Sunday, October 12, 2014

Collateral Estoppel Bars Title VII Religious Accommodation, But Not Retaliation, Claim

In Mathis v. Christian Heating & Air Conditioning, Inc., (ED PA, Oct. 7, 2014), plaintiff Paul Mathis, an atheist, was fired from his position as a sheet metal installer when he insisted on covering with tape his employer company's mission statement printed on the back of his identification badge. The statement read in part: "This company is not only a business, it is a ministry. It is set on standards that are higher than man’s own. Our goal is to run this company in a way most pleasing to the lord...." Mathis claimed that the mission statement was an attempt by the company to force its religious ideology on its employees.

In this Title VII action, a Pennsylvania federal district court held that Mathis was barred by collateral estoppel from proceeding with his Title VII claim of failure to accommodate his religious beliefs. In a prior state court worker's compensaton proceeding, the court held that Mathis had not shown any actual conflict between a sincere religious belief and the employer's requirement, nor had he requested an accommodation. Thefederal district court went on to hold, however, that Mathis was not barred by collateral estoppel from moving ahead with his claim under Title VII for unlawful retaliation against him for opposing what he saw to be religious discrimination.