7th Circuit: Factual Issue Remains On Whether Employer Had Notice That Leave Request Was Religious In Nature

In Adeyeye v. Heartland Sweetners, L.L.C., (7th Cir., July 31, 2013), the U.S. 7th Circuit Court of Appeals reversed a district court's summary judgment for defendant in a Title VII religious accommodation case. The request by plaintiff, a native of Nigeria, to take several weeks of unpaid leave to travel to Nigeria to lead his father's burial rites was refused by his employer. The Court of Appeals rejected the district court's finding that the employer did not have notice of the religious nature of the request. It held that a genuine issue of material fact remained, saying:

We recognize, of course, that the religious beliefs and practices Adeyeye referred to are not as familiar as beliefs and practices closer to the modern American mainstream. But the protections of Title VII are not limited to familiar religions.