Employer Must Accommodate Sincere Religious Belief Even If Not Part of Formal Religion's Doctrines

In Telfair v. Federal Express Corp., (SD FL, March 28, 2013), a Florida federal district court held that two Jehovah's Witness employees could establish a prima facie case under Title VII of the 1964 Civil Rights Act of failure to accommodate their sincerely held religious beliefs even though their beliefs were not part of formal Jehovah's Witness doctrine.  It is sufficient that plaintiffs subjectively believed that the practice of field ministry and engagement in Bible study on Saturdays was a necessary expression of their religion. However, the court granted defendant's motion for summary judgment, finding that Federal Express had offered plaintiffs reasonable accommodation of their need not to work on Saturdays.