Massachusetts High Court Lets Rastafarian Go To Trial Against Jiffy Lube

In Brown v. F.L. Roberts & Co., Inc., (MA Sup. Jud. Ct., Dec. 2, 2008), the Massachusetts Supreme Judicial Court rejected defendant's motion for summary judgment and ordered to trial a case in which a Rastafarian sought an exemption from an employer's grooming policy. Plaintiff, Bobby Brown, alleged religious discrimination in violation MGL c. 151B, § 4(1A) after Jiffy Lube told the lube technician that he could only work in the lower bay, where there was no customer contact, because he wore a beard and long hair. The statute requires an employer to accommodate an employee's religious practices unless accommodation would impose an undue hardship. The court held that Jiffy Lube must show more than merely a non-economic cost to its image to prove undue hardship. It also held, however, that Jiffy Lube is entitled to a trial on whether working in the lower bay was a reasonable accommodation of Brown's religious needs. The Quincy Patriot Ledger and the AP report on the case.