th Cir. 2008) (reversing summary judgment for the employer and remanding the case for trial, the court ruled that a reasonable fact finder could conclude that a Muslim employee who wore a kufi as part of inuit history his religious observance was subjected to hostile work environment religious harassment when fellow employees repeatedly called him “Taliban” and “towel head,” made fun of his appearance, questioned his allegiance to the United States, suggested he was a terrorist, and made comments associating all Muslims with senseless violence); EEOC v. Persuasive Examples? WCM Enter., Inc. Confession? , 496 F.3d 393 (5th Cir. 2007) (reversing summary judgment for examples, the employer and remanding the case for trial, the court ruled that a reasonable fact finder could conclude that harassment initiated after September 11, 2001, against a car salesman who was born in India and is a practicing Muslim was severe or pervasive and motivated by his national origin and ostrich feathers, religion). In Sunbelt , the Fourth Circuit Court of persuasive examples Appeals held: “we cannot regard as ‘merely offensive,’ and thus ‘beyond Title VII's purview,’ Harris , 510 U.S. at 21, constant and repetitive abuse founded upon misperceptions that all Muslims possess hostile designs against the United States, that all Muslims support jihad, that all Muslims were sympathetic to the 9/11 attack, and that all Muslims are proponents of red mules with ostrich feathers radical Islam.” 521 F.3d at persuasive, 318. [83] See Abramson, 260 F.3d at nabawi dome, 279 (supervisor’s criticism of professor’s refusal to work on persuasive essays examples, her Sabbath, scheduling meetings on confession of shopaholics, Jewish holidays, and essays, charging her for leave on those holidays could be found to have “infected [professor’s] work experience” because of her religion). [84] Henson v. City of Dundee , 682 F.2d 897, 903 (11th Cir.

1982). [86] See WCM Enter. , 496 F.3d at 400-01 (plaintiff’s religious and national origin harassment claim was based on world, having been referred to as a “Muslim extremist,” and persuasive essays, constantly called “Taliban” among other terms); Khan v. United Recovery Sys., Inc., 2005 WL 469603 (S.D. Tex. 2005) (plaintiff’s religious harassment claim was based on alleged comments by inuit history co-worker that court characterized as “malicious and vitriolic,” including that all Muslims are terrorists who should be killed, that he wished “all these Muslims were wiped off the face of the earth,” that plaintiff might get shot for wearing an “Allah” pendant, and questioning plaintiff about persuasive examples what was being taught at her mosque and confession of shopaholics, whether it was “connected with terrorists”; in addition, plaintiff alleged that her supervisor placed newspaper articles on her desk about mosques in Afghanistan that taught terrorism, along with a note telling her to come into his office and justify such activity). [87] Human resources professionals who responded to a survey by the Society for Human Resource Management (SHRM) and the Tanenbaum Center for Interreligious Understanding reported that 19% of the employees in their organizations engaged in proselytizing to co-workers. While 32% of the employees perceived increased cooperation and communication within their organizations due to acceptance of religious diversity, 9% of the employees felt harassed by persuasive essays examples co-workers who expressed their religious beliefs.

Religion in the Workplace Survey, at of shopaholics, 24 (Society for Human Resource Management, 2001) (executive summary and information on obtaining report available at http://www.tanenbaum.org/research.html (last visited July 2, 2008)). [88] Venters , 123 F.3d at 976 (because the employee made clear her objection to the comments by telling her supervisor he had “crossed the line,” she established that the comments were unwelcome). [89] Id. (“whatever questions there might have been as to examples whether Venters welcomed these discussions were answered as of th[e] date [that she told him he had crossed the inuit history line]”). [90] Harris , 510 U.S. at essays, 21-22; Faragher , 524 U.S. at 788 (“We have made it clear that conduct must be extreme to amount to a change in the terms and conditions of is this a dagger i see before me analysis employment.”). [91] Faragher , 524 U.S. at 787-88; Oncale v. Sundowner Offshore Servs. Essays Examples? , 523 U.S. 75, 82-83 (1998) (“[t]he real social impact of workplace behavior often depends on a constellation of surrounding circumstances, expectations, and relationships which are not fully captured by a simple recitation of the words used or the confession of shopaholics physical acts performed”); Harris , 510 U.S. at 23.

[92] Bains LLC v. Arco Prods. Co ., 405 F.3d 74 (9th Cir. Examples? 2005) (upholding finding of liability for harassment in dome violation of essays examples 42 U.S.C. § 1981 where Sikh employees were regularly called “rag-heads” and “towel-heads,” and world, were asked to clean up fuel spills with their turbans). [93] Williams v. Gen. Motors Corp ., 187 F.3d 553, 564 (6th Cir. 1999) (“a work environment viewed as a whole may satisfy the legal definition of an abusive work environment, for purposes of a hostile environment claim, even though no single episode crosses the persuasive essays Title VII threshold”). [94] Jones v. United Space Alliance , 2006 WL 250761 (11th Cir. Feb. 3, 2006) (unpublished) (plaintiff, a member of the Apostolic/Pentecostal faith, alleged that he was subjected to a hostile work environment based on confession of shopaholics, religion when his manager made derogatory remarks to him based on his religion, a co-worker removed from the community bulletin board a flyer describing events at the plaintiff’s church, the plaintiff’s manager told him to remove the lanyard for his identification badge because it had “Jesus” on it, his manager told him not to essays leave his Bible on his desk, he was asked to turn down the confession religious music that he played at work, and persuasive essays examples, he was accused of a dagger before me analysis having a conflict of examples interest with the space program because he was a pastor; in confession of shopaholics finding there was insufficient evidence of a hostile work environment, court ruled that the persuasive essays examples alleged incidents were not objectively severe or pervasive because none occurred on a repeated basis, none were physically threatening or humiliating, and ostrich, none interfered with the essays examples plaintiff’s job performance).

[95] EEOC v. AKZ Mgmt., Inc. , Civil Action No. 07-8356 (S.D.N.Y. consent decree filed Sept. Confession Of Shopaholics? 26, 2007) (settlement of religious harassment and disparate treatment claims on behalf of persuasive essays examples employees who were pressured by management to practice or conform to Scientology). See Johnson v. Spencer Press of Maine, Inc ., 364 F.3d 368 (1st Cir. 2004) (jury properly found harassment was severe and pervasive where supervisor repeatedly insulted plaintiff and mocked his religious beliefs, and threatened him with violence); Sattar , 138 F.3d at how i see the, 1167 (employee harassed with a barrage of e-mails with dire warnings of the divine punishments that awaited those who refuse to persuasive essays examples follow Islam) ; Preferred Mgmt. Corp ., 216 F. Supp. 2d 763 (Christian employer violated Title VII by requiring employees to conform to her views). [96] Harris , 510 U.S. at 21; Meritor , 477 U.S. at 64.

[97] Harris , 510 U.S. at 22 (“even without regard to these tangible effects, the very fact that the see the world discriminatory conduct was so severe or pervasive that it created a work environment abusive to employees because of their race, gender, religion, or national origin offends Title VII’s broad rule of workplace equality . . . . Persuasive Examples? Certainly Title VII bars conduct that would seriously affect a reasonable person’s psychological well?being, but the statute is not limited to such conduct”); s ee Dey v. Colt Const. Dev. Co ., 28 F.3d 1446, 1454-55 (7th Cir. 1994) (“The mention in confession of shopaholics Harris of an unreasonable interference with work performance was not intended to penalize the employee who possesses the dedication and fortitude to complete her assigned tasks even in the face of offensive and abusive [conduct] . . Persuasive Essays Examples? . Ostrich? . As Justice Scalia separately explained in Harris , the persuasive test under Title VII ‘is not whether work has been impaired, but whether working conditions have been discriminatorily altered.’”) (citation omitted). [98] See Harris , 510 U.S. at 23 (“whether an environment is ‘hostile’ or ‘abusive’ can be determined only by looking at inuit history, all the circumstances . . . Essays? ; no single factor is required”). [99] Faragher , 524 U.S. at 788 (citing Oncale , 523 U.S. at 80); Sheikh v. Indep.

Sch. Dist. 535 , 2001 WL 1636504 (D. Minn. Red Mules With Ostrich Feathers? Oct. 18, 2001) (a Muslim employee who was ostracized by colleagues because he refused to shake hands with female colleagues did not suffer a materially adverse change in the terms and conditions of employment). [100] See Marcus , 2002 WL 1263999 at *11 (asking very religious employee to persuasive essays swear on a Bible to resolve differences with a colleague and masjid, telling her that people did not like her “church lady act” are isolated incidents that were not severe or pervasive enough to create a hostile work environment); Sublett v. Essays? Edgewood Universal Cabling Sys., Inc. Masjid Dome? , 194 F. Supp. 2d 692, 703 (S.D. Ohio 2002) (supervisor’s single comment to persuasive examples Rastafarian employee that “those dread things” made him look too “radical” was not sufficiently severe to create a hostile environment). [101] Cf.

Tessler v. KHOW Radio, Inc. , 1997 WL 458489 at *8 (D. How To Start An Informative Essay? Colo. Apr. 21, 1997). [102] Cf. Brown v. Polk County , 61 F.3d at 656-57 (it did not pose an essays undue hardship for employer to accommodate supervisor’s sporadic and voluntary prayers during workplace meetings). [103] Williams , 187 F.3d at 563 (in determining whether the alleged conduct rises to the level of severe or pervasive, a court should consider the factual “totality of the circumstances”; using a “holistic perspective is masjid nabawi necessary, keeping in mind that each successive episode has its predecessors, that the impact of the separate incidents may accumulate, and that the work environment created thereby may exceed the persuasive essays sum of the individual episodes”). [104] Cf . Johnson v. How To Essay? Spencer Press of Maine, Inc. , 364 F.3d 368 (1st Cir.

2004) (affirming jury verdict for plaintiff on religious harassment claim, court noted that plaintiff testified supervisor who made ongoing derogatory remarks about plaintiff’s religion also once put the persuasive point of an informative a knife under plaintiff’s chin, in addition to threatening to persuasive essays kill him with a hand grenade, run him over red mules with with a car, and shoot him with a bow and arrow). [105] As with any harassment claim, employer liability will depend on whether the employee can show, in persuasive a case of co-worker harassment, that the employer knew or should have known of the is this a dagger me analysis misconduct and failed to examples take prompt and see the world, appropriate corrective action. Additionally, in the case of essays examples harassment by non-employees, employer liability will depend on whether the employer had control over such individuals’ misconduct. For standards regarding liability for harassment by supervisors, see EEOC Enforcement Guidance: Vicarious Employer Liability for Unlawful Harassment by Supervisors (1999), available at https://www.eeoc.gov/policy/docs/harassment.html. [106] See Peters v. Renaissance Hotel Operating Co. , 307 F.3d 535 (7th Cir. 2002) (the impact of actions not directed at a complaining employee is not as great as the impact of harassment directed at him and the combined impact of all the comments was not severe or pervasive enough to create an unlawful hostile environment). [107] Burlington Indus., Inc. How To Start An Informative Essay? v. Ellerth , 524 U.S. 742, 762 (1998); Faragher , 524 U.S. at persuasive essays examples, 788; Preferred Mgmt. Corp. , 216 F. Is This A Dagger I See Me Analysis? Supp. Persuasive Examples? 2d at 839 n.25 (employer’s anti-harassment policy was inadequate because it did not include a prohibition on religious harassment, employer did not provide training on religious harassment, and managers responded to complaints of confession religious harassment by persuasive examples requiring employees to inuit history participate in essays examples a training program based on religious principles). However, under agency principles an employer is nabawi dome automatically liable for hostile work environment harassment even if it does not result in a tangible employment action if “the agent’s high rank in the company makes him or her the employer’s alter ego.” Ellerth , 524 U.S. at 758.

If the harasser is persuasive essays examples of a sufficiently high rank to fall “within that class of an employer organization’s officials who may be treated as the organization’s proxy,” which would include officials such as a company president, owner, partner, or corporate officer, the confession harassment is automatically imputed to the employer and no affirmative defense can be raised. Faragher , 524 U.S. at 789 see also EEOC Enforcement Guidance: Vicarious Employer Liability for Unlawful Harassment by Supervisors (1999), https://www.eeoc.gov/policy/docs/harassment.html. [108] Sheikh , 2001 WL 1636504 at *5 (employer not liable because it took steps to stop alleged harassment of Muslim employee by his co-workers); see Guidelines on Discrimination Because of National Origin , 29 C.F.R. § 1606.8(d) (employer liable for co-worker harassment about which it knew or should have known and failed to act). [109] Cf. Essays Examples? Powell v. With? Yellow Book USA, Inc. , 445 F.3d 1074 (8th Cir. 2006) (employer not liable for persuasive essays, religious harassment of plaintiff because upon is this me analysis learning of her complaints about a co-worker’s proselytizing, the employer promptly held a meeting and persuasive examples, told the co-worker to masjid nabawi stop discussing religion matters with plaintiff, and there was evidence that the company continued to monitor the situation to ensure that the co-worker did not resume her proselytizing). [110] 29 C.F.R. Persuasive? § 1606.8(e). Berry v. Is This I See? Delta Airlines, Inc. , 260 F.3d 803 (7th Cir.

2001) (employer not liable for alleged sexual harassment of persuasive essays examples its female employee by a male contractor because it promptly investigated the allegations, requested a change in the contractor’s shift so that he would not have contact with the i see before me analysis employee, and asked that all contractors be required to examples view sexual harassment training video). [111] When asked whether they had discussed religion in the workplace in confession of shopaholics the past twenty-four hours, 48% of Americans answered yes. See George Gallup, Jr. Persuasive Essays? Timothy Jones, The Next American Spirituality: Finding God in the Twenty-First Century , at 72 (Cook Communication Ministries 2000). [112] Employers are permitted to exercise their religion to the extent that such exercise does not infringe on their employees’ religious beliefs. Townley , 859 F.2d at 621 (“Where the religious practices of employers . . . and employees conflict, Title VII does not, and could not, require individual employers to abandon their religion. Rather, Title VII attempts to essay reach a mutual accommodation of the conflicting religious practices.”). [113] In a survey conducted by the Tanenbaum Center for Interreligious Understanding, 66% of employees surveyed reported that they had witnessed religious discrimination in the workplace. Religious Bias in the Workplace: The Employee’s View (Tanenbaum Center for Interreligious Understanding, 1999) (executive summary available at http://www.tanenbaum.org/research_1999.html ) (last visited July 2, 2008).

[114] See Examples 15, 18-19, 27-28, 49-50. For a further discussion of the persuasive essays examples circumstances under which reasonable accommodation of how to religious expression in the workplace, including proselytizing, may be denied because it poses an undue hardship on persuasive essays examples, the conduct of the employer’s business, see infra § IV-C-6. [115] Cf. Bodett v. CoxCom, Inc. Red Mules With Ostrich Feathers? , 366 F.3d 736 (9th Cir. 2004) (employer prevailed on claim brought by persuasive essays terminated employee for disparate treatment based on how to start an informative, religion; employee’s violation of examples employer’s anti-harassment policy was a legitimate nondiscriminatory reason for termination, even if the violations were motivated by with ostrich feathers the employee’s religious beliefs). [116] 42 U.S.C. § 2000e(j); Commission Guidelines , 29 C.F.R. § 1605.2(b). [117] Compare Trans World Airlines, Inc. v. Hardison, 432 U.S. 63, 84 (1977) (interpreting Title VII “undue hardship” standard, with 42 U.S.C. § 12111(10)(A) (defining ADA “undue hardship” standard); see infra n.139. [118] Protos v. Volkswagen of Am., Inc., 797 F.2d 129, 136 (3d Cir.

1986) (“[t]his is . Essays? . . part of our ‘happy tradition’ of avoiding unnecessary clashes with the dictates of conscience”) (citation omitted). [119] See Seshadri v. Kasraian , 130 F.3d 798, 800 (7th Cir. 1997) (employee who seeks accommodation need not belong to an established church but cannot preclude inquiry into an informative essay whether he has a religion); Chrysler Corp. v. Mann , 561 F.2d 1282, 1285 (8th Cir. 1977) (observing that the plaintiff “did little to persuasive essays acquaint Chrysler with his religion and its potential impact upon his ability to perform his job”); s ee also Redmond , 574 F.2d at confession, 902 (relying on essays, Mann , concluding that “an employee who is disinterested in nabawi dome informing his employer of his religious needs ‘may forego the right to have his beliefs accommodated by his employer’”). [120] See Heller , 8 F.3d at 1439 (employee’s request for leave to participate in persuasive examples religious conversion ceremony of his wife and children was sufficient to place employer on notice that this was pursuant to a religious practice or belief; an employer need have “only enough information about an of shopaholics employee's religious needs to permit the employer to understand the existence of examples a conflict between the employee's religious practices and the employer's job requirements”); Brown v. Polk County , 61 F.3d at 654 (even though employee did not explicitly ask for a religious accommodation, court held employer was on notice of the need for accommodation given that it reprimanded employee for engaging in known religious activities); Hellinger v. Eckerd Corp., 67 F. Supp. 2d 1359 (S.D. See The World? Fla. Persuasive Essays Examples? 1999) (although applicant did not himself inform employer about his religious conflict on his job application, employer had learned when he contacted applicant’s former supervisor for a reference that the applicant had refused to sell condoms at prior job due to a religious objection, and was therefore on notice); cf. Wessling , 554 F. Inuit History? Supp. at 552 (employee’s request to leave work early in order to arrive early for a Christmas play at her church in order to decorate and receive children was insufficient to place her employer on essays examples, notice of a religious practice; it was more in the nature of a social activity or family obligation that happened to confession of shopaholics be associated with the church). [121] Cary v. Carmichael, 908 F. Supp.

1334 (E.D. Examples? Va. 1995), aff’d , 116 F.3d 472 (4th Cir. Confession? 1997); see also Elmenayer v. ABF Freight Sys. Essays Examples? , 2001 WL 1152815 (E.D.N.Y. Sept. 20, 2001) (employer not liable for disciplining employee for tardiness where employee failed until after his discharge to explain that tardiness was because he attended a prayer service), aff’d on other grounds , 318 F.3d 130 (2d Cir. 2003). [122] Notwithstanding the different legal standards for determining when a failure to accommodate poses an undue hardship under Title VII and the ADA, see supra n.117, courts have endorsed a cooperative information-sharing process between employer and how to essay, employee, similar to the “interactive process” used for disability accommodation requests under the persuasive ADA. See, e.g., Thomas v. Before? Nat’l Ass’n of Letter Carriers , 225 F.3d 1149, 1155 n.5 (10th Cir. 2000) (“the [ADA] ‘interactive process’ rationale is essays examples equally applicable to the obligation to dome offer a reasonable accommodation to an individual whose religious beliefs conflict with an employment requirement”); Elmenayer , 2001 WL 1152815, at *5 (same), aff’d on other grounds , 318 F.3d 130 ; Kenner v. Domtar Indus., Inc ., 2006 WL 662466 (W.D.

Ark. Mar. 13, 2006) (“Title VII’s reasonable accommodation provisions contemplate an interactive process, with cooperation between the employer and the employee, but which must be initiated by persuasive essays the employer”); Cosme v. Henderson , 2000 WL 1682755, *6 (S.D.N.Y. Nov. 9, 2000) (“[t]he process of finding a reasonable [religious] accommodation is intended to be an interactive process in which both the employer and employee participate”), aff’d , 287 F.3d 152 (3d Cir. 2002); cf. Ansonia Bd. of confession of shopaholics Educ. Examples? , 479 U.S. at is this a dagger i see me analysis, 69 (“courts have noted that ‘bilateral cooperation is appropriate in the search for an acceptable reconciliation of the needs of the employee’s religion and the exigencies of the essays employer’s business’”) (quoting Brener v. Diagnostic Ctr. Hosp. , 671 F.2d 141, 145-46 (5th Cir. 1982)). [123] EEOC v. Red Mules? Arlington Transit Mix, Inc ., 957 F.2d 219, 222 (6th Cir.

1991) (“[a]fter failing to pursue [a voluntary waiver of seniority rights] or any other reasonable accommodation, the essays company is in no position to argue that it was unable to accommodate reasonably [plaintiff’s] religious needs without undue hardship on dome, the conduct of its business”); EEOC v. Ithaca Indus., Inc. , 849 F.2d 116 (4th Cir. 1988) (employer’s failure to attempt to persuasive essays accommodate violated Title VII). [124] Shelton v. Univ. of Med. Dentistry of N.J. , 223 F.3d 220, 227 (3d Cir. 2000) (by refusing to meet with employer’s human resources department, employee failed to inuit history satisfy her duty to cooperate in finding a reasonable accommodation). [125] Ansonia Bd. of Educ. , 479 U.S. at persuasive examples, 69 (employer could satisfy its obligation by offering an alternative reasonable accommodation to the particular one proposed by the employee); Brener , 671 F.2d at 146 (“employee has a correlative duty to make a good faith attempt to satisfy his needs through means offered by the employer”); EEOC v. AutoNation USA Corp ., 2002 WL 31650749 (9th Cir.

Nov. 22, 2002) (unpublished) (employer satisfied its initial burden by showing that it suggested possible accommodations but that the employee short-circuited the confession of shopaholics process by resigning without first giving the proposed accommodations the opportunity to be implemented or tested); Chrysler Corp. v. Mann , 561 F.2d 1282, 1286 (8th Cir. 1977) (where employee “will not attempt to accommodate his own beliefs through the means already available to him or cooperate with his employer in its conciliatory efforts, he may forego the right to have his beliefs accommodated”), cert. denied , 434 U.S. 1039 (1978). [126] See also Bushouse , 164 F. Supp. 2d 1066. [127] Id. at 1078 n.18 (court held that union’s refusal to provide accommodation unless employee produced independent corroboration that his accommodation request was motivated by a sincerely held religious belief did not violate Title VII’s religious accommodation provision, but cautioned that the holding was limited to “the facts and circumstances of the present case” and that “the inquiry [into sincerity] and persuasive essays, scope of how i world that inquiry will necessarily vary based upon the individual requesting corroboration and the facts and circumstances of the request”).

[128] EEOC v. Tyson Foods, Inc ., Civil Action No. 99-5126 (W.D. Ark. consent decree entered Aug. Essays Examples? 14, 2000) (settlement of Title VII challenge to employer’s policy of requiring a letter from start an informative a church in support of all accommodation requests). [129] See EEOC v. Ilona of Hungary, Inc. , 108 F.3d 1569 (7th Cir. 1997) (employer did not satisfy reasonable accommodation requirement by offering to let Jewish employees take off a day other than Yom Kippur, because that would not eliminate the conflict between religion and work); Shelton , 223 F.3d at essays examples, 225 (citing Ansonia Bd. of a dagger me analysis Educ ., 479 U.S. at 68-69) (employer’s accommodation of granting unpaid leave for essays, religious observance instead of allowing use of paid personal days provided for in collective bargaining agreement (CBA), was a reasonable accommodation as long as use of the start essay paid days was not allowed for essays examples, all purposes other than religious ones); cf. Start An Informative? Bruff v. N. Mississippi Health Serv., Inc., 244 F.3d 495 (5th Cir.

2001) (hospital offered reasonable accommodation as a matter of law where it offered plaintiff who could not be accommodated in essays her current position thirty days and the assistance of its in-house employment counselor to find another position where the see the world conflict between the duties and religious beliefs could be eliminated or reduced); EEOC v. Universal Mfg. Persuasive Examples? Corp ., 914 F.2d 71 (5th Cir. 1990) (employer’s offer of confession of shopaholics five working days off or alternatively seven days off if employee worked one shift within that seven days, did not satisfy obligation to persuasive essays examples offer reasonable accommodation of her religious practice of how i see the refraining from work during seven-day religious festival, where employer did not show undue hardship). [130] See infra nn.131-133. Under the Commission’s approach, a reasonable accommodation must eliminate the conflict between work and religion unless such accommodation would impose an undue hardship, i.e. , more than de minimis cost or disruption on the employer’s business. Some courts have approached the issue of what is a reasonable accommodation in a manner that conflicts with longstanding Commission and judicial precedent. See, e.g., EEOC v. Firestone Fibers Textiles Co. Persuasive? , 515 F.3d 307 (4th Cir. 2008) (analyzing reasonableness of proposed accommodation based on red mules with ostrich, facts typically considered as part of undue hardship analysis); Sturgill v. United Parcel Service, Inc. , 512 F.3d 1024 (8th Cir. 2008) (noting that terminology which describes a reasonable accommodation as one that eliminates any work-religion conflict is essays examples imprecise, because it may incorrectly imply that reasonableness is determined as a matter of law without regard to how i world the facts of an individual case, or that an employer is not permitted to choose among alternative accommodations, or that even accommodations which conflict with a CBA or otherwise pose an undue hardship must be granted). Persuasive? The Commission’s approach is confession more straightforward and more in essays keeping with the purpose of Title VII’s accommodation requirement. Concerns about issues such as conflicts with a union contract or burdens on other employees’ settled expectations can and should be addressed in the context of whether or not it would impose an undue hardship.

Moreover, the employer need not grant an how to start an informative essay employee’s requested reasonable accommodation if the employer wishes instead to offer an alternative accommodation of its own choosing that also would eliminate the work-religion conflict and does not adversely affect the examples employee’s terms, conditions, or privileges of employment. [131] In Ansonia Bd. of Educ., 479 U.S. at 68-69, the Court held that an employer has met its obligation under § 701(j) of Title VII when it demonstrates that it has offered a reasonable accommodation to how i world the employee; “where the examples employer has already reasonably accommodated the employee’s religious needs, the statutory inquiry is at an end. The employer need not further show that each of the world employee’s alternative accommodations would result in undue hardship.” Cf. Opuku?Boateng v. California, 95 F.3d 1461 (9th Cir. 1996) (where employer offered no accommodation and employee offered several possibilities, such as scheduling him instead for other equally undesirable shifts and adopting a system of voluntary or mandatory shift trades, the employer had to examples accept one of the employee’s proposals unless doing so would create an undue hardship). This section addresses only whether the masjid accommodation was reasonable. An employer that does not provide a reasonable accommodation may nevertheless avoid liability if it shows that providing the accommodation would pose an undue hardship. Undue hardship is addressed below in essays examples § IV.B. [132] Ansonia Bd. of Educ. , 479 U.S. at a dagger i see before me analysis, 70-71 (“requiring [an employee] to persuasive essays take unpaid leave for holy day observance rather than use personal paid leave days provided for under CBA would generally be a reasonable accommodation” because it has “no direct effect upon either employment opportunities or job status,” but “unpaid leave is not a reasonable accommodation when paid leave is provided for all purposes except religious ones . . . [s]uch an arrangement would display a discrimination against see the religious practices that is the antithesis of reasonableness”).

In cases involving requests for schedule changes or leave as an accommodation, an employer does not have to persuasive examples provide paid leave as an accommodation beyond that otherwise available to inuit history the employee, but may have to persuasive examples provide unpaid leave as an accommodation if it would not pose an red mules with ostrich feathers undue hardship. [133] Commission Guidelines , 29 C.F.R. § 1605.2(c)(2)(ii) (“when there is more than one means of persuasive essays examples accommodation that would not cause undue hardship, the employer or labor organization must offer the start alternative which least disadvantages the individual’s employment opportunities”). The Commission’s guidelines do not require an employer to accept any alternative favored by the employee, and, thus, are not inconsistent with Ansonia . In fact, the persuasive Court in Ansonia recognized that the limitation in the Commission’s guidelines that alternatives must be considered if they will not “disadvantage an nabawi individual’s employment opportunities” distinguished the Commission’s position from the persuasive examples position of the how to start Second Circuit that was rejected in Ansonia . 470 U.S. at 69 n.6. Appellate courts in the wake of Ansonia have, as the Commission’s guidelines instruct, evaluated whether employer accommodations had a negative impact on essays examples, the individual’s employment opportunities. Of Shopaholics? See Cosme v. Henderson , 287 F.3d 152, 160 (2d Cir. 2002) (an accommodation might be unreasonable if it imposes a “significant work-related burden on the employee without justification”); Wright v. Runyon , 2 F.3d 214, 217 (7th Cir. 1993) (whether an accommodation is reasonable requires a more searching inquiry if an employee, “in order to accommodate his religious practices, had to persuasive examples accept a reduction in pay or some other loss of how to essay benefits”). [134] Smith v. Pyro Mining Co. Persuasive Essays? , 827 F.2d 1081, 1085 (6th Cir. 1987) (quoting Redmond , 574 F.2d at 902-03). [135] Baker v. Is This Before? Home Depot , 445 F.3d 541 (2d Cir.

2006) (employer’s offer to schedule employee to work in the afternoon or evenings on Sundays, rather than the mornings, was not a “reasonable” accommodation under Title VII where employee’s religious views required not only attending Sunday church services but also refraining from work on Sundays). [136] Wilshin v. Allstate Ins. Co., 212 F. Examples? Supp. 2d 1360 (M.D. Ga. 2002) (employer satisfied obligation to a dagger me analysis accommodate employee’s Saturday Sabbath observance by offering Sunday work hours instead, notwithstanding that employee would have preferred weekday hours). [137] Shelton , 223 F.3d at persuasive essays, 226 (state hospital’s offer to inuit history transfer nurse to newborn intensive care unit was reasonable accommodation for her religious beliefs which prevented her from persuasive assisting in emergency procedures to terminate pregnancies, where nurse presented no evidence that transfer would affect her salary or benefits); see also Rodriguez v. City of Chicago, 156 F.3d 771 (7th Cir.

1998) (city’s offer to allow police officer to how i world exercise his right under CBA to persuasive essays transfer to a district with no abortion clinics resolved his religious objection to being assigned to guard such facilities; Title VII did not compel employer to instead grant his preferred accommodation of remaining in his district but being relieved of such assignments); Wright , 2 F.3d at start an informative essay, 217 (7th Cir. 1993) (employer reasonably accommodated employee by suggesting he exercise his rights under CBA to bid on jobs that would have eliminated the conflict between work and religion). [138] Townley , 859 F.2d at 614 n.5 (citing Am. Postal Workers Union v. Postmaster , 781 F.2d 772, 774?75 (9th Cir. 1986)); see also Rodriguez v. City of Chicago, 1996 WL 22964, at *3 (N.D. Ill. Essays Examples? Jan. 12, 1996) (rejecting employer’s argument that a threat of inuit history adverse action is not enough to state a claim; “it is nonsensical to suggest that an employee who, when forced by his employer to choose between his job and his faith, elects to avoid potential financial and/or professional damage by acceding to his employer’s religiously objectionable demands has not been the essays victim of religious discrimination”).

Moreover, a denial of accommodation claim can be brought if the employer could have provided an accommodation absent undue hardship that did not disadvantage a term, condition, or privilege of employment, but did not do so. For example, if a Muslim employee is how i see the transferred to non-customer service position because she refuses to stop wearing a religiously mandated headscarf, she states a claim for denial of accommodation under Title VII. Examples? Draper v. U.S. Pipe Foundry Co. , 527 F.2d 515 (6th Cir. 1975) (resorting to transfer where accommodation was possible in employee’s current position is actionable as denial of reasonable accommodation). Start Essay? However, an essays employer need not accommodate an employee who chooses to resign before notifying the employer of the need for of shopaholics, accommodation or fails to cooperate with the employer in the accommodation process. See, e.g., Goldmeier v. Essays? Allstate Ins. How I World? Co. , 337 F.3d 629 (6th Cir. 2003) (resignation 53 days prior to effective date of employer’s policy that would have posed conflict with employees’ religious beliefs did not constitute constructive discharge); Lawson v. Washington , 296 F.3d 799 (9th Cir. 2002) (Jehovah’s Witness who quit state patrol rather than salute the essays flag or take an oath in violation of his religious beliefs was not constructively discharged and thus was not subject to an adverse employment action where, rather than request accommodation, he informed employer that he was resigning due to his religious conflict); Shelton v. How To Start Essay? Univ. of Med.

Dentistry of N.J. , 223 F.3d 220, 227 (3d Cir. 2000) (employee who refused to meet with employer’s human resources department to pursue alternative accommodations could not argue that accommodation employer offered was not reasonable). [139] Townley , 859 F.2d at 614 n.5 ; Rodriguez, 1996 WL 22964. [140] Cooper , 15 F.3d at 1379 (Seventh-day Adventist employee’s need for accommodation to essays examples observe Sabbath had changed in the 17 months since employer had last scheduled her to how i see the world work on a Friday night or Saturday; her “undisputed testimony was that her faith and commitment to persuasive her religion grew during this time”). [141] See, e.g., Hardison, 432 U.S. at 84. This “more than de minimis ” Title VII undue hardship standard is inuit history substantially lower than the ADA undue hardship standard, which requires employers to show that the accommodation would cause “significant difficulty or expense.” [142] Both the statute, at 42 U.S.C. § 2000e(j), and the Commission Guidelines , at 29 C.F.R. § 1605.2(b), require an employer to reasonably accommodate an employee’s or applicant’s religious beliefs and practices “unless the employer demonstrates” that doing so would pose an undue hardship. Even under the Fourth Circuit’s decision in essays examples EEOC v. Firestone , and red mules ostrich feathers, the Eighth Circuit’s decision in Sturgill v. United Parcel Service , where courts focused on reasonableness before looking at persuasive examples, undue hardship, the employer still has the burden of inuit history persuasion. Persuasive Examples? Firestone , 515 F.3d at 315; Sturgill , 512 F.3d at 1033 n.4. [143] Tooley v. Martin Marietta Corp. , 648 F.2d 1239, 1243 (9th Cir. 1981).

[144] Commission Guidelines , 29 C.F.R. § 1605.2(e). [145] Compare Cooper , 15 F.3d at inuit history, 1380(employee’s request not to be scheduled for essays examples, Saturday work due to Sabbath observance posed undue hardship for employer because it would have required hiring an additional worker), and Beadle v. Tampa , 42 F.3d 633 (11th Cir. 1995) (requiring police department to alter training program schedule involving more than 900 employees to accommodate one employee’s religious needs amounts to nabawi dome more than de minimis cost and thus undue hardship), with Protos , 797 F.2d 129 (employee’s request not to be scheduled for Saturday work due to persuasive essays examples Sabbath observance did not pose undue hardship where employer made no showing that efficiency, production, or quality would be affected and entire assembly line remained intact notwithstanding employee’s Saturday absences). [146] See Brown v. Gen. Motors Corp., 601 F.2d 956, 960 (8th Cir. 1979) (“projected ‘theoretical’ future effects cannot outweigh the of shopaholics undisputed fact that no monetary costs and de minimis efficiency problems were actually incurred during the three month period in which [employee] was accommodated”); EEOC v. Alamo Rent-A-Car, LLC , 432 F. Supp. 2d 1006 (D. Essays? Ariz. 2006) (employer incorrectly believed that if it allowed plaintiff to wear her religious headscarf it could not enforce its uniform policy with respect to other employees, and failed to show undue hardship based on its fear that allowing the accommodation would open “the floodgates to others violating the of shopaholics uniform policy”).

[147] Tooley , 648 F.2d at 1243 (“undue hardship cannot be supported by merely conceivable or hypothetical hardships . . . . The magnitude as well as the fact of hardship must be determined by ‘actual imposition on co-workers or disruption of the work routine’”) (quoting Anderson v. Gen. Dynamics Convair Aerospace Div. , 589 F.2d 397, 406-07 (9th Cir. Essays? 1978)); EEOC v. Alamo Rent-A-Car, LLC , 432 F. An Informative Essay? Supp. Persuasive? 2d at red mules with ostrich, 1016 (“‘hypothetical hardships’” based on persuasive essays examples, assumptions or “pure speculation” about accommodations which have never been put into practice are insufficient to nabawi dome show undue hardship”). [149] Id. Compare EEOC and Electrolux Reach Voluntary Resolution in persuasive essays examples Class Religious Accommodation Case (press release available at https://www.eeoc.gov/press/9-24-03.html, Sept. 24, 2003) (settlement whereby employer agreed to accommodate the religious request of 165 Somali workers who, pursuant to the tenets of the Islamic faith, must offer at least five daily prayers, two of which must be observed within a restricted time period of between one and two hours) with Farah v. Whirlpool Corp ., 3:02cv424 (M.D.

Tenn. Oct. 16, 2004) (jury verdict entered in favor of employer, which argued that allowing 40 Muslim factory workers to take a break from the line for their sunset prayers at the same time would result in an undue hardship because as a result of their absence, the line would have to be shut down). [150] Commission Guidelines , 29 C.F.R. Start? § 1605.2(e)(1). Under Title VII, for example, in Hardison , the payment of overtime (or premium pay) to another employee so that plaintiff could be off for weekly religious observance was an persuasive undue hardship. How To? Id . By contrast, infrequent pay of premium wages for an occasional religious observance is essays examples not “more than de minimis .” See, e.g., EEOC v. Southwestern Bell Tel. LP , 2007 WL 2891379 (E.D. Ark. Oct. Of Shopaholics? 3, 2007) (summary judgment for employer denied on claim by two employees that they were improperly denied leave for an annual religious observance that would have required company to pay two other workers overtime wages of approximately $220 each to fill in, where the facility routinely paid technicians overtime, the employer failed to contact the union about persuasive possible accommodation, the start an informative policy providing for only one technician on leave per day was not always observed, and there was no evidence that customer service needs actually went unmet on persuasive, the day at issue) (jury verdict for plaintiffs subsequently entered), appeal docketed , Case No.

08-1096 (8th Cir. filed Jan. 10, 2008); Brown v. Gen. Motors Corp. Is This A Dagger I See? , 601 F.2d at 959-60 (no more than de minimis cost imposed by persuasive allowing employee to leave work at Sundown on Friday where he did not receive any pay for the time missed, a replacement worker was readily available to fill in for him on the shift during the hours he missed because the company maintained “extra board men” who were at all times available to replace unscheduled absences of regular employees); Burns v. S. Pac. Transp. Co. , 589 F.2d 403, 407 (9th Cir. 1978) (excusing employee from red mules paying his monthly $19 union dues due to religious objection did not pose an undue hardship, where one union officer testified that the loss “wouldn’t affect us at all”; the loss was also de minimis because “even if so necessary to its fiscal well?being that its equivalent would be collected from the Local’s 300 members at a rate of 2 cents each per month; an accommodation that would only result in an increase of other union members dues in amount of 24 cents per essays, year was de minimis ; unions asserted fear that many more religious objectors would request similar accommodation, resulting in greater cost, was based on mere speculation); EEOC v. IBP, Inc. , 824 F. Supp. 147 (C.D. Ill. 1993) (adopting EEOC’s interpretation in the Commission Guidelines that undue hardship means, with respect to costs for a substitute, “costs similar to the regular payment of premium wages,” and holding that “[i]nfrequent payment of how to an informative premium wages made on a temporary basis and examples, administrative costs associated with implementing an inuit history accommodation are considered de minimis , although the ultimate determination is made with ‘due regard given to the identifiable cost in relation to the size and persuasive essays examples, operating cost of the employer.’ 29 C.F.R. § 1605.2(e)(1)).” [151] Commission Guidelines , 29 C.F.R. § 1605.2(e)(1); Redmond , 574 F.2d at 904 (employer could not demonstrate that paying replacement worker premium wages would cause undue hardship because plaintiff would have been paid premium wages for the hours at issue). [152] Protos , 797 F.2d at 134-35; Brown v. Polk County , 61 F.3d at masjid dome, 655 (allowing employee to assign secretary to type his Bible study notes posed more than de minimis cost because secretary would otherwise have been performing employer’s work during that time). [153] “[A]n employer need not accommodate an employee’s religious beliefs if doing so would result in discrimination against his co-workers or deprive them of contractual or other statutory rights.” Peterson v. Hewlett-Packard Co. , 358 F.3d 599 (9th Cir.

2004) (also holding that employee’s proposed accommodation of either allowing him to post religiously motivated messages intended to demean and examples, harass co-workers, or the masjid nabawi company deleting sexual orientation from its voluntarily adopted diversity and non-discrimination policy, would have posed an undue hardship on examples, the employer); EEOC v. BJ Servs. Co. , 921 F. Supp. 1509 (N.D. Tex. 1995) (employer was unable to accommodate employee’s religious request for a dagger before, certain day off because no other employees were available to work, there were safety concerns regarding untrained substitute personnel, there were significant costs in bringing employees from other locations, and this accommodation would deny other employees their day off); Virts v. Consol. Persuasive Essays? Freightways Corp. of Delaware , 285 F.3d 508 (6th Cir. With Ostrich? 2002) (trucking firm had no obligation under Title VII to accommodate a driver’s religious request for only male driving partners, where making assignments in this manner would have violated collective bargaining agreement). [154] BJ Servs. Persuasive Examples? Co., 921 F. Masjid Nabawi? Supp. at 1509; Balint v. Carson City, Nevada , 180 F.3d 1047, 1054 (9th Cir. 1999) (citing Bhatia v. Chevron U.S.A., Inc. , 734 F.2d 1382, 1384 (9th Cir.1984) (cost of plaintiff’s requested accommodation was more than de minimis when it required co-workers to assume plaintiff’s share of the hazardous work)); Bruff 244 F.3d at 501 (requiring co-workers of plaintiff mental health counselor to assume disproportionate workload to accommodate plaintiff’s request not to counsel certain clients on religious grounds would constitute undue hardship). [155] See, e.g., Sutton v. Providence St.

Joseph Med. Ctr. , 192 F.3d 826 (9th Cir. 1999) (employer not required to accommodate job applicant’s religiously based refusal to provide his social security number where employer sought it to persuasive essays examples comply with Internal Revenue Service and Immigration and Naturalization Service requirements). However, an how i world employer should not assume that it would pose an undue hardship to accommodate a religious practice that appears to conflict with a generally applicable safety requirement, but rather should assess whether an persuasive undue hardship is actually posed. For example, there are existing religious exemptions to the government enforcement procedures of before me analysis some safety requirements.

See, e.g. , U.S. Department of examples Labor, Occupational Safety and Health Administration STD 1-6.5 (“Exemption for Religious Reason from Wearing Hard Hats”) (June 20, 1994) (exempting employers from citations for certain violations based on religious objection of employee, but providing for various reporting requirements). [156] See EEOC v. Oak-Rite Mfg. Corp. , 2001 WL 1168156 (S.D. Ind. Aug. Confession Of Shopaholics? 21, 2001) (manufacturing employee’s proposed accommodation of wearing close-fitting denim or canvas dress or skirt that extends to within two or three inches above the ankle would impose an persuasive essays undue hardship on employer by requiring it to experiment with employee safety, given the absence of evidence demonstrating safety of proposed accommodation in a comparable work setting); EEOC v. Brink’s Inc., No. 1:02-CV-0111 (C.D. Inuit History? Ill.) (consent decree filed Dec. 27, 2002) (settlement of examples case alleging that employee was denied reasonable accommodation when she sought to wear culottes made out of messenger uniform material, rather than the required trousers, because her Pentecostal Christian beliefs precluded her from wearing pants); c f. Inuit History? Webb v. City of Philadelphia, 2007 WL 1866763 (E.D.

Pa. June 27, 2007) (undue hardship to accommodate the wearing of a traditional religious headpiece called a khimar by a Muslim police officer while in uniform, where evidence showed dress code in para-military organization promotes cooperation, fosters esprit de corps, emphasizes the hierarchical nature of the police force, and portrays a sense of authority as well as public and religious neutrality to the public). [157] Hardison, 432 U.S. at 80; Stolley v. Lockheed Martin Aeronautics Co. , 2007 WL 1010418 (5th Cir. March 28, 2007) (unpublished) (affirming summary judgment in favor of the employer, the court ruled that a newly-hired aircraft assembly line worker was not entitled to have the employer reassign him to a different shift as an accommodation for essays, his Sabbath observance, because the employer’s union contract dictated that shift swapping and transfers would be based on seniority and the union was unwilling to waive the contract in this case); see also Balint , 180 F.3d at 1054. [158] Balint, 180 F.3d at 1054; Killebrew v. Local Union 1683 of Am. Fed’n of State, County, Mun. Employees, AFL-CIO, 651 F. Supp. 95 (W.D. Ky. Masjid Nabawi Dome? 1986) (union not required to negotiate a change in the CBA to allow an employee to bump another employee to obtain an accommodation because bumping would have been detrimental to persuasive those bumped); see also Virts v. Consol. Freightways Corp. of Delaware , 285 F.3d 508 (6th Cir.

2002) (trucking firm had no obligation under Title VII to accommodate a driver’s religious request for only male driving partners, where making assignments in this manner would have violated CBA); Weber v. Roadway Express, Inc. , 199 F.3d 270 (5th Cir. 2000) (same); Thomas , 225 F.3d 1149 (because seniority system in CBA gave more senior employees first choice for job assignments, it would be an undue hardship for employer to grant employee’s accommodation request not to be scheduled to work on Saturdays); Mann v. Frank , 7 F.3d 1365 (8th Cir.1993) (no violation of the duty to how i accommodate where the union refused the persuasive examples Postal Service’s request to assign another worker to take plaintiff’s Saturday shift, which would have violated CBA’s provisions governing overtime). [159] Commission Guidelines , 29 C.F.R. How To Essay? § 1605.2(e)(2); Stolley , 2007 WL 1010418. [160] Lee v. Persuasive Essays Examples? ABF Freight Sys., Inc., 22 F.3d 1019 (10th Cir. Masjid Dome? 1994) (employer satisfied Title VII obligation when it suggested method by essays examples which driver would usually be able to work the number of trips each week required under the of shopaholics union contract prior to the Sabbath, and essays, could use vacation time on other occasions; employer was not required to grant driver’s request to world skip assignments, which would then have to be worked by other drivers, or his request to work less than other full-time drivers and reimburse employer for examples, additional costs; or his request to transfer with no loss of dome seniority, which would violate its CBA, where the employer had sought but could not obtain a waiver from the union). [162] See Wilson v. U.S. West Communications, 58 F.3d 1337 (8th Cir. Persuasive Examples? 1995) (employer reasonably accommodated an employee by asking her when she was outside her cubicle to cover up an masjid nabawi dome anti-abortion button she wore containing a graphic photograph of a fetus because the button so distracted other employees that it had caused a 40% reduction in productivity and some employees threatened to walk off their jobs). [163] Opuku-Boateng , 95 F.3d at 1473 (mere complaints by other employees did not constitute undue hardship; employer failed to establish undue hardship in accommodating employee’s religious holidays because it did not show hardship on plaintiff’s co-workers or that accommodation required more than de minimis cost).

[164] Burns, 589 F.2d at 407 (“Undue hardship requires more than proof of essays some fellow-workers’ grumbling or unhappiness with a particular accommodation to a religious belief. An employer or union would have to of shopaholics show . . . actual imposition on co-workers or disruption of the persuasive essays work routine.”); accord Brown v. Polk County , 61 F.3d at 655; Peterson v. Hewlett-Packard Co. , 358 F.3d 599 (9th Cir. Nabawi? 2004) (it would have posed an undue hardship for employer to accommodate employee’s religiously motivated posting of large signs in persuasive his cubicle which he “intended to confession be hurtful” and to demean and harass his co-workers; it also would have posed an persuasive examples undue hardship for employer to eliminate a portion of its diversity program to which plaintiff had religious objections). [165] See nn.182-184, infra. However, a different result may obtain depending on the setting and inuit history, the religious garb at persuasive essays examples, issue. See United States v. New York State Dep’t of nabawi dome Corr. Servs. , Civil Action No. 07-2243 (S.D.N.Y. Persuasive Essays Examples? settlement approved Jan. 18, 2008) (providing for individualized review of correctional officers’ accommodation requests with respect to how to start essay uniform and grooming requirements, and allowing employees to wear religious skullcaps such as kufis or yarmulkes if close fitting and solid dark blue or black in essays examples color, provided no undue hardship was posed).

[166] For example, Title 18 U.S.C. Section 930 generally prohibits the possession of knives, including kirpans, with blades longer than 2.5 inches, in is this i see federal facilities, unless otherwise authorized. [167] The Commission’s regulations, Commission Guidelines , 29 C.F.R. § 1605.2(d), set forth suggested methods of accommodating scheduling conflicts, but those methods are not intended to comprise an exhaustive list. Different factual circumstances will require different solutions. Essays Examples? State wage and hour laws may provide certain limitations that impact an employer’s potential flexibility. [168] See “Electronics Manufacturer and Islamic Group Settle Muslim Prayer Issue in Georgia Factory,” Daily Labor Report (BNA), No. Inuit History? 230 (Dec. 1, 1999) (ISSN 1522-5968); see also supra n.149; George v. Home Depot , 2002 WL 31319124 (5th Cir. Sept. 22, 2002) (unpublished) (excusing employee who served as department “greeter” from examples working any Sundays would have posed an undue hardship, because she was the only greeter in inuit history the department; the store would have had to do without a Sunday greeter or hire another employee in order to grant the accommodation, both of persuasive examples which would have posed an undue hardship based on the evidence the employer provided regarding the need for the position); Brener , 671 F.2d 141 (requiring hospital to hire a substitute pharmacist for days employee sought not to work due to religious observance involved more than a de minimis cost, and operating without him or having the confession pharmacy director substitute for him would have had an unacceptable adverse impact on functions of the pharmacy). [169] See U.S. Essays Examples? v. Los Angeles County Metropolitan Transit Authority , Case No.

CV 04-07699 JFW (JTLx) (C.D. Cal. Me Analysis? consent decree filed Oct. Persuasive Essays Examples? 2005) (lawsuit filed by Civil Rights Division of the U.S. Department of ostrich Justice and resolved by consent decree prior to ruling by court on merits; the settlement provided that the employer would accept the applications of Sabbath-observant applicants; provide applicants with information about persuasive essays their accommodation rights; permit drivers to swap assignments with other drivers, and inuit history, when no acceptable assignment is possible either through use of seniority rights or swaps, permit drivers to take temporary leaves of absence; and provide information about religious accommodation in essays examples marketing literature and in its training programs for how i, supervisors). [170] EEOC v. Robert Bosch Corp. , 2006 WL 406296 (6th Cir.

Feb. Persuasive Examples? 21, 2006) (unpublished) (in case involving request for inuit history, shift swap and essays, relief from confession mandatory overtime to accommodate Sabbath observance, summary judgment for employer reversed where reasonable factfinder could conclude that employer failed to provide reasonable accommodation based on evidence that plaintiff was told a shift swap would not be permitted and the employer’s policy was only examples designed to identify employees willing to work additional shifts, not to inuit history swap shifts); Beadle v. Hillsborough County Sheriff’s Dep’t , 29 F.3d 589 (11th Cir. 1994) (employer satisfied its accommodation obligation by persuasive essays examples allowing employee to make announcement on inuit history, bulletin board and at employee meeting to seek out persuasive essays, co-workers willing to swap); McGuire v. Gen. Motors Corp ., 956 F.2d 607 (6th Cir. 1992) (summary judgment for employer reversed where genuine issue of material fact existed regarding whether employer’s accommodation of allowing voluntary shift swaps was a reasonable accommodation where there was evidence employer may have intentionally or unintentionally inhibited volunteers from swapping shifts by issuing a survey to employees regarding whether they would be willing to swap shifts in masjid nabawi order to accommodate plaintiff); see also Beadle v. Tampa, 42 F.3d at 636-37 (excusing police recruit from rotating training schedule would have posed undue hardship because it would undermine intended educational benefit of working with different training officers); Morrissette-Brown v. Mobile Infirmary Med. Ctr. , 2006 WL 1999133 (S.D. Ala. July 14, 2006) (in case brought by essays examples Seventh-day Adventist who requested not to work on her Sabbath, employer satisfied its accommodation obligation by maintaining a neutral shift rotation schedule, allowing plaintiff to arrange a shift swap with co-workers, and making available the schedules of is this before other employees). [171] See, e.g., Pyro Mining Co. , 827 F.2d at 1088-89 (it would be a reasonable accommodation for employer simply to be amenable to a shift swap; employer not required itself actively to solicit other employees to make such a swap unless plaintiff had religious constraints against arranging his own schedule swap with other employees; a CBA’s provision permitting religious observers to trade days off with other employees did not provide reasonable accommodation in the case of an persuasive essays employee who had a religious objection to seeking such a trade); EEOC v. Texas Hydraulics, Inc. , Case No. 2:06-cv-161 (E.D. Tenn.

April 16, 2008) (employer's proposal that employee find another qualified candidate to take his Saturday shift was not a reasonable accommodation because the employer was on notice that the employee considers it a sin for anyone to work on Saturday, not just himself); EEOC v. Red Mules? Aldi , 2008 WL 859249 (W.D. Pa. March 28, 2008) (where an employee sincerely believes that working on [his Sabbath] is morally wrong and that it is a sin to try to induce another to essays work in a dagger i see before me analysis his stead, then an employer's attempt at accommodation that requires the employee to seek his own replacement is not reasonable ”) (emphasis in original) (citing Pyro Mining Co. Persuasive? , 827 F.2d at inuit history, 1088). [172] Commission Guidelines , 29 C.F.R. § 1605.2(e)(1); Redmond. , 574 F.2d at 904 (employer could not demonstrate that paying replacement worker premium wages would cause undue hardship because plaintiff would have been paid premium wages for the hours at issue); EEOC v. Examples? Southwestern Bell Tel. LP, 2007 WL 2891379 (E.D. See The? Ark. Oct. 3, 2007) (payment of premium wages for one day to persuasive examples allow two employees to attend a yearly Jehovah’s Witness convention as part of their religious practice, at an alleged cost of $220.72 per person in a facility that routinely paid overtime was not an undue hardship as a matter of law, where there was no evidence that customer service needs actually went unmet on the day at issue), appeal docketed , Case No.

08-1096 (8th Cir. filed Jan. 10, 2008). [173] U.S.F. Logistics (IMC), Inc. , 274 F.3d at is this i see before me analysis, 477 (“[i]n many cases, a company must modify its stated policies in practice to examples reasonably accommodate a religious practice”) (citing Minkus v. Metro. With Ostrich Feathers? Sanitary Dist. , 600 F.2d 80 (7th Cir.1979) (municipal employer failed to accommodate a Jewish applicant when it followed its stated policy and examples, scheduled civil service examinations only on Saturdays). [174] EEOC v. Razzoo’s , Civil Action No. 3:06-CV-1781-L (N.D. Tex. A Dagger Before? consent decree filed June 18, 2007) (settlement of case alleging that restaurant unlawfully failed to accommodate server’s religious beliefs by excusing her from participating in singing “Happy Birthday” to celebrating customers). [175] Noesen v. Med. Staffing Network, Inc. , 2007 WL 1302118 (7th Cir. May 2, 2007) (unpublished) (pharmacy reasonably accommodated employee by persuasive essays examples allowing him to red mules with transfer to co-worker any customer service involving contraceptives; employee’s proposed further accommodation of assigning responsibility for all initial customer contact to lower-paid technicians, even if it could be done, would impose an undue hardship because it would divert technicians from their assigned data input and insurance verification duties, resulting in uncompleted data work).

The reasonable accommodation that the persuasive essays examples employer was able to nabawi dome provide in Noesen might pose an undue hardship in a different case where there was no qualified co-worker on duty to whom such customer service duties could be transferred, or where it would otherwise pose more than a de minimis burden on examples, the operation of the employer’s business. [177] Draper , 527 F.2d at 519-20 (transfer that involved substantial reduction in pay and would have “wasted [plaintiff’s] skills” would not be reasonable accommodation where plaintiff could have been accommodated in his original position without undue hardship). [178] Commission Guidelines , 29 C.F.R. § 1605.2(d)(iii) (“When an feathers employee cannot be accommodated either as to his or her entire job or an assignment within the job, employers and labor organizations should consider whether or not it is possible to change the job assignment or give the employee a lateral transfer.”); Rivera v. Choice Courier , 2004 WL 1444852 (S.D.N.Y. Persuasive Essays Examples? June 25, 2004) (employer’s failure to consider transferring employee to position with less stringent dress code so that he could continue his religious practice of proselytizing by wearing patch stating “Jesus is Lord” may have violated Title VII). [179] See supra n.138; Rodriguez , 156 F.3d at 775-77 (permitting employee to exercise transfer rights under CBA to obtain equivalent position that eliminated religious conflict with duty assignment was a reasonable accommodation); see also Cook v. Lindsay Olive Growers , 911 F.2d 233, 241 (9th Cir. Is This I See Before Me Analysis? 1990) (under state law parallel to persuasive essays Title VII, transfer of employee to a lower-level position was reasonable where no equivalent position was available); Bruff , 244 F.3d at 501 (accommodation by transfer to lower-paying non-counselor job could satisfy Title VII if plaintiff could not be accommodated in red mules with ostrich feathers her current position or an equivalent position). [180] Shelton , 223 F.3d at 227 (offering transfer to nurse who had religious objection to abortion procedure sometimes performed in her department was a reasonable accommodation); EEOC v. Persuasive Essays? Dresser-Rand Co. Is This I See Me Analysis? , 2006 WL 1994792 (W.D.N.Y. July 14, 2006) (summary judgment for employer denied in case on behalf of a Jehovah’s Witness who allegedly was denied transfer to different assignment as an accommodation of his religious objection to working on military projects). But cf. supra n.138 (discussing when a lateral transfer might be an persuasive essays examples adverse employment action). At least one court has ruled that it is unreasonable for public protectors such as police officers or fire fighters to see the world seek to be relieved from certain assignments as a religious accommodation.

See Endres v. Indiana State Police , 349 F.3d 922, 927 (7th Cir. 2003) (state police officer’s religious accommodation request not to be assigned to full-time, permanent work at a casino was unreasonable; police and fire departments “need the cooperation of all members” and need them to perform their duties “without favoritism”), cert. denied , 541 U.S. 989 (2004). Because public protectors, such as police officers and firefighters, are obliged to persuasive examples serve and protect all under their care, and how i world, their public responsibilities must take precedence over their religious and persuasive essays, other personal scruples, in some cases conflicts between the requirements of their job and their religious beliefs may not be able to be resolved. Masjid Dome? However, it is not per se unreasonable for public protectors to obtain changes in job assignments, schedule changes, or transfers in situations where a conflict between their job duties and their religious beliefs could be eliminated or reduced.

Therefore, the essays examples better approach is to confession determine on essays examples, a case-by-case basis whether granting the request would pose an is this i see undue hardship. [181] See, e.g., EEOC v. United Parcel Serv. Persuasive? , 94 F.3d 314 (7th Cir. 1996) (genuine issue of a dagger me analysis material fact regarding whether the examples employer reasonably accommodated the with feathers employee’s religious practice of wearing a beard precluded summary judgment for the employer); EEOC v. Comair, Inc. , Civil Action No. 1:05-cv-0601 (W.D. Mich. consent decree filed Nov. 22, 2006) (settlement prior to ruling on merits of case on behalf of Rastafarian airline applicant alleging he was not hired because he refused to cut his hair to conform with the company’s grooming standards); EEOC v. Pilot Travel Ctrs .LLC , Civil Action No. 2:03-0106 (M.D. Tenn. consent decree filed April 9, 2004) (settlement prior to ruling on merits of claim on behalf of Messianic Christian maintenance worker, who wore beard as part of his religious practice, and essays examples, was terminated for see the world, refusing to examples shave in compliance with employer’s no-beard policy). [182] United Parcel Serv ., 94 F.3d at 318-20; c ompare Daniels , 246 F.3d 500 (police department may be able to demonstrate that allowing an officer to how i see the wear a cross on his uniform would give the examples appearance of public agency endorsement of the officer’s religious views, in violation of the department’s constitutional obligations, and therefore would pose an undue hardship under Title VII), cert. denied , 534 U.S. 951 (2001), with Draper v. Logan County Pub.

Library , 403 F. Confession? Supp. 2d 608 (W.D. Ky. 2005) (public library employee’s First Amendment free speech and free exercise rights were violated when she was prohibited from wearing a necklace with a cross ornament). [183] See, e.g., Cloutier v. Costco Wholesale Corp. , 390 F.3d 126 (1st Cir.

2004) (holding that it would pose “an undue hardship to persuasive examples require Costco to is this grant an exemption because it would adversely affect the employer’s public image,” given Costco’s determination that facial piercings detract from the “neat, clean and professional image” that it aims to cultivate). [184] Denying the employer’s motion for summary judgment in EEOC v. Red Robin Gourmet Burgers, Inc. Persuasive? , 2005 WL 2090677 (W.D. How I See The? Wash. Aug. Persuasive Essays Examples? 29, 2005), the court ruled that notwithstanding the employer’s purported reliance on a company profile and customer study suggesting that it seeks to present a family-oriented and an informative, kid-friendly image, the company failed to demonstrate that allowing an employee to have visible religious tattoos was inconsistent with these goals. “Hypothetical hardships based on persuasive, unproven assumptions typically fail to constitute undue hardship . . . Confession? . Red Robin must provide evidence of ‘actual imposition on co-workers or disruption of the work routine’ to demonstrate undue hardship.” S ee also Brown v. F.L. Roberts , 419 F. Examples? Supp. 2d 7, 17 (D. Mass. 2006) (district court held no Title VII violation occurred when employer transferred lube technician whose Rastafarian religious beliefs prohibited him from is this me analysis shaving or cutting his hair to a location with limited customer contact because he could not comply with a new grooming policy; stating it was bound to follow Cloutier as the law of the circuit, the court nevertheless observed in dicta: “If Cloutier’s language approving employer prerogatives regarding ‘public image’ is read broadly, the essays implications for persons asserting claims for religious discrimination in the workplace may be grave. One has to wonder how often an employer will be inclined to cite this expansive language to terminate or restrict from customer contact, on image grounds, an employee wearing a yarmulke, a veil, or the mark on the forehead that denotes Ash Wednesday for many Catholics. Of Shopaholics? More likely, and more ominously, considerations of essays ‘public image’ might persuade an masjid dome employer to tolerate the religious practices of predominant groups, while arguing ‘undue hardship’ and ‘image’ in forbidding practices that are less widespread or well known.”); EEOC v. Chriskoll, Inc. Persuasive Essays Examples? , d/b/a Brookhaven Burger King, Civil Action No.

06-cv-1197 (E.D. Confession? Pa. Persuasive? consent decree filed December 3, 2007) (settlement of claim on behalf of Muslim employee who was terminated pursuant to restaurant appearance code requiring male employees to be clean-shaven notwithstanding that employer’s written policy had exception permitting beards required for religious reasons). [185] See generally EEOC v. How I World? American Airlines , Civil Action No. 02-C-6172 (N.D. Persuasive Examples? Ill.) (Order of see the world Resolution filed September 3, 2002) (resolving claim on behalf of employee who was not hired as passenger service agent because she wore a hijab for religious reasons in violation of the airline’s since-changed uniform policy; the airline’s current uniform policy specifically contemplates exceptions for persuasive essays examples, religious accommodation of employees). [186] Webb v. Confession? City of Philadelphia, 2007 WL 1866763 (E.D.

Pa. June 27, 2007) (granting summary judgment to the employer, the persuasive essays examples court ruled that the City of Philadelphia established as a matter of law that it would pose an undue hardship to accommodate the wearing of a traditional religious headpiece called a khimar by a Muslim police officer while in how to start uniform, in contravention of the department’s dress code directive). [187] See U.S. v. New York State Dep’t of persuasive essays Corr. Servs. How I See The? , Civil Action No. 07-2243 (S.D.N.Y. settlement approved Jan. 18, 2008) (settlement of case brought on persuasive essays, behalf of Muslim correctional officers by U.S. Department of Justice providing that employee requests for inuit history, religious exemptions from uniform and grooming requirements of persuasive essays examples state prison system would be determined on a case-by-case basis, and allowing employees to wear religious skullcaps such as kufis or yarmulkes if close fitting and solid dark blue or black in red mules ostrich feathers color, provided no undue hardship was posed). [188] See also Federal Workplace Guidelines , supra n.11, at § 1.c (“Accommodation of persuasive essays Religious Exercise”), example (d) (under the First Amendment, government workplaces that allow employees to red mules with ostrich use facilities for non-work related secular activities generally are required to allow the privilege on equal terms for employee religious activities). [189] See, e.g., Minkus , 600 F.2d 80; Cary , 908 F. Supp. at 1343-44 (employee failed to give employer proper notice so that it could attempt an accommodation of his religious objection to persuasive essays signing consent form for a drug test). [190] Minkus , 600 F.2d 80 (employer must demonstrate it would pose undue hardship to is this a dagger i see before me analysis allow applicant to take exam at different time than others as a religious accommodation). [191] Sutton v. Providence St.

Joseph Med. Ctr. , 192 F.3d 826 (9th Cir. Essays? 1999) (hospital not liable for refusing to hire applicant who declined to provide social security number on religious grounds; because federal tax law required the hospital to obtain all employees’ social security numbers, accommodation of applicant’s religious belief would pose undue hardship); Hover v. Florida Power Light Co., 1995 WL 91531 (S.D. Fla. Feb.

6, 1995) (employee’s proposed accommodation that employer “make up” a social security number rather than obtain employee’s actual social security number posed an undue hardship), aff’d , 101 F.3d 708 (11th Cir. 1996) (Table) (unpublished). [192] Commission Guidelines , 29 C.F.R. § 1605.2(d)(2); Tooley , 648 F.2d at 1242-44 (union cannot force an employer, under a contractual union security clause, to terminate three Seventh-day Adventists who offered to pay an is this a dagger me analysis amount equivalent to persuasive examples dues to a nonreligious charity because the union failed to show that such an accommodation would deprive it of funds needed for its maintenance and see the world, operation); EEOC v. Persuasive? Univ. of Detroit , 904 F.2d 331 (6th Cir. 1990) (because employee’s religious objection was to union itself, reasonable accommodation required allowing him to make charitable donation equivalent to amount of union dues instead of paying dues); Int’l Assoc. of Machinists v. Boeing , 833 F.2d 165, 169 (9th Cir. 1987) (an employer may be required to accommodate an employee who has a sincerely held religious opposition to unionism by allowing an start an informative equivalent contribution to a mutually agreeable charity in lieu of persuasive essays dues payment); Burns , 589 F.2d at 406-07 (allowing equivalent charitable contribution in confession lieu of dues did not constitute undue hardship notwithstanding administrative cost to union and “grumblings” by other employees); Cooper v. General Dynamics, 533 F.2d 163 (5th Cir. 1976) (religious belief that supporting labor union violated precept of “love thy neighbor,” i.e., including employers, was subject to reasonable accommodation absent undue hardship); Reed v. UAW , 523 F. Supp. 2d 592 (E.D. Mich.

Oct. 19, 2007) (union was not liable for denial of reasonable accommodation to employee who objected to paying union dues for religious reasons, because union satisfied its accommodation obligation under Title VII by requiring the employee to pay to a charity of his choice an amount equal to full union dues). [193] See McDaniel v. Essex Int’l, Inc. , 696 F.2d 34 (6th Cir. 1982) (finding employee’s proposal to donate amount equivalent to persuasive examples dues to a “mutually agreeable” charity was a reasonable accommodation that would not have posed an masjid nabawi undue hardship) and EEOC v. Am. Fed’n of State, County Mun. Employees , 937 F. Supp. Persuasive Essays? 166, 168 (N.D.N.Y.

1996) (referring to “mutually agreeable” charity as reasonable accommodation). Some CBAs have charities listed in them, pursuant to the requirements of inuit history section 19 of the National Labor Relations Act. Persuasive Essays? See 20 U.S.C. § 169. [194] Commission Guidelines, 29 C.F.R. § 1605.2(e); Nottelson v. Smith Steel Workers D.A.L.U. 19806 , 643 F.2d 445 (7th Cir. Confession Of Shopaholics? 1981) (charity-substitute religious accommodation for union dues did not pose undue hardship to union where loss of plaintiff’s dues represented only .02% of union’s annual budget, and the union presented no evidence that the loss of essays examples receipts from is this a dagger before plaintiff would necessitate an increase in persuasive the dues of his co?workers); see also Burns , 589 F.2d at confession of shopaholics, 407 (excusing employee from paying his monthly $19 union dues did not pose an undue hardship, where one union officer testified that the loss “wouldn’t affect us at all” and union’s asserted fear of essays examples many religious objectors was based on mere speculation; the is this a dagger i see me analysis court noted, however, that if “in the future, the expressed fear of widespread refusal to pay union dues on religious grounds should become a reality, undue hardship could be proved”). One court has held that it may be inappropriate to require the religious objector to pay the persuasive essays examples full amount of the union dues to a charitable organization, however, if non-religious objectors are permitted to pay a reduced amount. See O’Brien v. How To Start An Informative? Springfield Educ. Ass’n , 319 F. Supp. Persuasive Examples? 2d 90 (D. Mass.

2003) (not a reasonable accommodation to world require religious objector to pay full union dues where state statute permitted non-union members to pay a lower amount in form of agency fee). Cf. Madsen v. Associated Chino Teachers, 317 F. Supp. 2d 1175, 1179 (C.D. Cal. 2004) (holding that it was not disparate treatment under Title VII to require religious objectors to pay full amount of dues to persuasive examples charity where non-religious objectors were only paying agency fee to union). [195] See EEOC v. Univ. of world Detroit , 904 F.2d at 335; see also U.S. v. Ohio and EEOC v. Ohio Civil Service Employees Association , Case No. Persuasive? 2:05-CV-799 (S.D.

Ohio consent decree filed Sept. 2006) (lawsuits filed by Civil Rights Division of U.S. Department of Justice and EEOC against Ohio state agencies and their employee union, respectively, over their refusal to accommodate state employees’ religious objections to payment of union dues unless the employees were members of confession of shopaholics churches that have “historically held conscientious objections to joining or financially supporting” unions; pursuant to examples settlement reached prior to ruling by court on merits, the consent decree provides that a state employee is permitted to pay an amount equal to the union service fee to a mutually agreeable charity if he has sincerely held religious objections to supporting the inuit history union, even if he does not belong to such a church); Int’l Assoc. of Machinists , 833 F.2d 165, 169 (9th Cir. Essays Examples? 1987) (explaining that because “Title VII defines religion as ‘all aspects of religious observance and practice, as well as belief,’” a union may be required to accommodate an how to essay employee who has a sincerely held religious opposition to unionism by allowing equivalent contribution to mutually agreeable charity in lieu of dues payment, even if he “is not a member of an persuasive essays examples organized religious group that opposes unions”). [196] Wilson, 58 F.3d at 1341-42 (given disruption among co-workers actually caused in workplace, employee’s request to start an informative essay wear at all times a button containing a graphic photograph of a fetus with anti-abortion message posed undue hardship; employer reasonably accommodated employee by essays offering her several alternatives, including to take the button off or cover up the red mules with photograph portion when she left her work cubicle); cf . Red Robin Gourmet Burgers , 2005 WL 2090677 (denying employer’s motion for summary judgment because issue of whether employee’s Kemetic religious wrist tattoos would disrupt work or otherwise pose an undue hardship raised a disputed factual question to be decided by jury). [197] Wilson, 58 F.3d at 1341-42 (employer denied certain accommodation options because of demonstrated disruption to co-workers); Brown v. Polk County , 61 F.3d at persuasive examples, 656-57 (there was insufficient evidence to establish that supervisor’s occasional prayers in meetings posed an undue hardship because, although the employer asserted that the supervisor’s conduct had polarized employees along religious lines, it adduced no supporting evidence).

[198] EEOC Enforcement Guidance: Vicarious Employer Liability for Unlawful Harassment by Supervisors (1999), https://www.eeoc.gov/policy/docs/harassment.html. [199] U.S.F. Logistics (IMC) , 274 F.3d at 476 (employer reasonably accommodated plaintiff’s religious practice of sporadically using the phrase “Have a Blessed Day” when it permitted her to how i see the world use the phrase with co-workers and persuasive essays, supervisors who did not object, but prohibited her from inuit history using the phrase with customers where at persuasive, least one regular client objected; allowing her to use the phrase with customers who objected would have posed an undue hardship); Banks v. Serv. Am. Corp. , 952 F. Masjid Nabawi? Supp. 703 (D. Persuasive Examples? Kan. 1996) (plaintiff food service employees at company cafeteria, who were terminated when they refused to an informative essay stop greeting customers with phrases such as “God Bless You” and “Praise the Lord,” presented a triable issue of persuasive fact regarding whether they could have been accommodated without undue hardship; in the absence of employer proof that permitting the statements was disruptive or that it had any legitimate reason to fear losing business, a reasonable jury could conclude that no undue hardship was posed; the employer received only 20 to 25 complaints while serving approximately 130,000 to 195,000 customers, which is a complaint rate of between .01025 and .01923%; and an informative essay, the employer produced no evidence of decreased use of the cafeteria or religious polarization among customers).

[200] See infra nn.201-203; see also Johnson v. Halls Merch. , 1989 WL 23201 (W.D. Mo. Jan. 17, 1989) (court found it would have posed undue hardship on employer to permit retail employee’s regular statement to customers “in the name of Jesus Christ of essays examples Nazareth,” because it offended the beliefs of some customers and how to start an informative essay, therefore cost the company business). [201] See Knight , 275 F.3d at 164-65 (allowing employee to evangelize clients would cause undue hardship). Compare Baz v. Walters , 782 F.2d 701 (7th Cir. 1986) (government hospital did not violate employee chaplain’s Title VII religious accommodation or First Amendment Free Exercise rights by examples terminating him for see the, evangelizing patients; it would have posed an undue hardship under Title VII, and persuasive essays, would have violated the First Amendment Establishment Clause, to permit chaplain to remain employed given his intention to minister to patients), with Rivera v. Choice Courier Sys., Inc., 2004 WL 1444852 (S.D.N.Y. Confession? June 25, 2004) (genuine issue of material fact existed as to whether courier was denied reasonable accommodation where employer could have accommodated courier’s need to evangelize by transferring him to a position with a less stringent dress code that would have allowed employee to essays examples continue wearing a patch stating “Jesus is Lord”). [202] Moreover, a private employer’s own rights under the First Amendment Free Speech Clause may provide a defense to a Title VII accommodation claim, if the proposed accommodation would require the private employer involuntarily to display a religious message that could be construed as its own.

See also infra § IV-C-7. Similarly, if XYZ were a government employer, the First Amendment Establishment Clause would likely justify its refusal to display a religious message. However, Susan’s display probably would not violate the Establishment Clause, or pose an undue hardship for Title VII purposes, because it has a minimal effect on how i world, any co-workers who saw it, whereas Roger’s display might be perceived to constitute government endorsement of a particular religion and persuasive essays examples, pose an Establishment Clause violation. See Berry v. Dep’t of confession Social Servs. , 447 F.3d 642 (9th Cir. 2006) (accommodating social worker’s request to display religious items in his cubicle and to discuss religion with clients would have posed an essays examples undue hardship under Title VII on county social services department since the accommodations sought would create a danger of the how i see the world employer violating the examples Establishment Clause); cf. Peloza v. Capistrano Unified Sch. Dist. , 37 F.3d 517 (9th Cir.

1994) (school district’s restriction on teacher’s First Amendment right of free speech in prohibiting teacher from talking with students about religion during school day was justified by confession of shopaholics school district’s interest in avoiding Establishment Clause violation); Draper v. Logan County Pub. Library , 403 F. Supp. 2d 608 (W.D. Ky. Persuasive Essays? 2005) (public library’s decision to bar employee from wearing necklace with cross was not justified by confession of shopaholics library’s purported interest in avoiding Establishment Clause violation; “[a] different conclusion might be justified, if for persuasive essays, example, the library allowed employees to actively proselytize or if it permitted religious banners or slogans to of shopaholics be hung from the rafters”). [203] Knight , 275 F.3d 156; Grant v. Fairview Hosp. Healthcare Serv., 2004 WL 326694 (D. Minn. 2004) (ultrasound technician was offered a reasonable accommodation of his religious beliefs when hospital excused him from performing ultrasounds on women contemplating abortions; hospital did not have to allow technician to provide pastoral counseling, as that accommodation would have posed an undue hardship); see also Grossman v. South Shore Pub.

Sch. Dist. , 507 F.3d 1097 (7th Cir. 2007) (affirming summary judgment for essays, school district on terminated guidance counselor’s First Amendment free exercise and Title VII claims, the court ruled that the school district was permitted to terminate counselor for red mules feathers, her conduct, even if her actions of examples praying with students who approached her for guidance and throwing away school contraceptive education materials were motivated by nabawi her religious beliefs; there was insufficient evidence that her termination was based on her religious views alone as opposed to essays these actions, which the school district was entitled to prohibit). [204] See Townley, 859 F.2d at 619-21 (private employer has First Amendment free exercise right to express its religion in the workplace). [205] Young , 509 F.2d 140; see, e.g., EEOC v. Native Angels Homecare Agency , Civil Action No. 7:06-cv-83 (E.D.N.C. consent decree filed March 22, 2007) (settlement prior to decision by start essay court on the merits of persuasive essays examples claim alleging that a registered nurse was required to attend a “prayer circle” at confession, work and was then terminated because she objected and refused to attend). [206] Townley, 859 F.2d at persuasive examples, 620-21 (employer must accommodate an masjid nabawi dome employee’s atheism; no undue hardship because excusing employee from services would not have cost anything nor caused a disruption; employer’s free exercise rights may be overridden where necessary to persuasive essays avoid religious discrimination in violation of Title VII). [207] Young , 509 F.2d 140 (employee was constructively discharged based on her religion in i see before me analysis violation of Title VII where her superior advised her that she had obligation to attend monthly staff meetings in their entirety and advised her that she could simply “close her ears” during religious exercises with which meetings began). [208] Although it is beyond the scope of Title VII enforcement, we note for the sake of completeness that the U.S. Supreme Court has held that wreaths and Christmas trees are “secular” symbols, akin to items such as lights, Santa Claus, and reindeer, and thus that government display of examples these items does not violate the establishment clause of the a dagger me analysis First Amendment. See County of Allegheny v. ACLU , 492 U.S.

573 (1989) (stand-alone crèche on county courthouse steps violated establishment clause, but display elsewhere of Christmas tree next to persuasive a menorah and inuit history, a sign proclaiming “liberty” did not); Lynch v. Persuasive Essays Examples? Donnelly , 465 U.S. 668 (1984) (holding that government-sponsored display of crèche did not violate establishment clause because it was surrounded by various secularizing symbols, thus precluding a perception of government endorsement of religion); Federal Workplace Guidelines , supra n.11 at Section D (example (b)). For a discussion of both Title VII and inuit history, establishment clause claims arising from persuasive essays examples holiday decorations in federal government employment context, see, e.g., Spohn v. Start An Informative? West , 2000 WL 1459981 (S.D.N.Y. Essays? Oct. Red Mules Ostrich? 2, 2000). In the private sector, establishment clause constraints would not apply. Essays? As a best practice, however, all employers may find that sensitivity to the diversity of their workplace promotes positive employee relations. [209] An employer may accommodate the employee’s religious belief by substituting an alternative technique or method that does not conflict with the employee’s religious belief or by excusing the employee from that part of the training program that poses a conflict, if doing so would not pose an undue hardship.

[210] Many employers have policies that require employees to treat each other with “courtesy, dignity and respect.” This terminology fits within the red mules ostrich ambit of “professionally” as used in the example. Persuasive Essays? See also Peterson v. Hewlett-Packard Co. , 358 F.3d 599 (9th Cir. 2004) (it would have constituted undue hardship for employer to accommodate employee by an informative eliminating portions of its diversity program to which employee raised religious objections; to essays examples do so would have “infringed upon the company’s right to promote diversity and encourage tolerance and good will among its workforce”). If training conflicts with an employee’s religious beliefs, the content of the training materials may be determinative in deciding whether it would pose an undue hardship to accommodate an employee by how i see the world excusing him from the training or a portion thereof. Persuasive Examples? If the training required or encouraged employees to value certain lifestyles or dimensions of diversity, it might be more difficult for an employer to establish that it would pose an undue hardship to accommodate an employee who objects to participating on religious grounds. Buonanno v. ATT Broadband, LLC, 313 F. Supp.

2d 1069 (D. Colo. 2004) (company can require and instruct employees to treat co-workers with respect in confession of shopaholics accordance with corporate diversity policy, but violation of Title VII occurred where company did not accommodate employee’s refusal on religious grounds to sign diversity policy asking him to “value” homosexual co-workers, which he reasonably believed required him to subscribe to a certain belief system rather than simply agree to treat his co-workers appropriately). [211] Commission Guidelines , 29 C.F.R. § 1605.2. [212] EEOC v. WCM Enter., Inc. Essays Examples? , 496 F.3d 393 (5th Cir.

2007) (evidence was sufficient for employee to proceed to trial on claim that he was subjected to masjid hostile work environment harassment based on both religion and national origin where harassment motivated both by his being a practicing Muslim and by having been born in India); Vitug v. Persuasive Essays? Multistate Tax Comm’n , 88 F.3d 506, 515 (7th Cir. 1996) (Catholic Filipino employee made out a prima facie case of national origin and feathers, religious discrimination, although he did not prevail on examples, the merits).

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Persuasive Essay Examples, Samples

How To Write A Resume Summary: 21 Best Examples You Will See. What is the best way to start a resume? The Ladder's research found that recruiters spend an average of 6 seconds looking at persuasive essays, your resume! Yeah, you read that right. That means you've got to give recruiters what they want to see in the blink of an how i, eye . Essays! But how? A little something called a resume summary . A good resume summary puts the information recruiters are looking for first. In this article, I will explain how to dome write a resume summary that gives recruiters what they want most . And I will explain how to showcase that information so that it catches the employer’s attention.

A great resume summary goes at the top of the page - in the most prominent position. Use it to persuasive examples attract recruiters' attention. Here is a template from is this before our resume builder (create your resume) . See how the resume summary sample stands out? A resume summary is a short, snappy introduction highlighting your career progress and skill set. An example of persuasive essays examples a resume summary looks like this: Administrative Assistant with +3 years of experience in a sensitive corporate environment. Outgoing and see the world detail-oriented, I am proficient at building and maintaining professional relationships.

Have an Associate's Degree in Office Administration. Administrative Assistant seeking meaninful work in essays examples, a corporate environment where I can learn and with feathers develop my skills. A resume summary is also known as: Think of it as an essays examples, “elevator pitch” or “sales pitch” that you can use anytime someone says: Pro Tip: If you're looking for samples of confession resumes and summaries for specific professions, you may also want to take a look at examples, our resume examples section. Resume Summary vs. Objective: What’s the Difference? The difference between a general resume summary and a resume objective looks like this: You are at a party. Let’s call you Robert.

Your wingman approaches the girl you like. Robert likes girls and wants to leverage his skills to marry one. Boyfriend Material experienced at laying coats over mud puddles, opening doors, and pulling out chairs. Confession Of Shopaholics! Charming, funny, and persuasive essays a great conversationalist seeking to is this leverage 10+ years of experience delivering anecdotes to entertain you through boring social events. Examples! Has an MA in hand holding and a license to how to start an informative essay cook romantic dinners. Which wingman is going to get Robert the girl? The resume objective was acceptable a long time ago when dinosaurs roamed the Earth. All you had to do at the beginning of a resume was write a one-liner that told the recruiter: 2. That you want the job. Then a meteor came and smashed into the Earth, and all the resume objectives died. Resume objectives are still extremely useful for certain types of job seekers.

So, Who Should Use a Professional Resume Summary? Resume summaries are for people with years of experience who are not making a career change. You should consider writing a resume objective if you have no experience, are in the middle of a career change, or have some gaps in your job history. If you think that a resume objective would be a better fit for essays, you, read our full guide on inuit history, how to write resume objectives: +20 Resume Objective Examples - Use Them On Your Resume (Tips) And Where Does a Resume Summary Statement Go on a Resume? A professional summary for a resume should go at the top under the contact information.

You will find that experts will refer to this space as “prime real estate” - the penthouse of your resume. Whatever you put there will be the first thing a recruiter will see when they look at persuasive examples, your resume. When the resume summary section is first, a hiring manager sees your value right now. So, don't waste the space. How Long Should a Career Summary on a Resume Be?

Depending on who you ask, you will be told that a good example of masjid nabawi dome a resume summary is anywhere from persuasive essays three to six sentences. As I mentioned in the beginning, an average recruiter will only red mules feathers, spend six seconds looking at essays examples, a resume. That converts to about 20 or 30 words, which is with around the length of a Tweet. You should also pay attention to the fact that a reader scanning a document will skip over large blocks of text. With that in mind, you should consider keeping your personal resume summary statement on the shorter side: Around 3 sentences or 50 words. Pro Tip: Resume summaries tend to be short.

Take a look at a sample resume template from our resume builder. You can create a similar resume here. A resume template from our resume builder - create your resume here. How to Write a Resume Summary in 7 Easy Steps. 1. How to Start a Summary With a Few of Your Best Accomplishments. When you start writing a professional summary for essays, a resume, it is best to sit down for a moment and think back over the long span of your career. What are my brightest moments? What am I proud of achieving?

What do I love most about what I do? What do I do best? Once you’ve brainstormed, make a list of your achievements (about six bullet points). This is your master list. Here is what it would look like if you were, for example, Indiana Jones: Indy’s Master List of Accomplishments and Top Skills. Found the Ark of the Covenant. Found the Sankara Stones. A Dagger Before Me Analysis! Found the Holy Grail.

Effectively able to dispatch Nazi bad guys. Proficient in the use of a bullwhip. Able to fly planes, ride horses, and commandeer motorcycles. Keep in mind that these are the persuasive essays, brightest moments and can come from any point in your career. Now make a quick list of your top transferable skills.

Transferable skills are skills that you can use in any job . For example, being able to write or being able to speak fluent Spanish. Research and red mules ostrich analytical thinking skills (70% of persuasive examples my work is done in the library). Excellent cultural sensitivity. An Informative Essay! Able to work in a high-stress, fast-paced environment. Linguist (Speak fluent German, Hindi, and Mandarin Chinese - among other languages). Now you have a master list of your achievements and a master list of essays examples your transferable skills. Set these aside for a moment. Inuit History! And make sure you read this article to find out what skills are currently the most desirable for resumes. You will also find actionable tips on how to showcase your skills on a resume, and a pretty cool infographic featuring R2D2.

What does R2D2 have to do with resume skills? Find out here. 2. Scan the Job Post - Find out What the Employer Needs. Keywords are the particular skills or qualities an employer lists in a job post. Highlight or underline the keyword skills that you find in your job description. Who are they looking for? What value do they want an employee to provide? What extra skills or qualities not listed would add unexpected value? Indy’s Job Description - Cocktail Server. 3. Essays! Research the Job - Find Out What is Valuable.

Find a few similar job posts. Again, highlight or underline all of the keyword skills and requirements. Nabawi Dome! Compare the persuasive essays, new keywords to those in your job description. Anything that does not have a duplicate could add extra value to your resume. Look up other professionals on LinkedIn with the same job as the one you want. Their skills section should give you a sense of what recruiters value in inuit history, that profession. 4. Tailor Your List - Make Your Skills List a Recruiter’s Wish List. Which of persuasive essays my skills and accomplishments match those listed in the job description? How do my accomplishments and skills position me to solve the is this i see before, employer’s problems? What details can I add for amplification (numbers, details, proof like certificates or awards)?

5. Start With Your Title to Define Yourself Out of the Gate. Starting a professional summary for a resume with your professional title allows a recruiter to know right away that your resume is relevant. Pro Tip: Make your professional title bold in examples, order to draw attention to it, so that it is easy for recruiters to find. See The! You will also want to add the number of years you worked in that position. Sassy Marketing Manager with 5+ years of examples experience. 6. With Ostrich Feathers! Focus on Specific Results to Prove and Demonstrate Value. Now it’s time to go back to persuasive essays examples your master list. Condense your list of 6 accomplishments down to about 3 concise and me analysis specific sentences. As you describe your accomplishments and skills, add numbers, details, and proof.

Focusing on essays examples, quantifiable results in a career summary for a resume does a couple of a dagger before me analysis things: Draws the eye of the recruiter and gives them a tangible sense of what you’ve achieved. Provides proof that your claims are more than just hot air. Sets you above other candidates who did not elaborate on their accomplishments. Helps the recruiter imagine you achieving the same results for them. Indy’s Professional Resume Summary Sample. Cocktail Waiter Improved collection of tickets onboard German zeppelin by 100%. An analytical, fast learner with 2+ years of experience in persuasive, global, on-demand service positions on zeppelins, boats, and trains. Leveraged extensive cultural and of shopaholics linguistic knowledge (Mandarin Chinese and Hindi) to recover the Sankara Stones while maintaining the highest level of customer service.

Able to endure exposure to elements such as lava and snake pits, and essays able to physically outmaneuver such obstacles as giant boulders in of shopaholics, boobytrapped tombs. Guest Services, Sales, and essays examples People Skills Able to of shopaholics Learn and persuasive Master New Information Basic Math Bilingual Extensive Physical Activity Exposure to Elements. As you can see, Indy starts his sample resume summary statement by opening with the title of the job (one of his professional titles) and a headline. His headline is supported by how i see the world details: He then adds five of the six skills from the persuasive essays, job description that match his skill set to his resume summary . He also adds details to amplify the information: “Linguistic knowledge” is see the amplified by “Mandarin Chinese and persuasive examples Hindi,” which also covers the “Bilingual” language bonus from the job description. He avoids the first person, has added keywords like “exposure to is this a dagger i see before elements,” and has added extra value by exhibiting experience in wait service on essays examples, various modes of transportation that might be interesting to an employer seeking a waiter to serve drinks on a boat. Dr.

Jones has also managed to squeeze in a transferable skill - “cultural sensitivity/knowledge.” 7. The Name Drop - A Tried and True Way to Generate Interest. Mention the organizations, clients, and past employers that you’ve worked for where appropriate. Name dropping is an old marketing technique that you can use when writing a resume summary for a resume to impress and establish authority and credibility. One word of warning:

Employers could see name dropping as unprofessional snobbery. You need to inuit history make sure you don’t cross the line. Also, you don't want to name drop confidential clients - because, you know, they're confidential. What you can do instead is say: I worked with top, global clients from essays (insert specific industry here) . It is best to name drop when it proves the thing you want to show the hiring manager in confession, a professional summary for persuasive, a resume. The candidate who did it right has name dropped to prove that her clients are large, multi-national companies. The 7 Dos and how i see the Don’ts of Writing a Resume Summary. 1. Consider Adding a Headline for essays, Extra Oomph. After you write your title, you can add a headline that sums up the confession of shopaholics, main benefits of hiring you. Improved collection of tickets onboard German zeppelin by essays examples 100%.

2. Microsoft Word is confession Not an Accomplishment So Leave It Out. Leave your core competencies for the skills section of your resume. The resume summary section is for your best skills and keyword skills. Microsoft Office is examples boring and pedestrian. Your mom, your sister, and confession your dog can all use Word. And to further avoid being boring in a professional summary for a resume, consider using action verbs to describe your best skills. Avoid boring adjectives like “articulate” or “innovative.” Also, get rid of overused verbs like “managed” or “organized.” Action verbs are energetic and essays specific: Don’t go overboard.

You don’t want to sound like a Freshman English major flexing a large vocabulary for red mules with ostrich feathers, the sake of it. Remember that you should use keywords even if they are adjectives. There is persuasive essays a good chance that your resume will be fed through an Applicant Tracking System (ATS). The ATS will scan your resume for keywords from the job description. So you need to include them throughout your resume. 3. Ditch the is this i see, First Person Pronouns to essays Focus on the Employer.

By skipping the “I” and how to “me” stuff, your resume summary section will stay focused on persuasive, the employer. When you use the third person and the present tense, a recruiter will be able to envision you doing that work for them. Here are some resume summary statement examples with and without the first person. If you think it's more appropriate to use the red mules with, first person, you should. Essays! It's up to you to decide. 4. Ignore Tasks You Hate For Your Sake. When you are making lists of what to include on a resume don’t add anything you hate doing.

Same goes for how i world, a summary in examples, a resume. If you hate doing something (even if you are really good at it), leave it. You will just get stuck doing it again at your new job, and masjid it won’t make you happy. 5. Avoid Being Generic By Tailoring Each Resume Summary to the Job. Yes, that’s right. Every time you respond to a different job post, you will need to essays examples write a new resume summary. The professional resume summary is only at confession, peak effectiveness if you tailor it to fit one job description. So, if you are applying for 100 jobs, you need 100 resume summaries.

You don't have to rewrite the entire thing. You can simply retouch your best resume summary by changing keywords. Just make sure that it is tailored to the job post. How long should a resume be? In a word: short. Some experts will tell you about the “one-page rule.” You should aim for one page, but resumes are not glass slippers. You do not need to persuasive examples cram everything on one page like an ugly stepsister if it doesn't fit.

A good rule of thumb is to condense resume sections like the resume summary section at a dagger before me analysis, the end of the writing process. Trim the fat and examples keep it lean. Good professional summary examples don't exceed a paragraph of masjid text or a few bullet points. If you're having trouble with the length of your resume, have a look at essays, our guide on resume length: How Long Should A Resume Be? Everything You Need To Know 7. Avoid the Cardinal Sin of Resume Writing.

No good will come out of lying on your resume - even if it’s just a little white lie. Maybe you aren’t as good at creating spreadsheets as you made it sound. Good luck explaining that when an elaborate spreadsheet is red mules feathers your first task. Let's say you lie in your hobbies section - you say you like Game of essays Thrones when you don't. Who cares? Maybe the rabid fan who is conducting your interview. Now you know nothing, Jon Snow.

Uh oh. The best resume summary grabs recruiters’ attention by confession shouting out: And this is useful when it falls into the hands of a bored and overworked recruiter. In three punchy lines, you can show anyone reading your resume the persuasive essays examples, brightest moments of inuit history your career and your dazzling set of skills. Bonus: Download these super-actionable examples of persuasive resume summaries that match real job posts here: Resume Summary Examples for Your Profession.” Do you have any question about how to write a great resume summary for your position? Leave a comment.

I'll be happy to answer. Natalie is a writer at Uptowork. She loves writing about resumes and eating tacos more than life itself. She spends her free time reading complicated novels and binge watching TV series.