3rd Circuit: Federal Employee Cannot Use RFRA For Employment Discrimination

In Francis v. Mineta, (3rd Cir., Oct. 10, 2007), the U.S. 3rd Circuit Court of Appeals held that Title VII of the 1964 Civil Rights Act is the exclusive route that a federal employee may use to assert a claim of religious discrimination in employment. The court held that a Transportation Security Administration screener fired for wearing dreadlocks in violation of the TSA's grooming policy cannot use the Religious Freedom Restoration Act as a way of avoiding Title VII's requirement that administrative remedies be exhausted before a lawsuit is filed.