In
Small v. Memphis Light, Gas & Water, (6th Cir., March 12, 2020), the U.S. 6th Circuit Court of Appeals affirmed the dismissal of an employment discrimination claim by a Jehovah's Witness. The court concluded that Memphis Light adequately accommodated their employee's religious beliefs when it allowed him to swap shifts with other employees. Judge Thapar filed a concurring opinion, criticizing the Supreme court's
Hardison decision.