Title VII Pre-Empts RFRA In Employment Discrimination Case

In Francis v. Ridge, (D VI, Dec. 27, 2005), Albion Francis claimed that the Transportation Security Administration's grooming policy for uniformed airport screening officers violates his free exercise rights as protected by the Religious Freedom Restoration Act. Francis wears his hair in dreadlocks for religious reasons. The federal district court for the Virgin Islands held that Title VII of the 1964 Civil Rights Act pre-empts RFRA in employment discrimination cases so that plaintiff was required to follow the exhaustion requirements of Title VII before filing an employment discrimination complaint.