In Leone v. Essex County Prosecutor's Office, (D NJ, Sept. 23, 2021), a New Jersey federal district court ruled against an assistant prosecutor in the Essex County Prosecutor's Office who sought a religious accommodation that would allow him to continue to work from home indefinitely as pandemic remote-work schedules were phased out. Plaintiff claims that his religion "'requires him to pray, including aloud and spontaneously, throughout each day,' preferably in his backyard to access 'peace and solitude.'" Plaintiff rejected numerous proposed accommodations that would allow him to pray while at his office. The court applied rational basis review to plaintiff's 1st Amendment claim, concluding that defendants had articulated "a myriad of reasons" justifying their denial of plaintiff's requested accommodation. It also concluded that there had not been a violation of the New Jersey Law Against Discrimination.
