In Zienni v. Mercedes-Benz, (11th Cir., Dec. 22, 2025), the U.S. 11th Circuit Court of Appeals rejected a claim by a Muslim employee of Mercedes-Benz that he had been denied a religious accommodation in violation of Title VII. The court said in part:
... Zienni worked on a moving assembly line ... where he was given a scheduled lunch break and two other scheduled breaks. As a practicing Muslim, Zienni was required to pray five times a day at predetermined times, based on the sun’s position in the sky. The times to pray changed daily and often fell outside the scheduled breaks. When it was time to pray, without specific permission from a supervisor, Zienni would flag a team leader down who would either personally cover Zienni’s station or have a coworker do so. A supervisor with MBUSI, not Zienni’s team leader, observed Zienni praying during an unscheduled break and said that he would not be allowed to take those breaks—an explicit denial of his religious accommodation. Despite this conversation, Zienni kept taking unscheduled breaks, never missed a prayer, and was never disciplined....
Zienni argues that he experienced harm because he was exposed to the risk of discipline for taking additional breaks. But MBUSI never disciplined or threatened to discipline Zienni. Further,... his ability to take unscheduled breaks was not a term or condition of employment for Title VII purposes. Zienni rests on a speculation about what would have happened if he was caught praying during an unscheduled break.... Thus, any risk of discipline that Zienni experienced was too speculative to show a change in a term or condition of his employment.
The court also rejected Zienni's argument that the psychological harm he suffered constituted a Title VII violation.
