777 F.3d 362
6th Cir.2015Background
- Yeager sued FirstEnergy under Title VII and Ohio Rev. Code ch. 4112, alleging religious discrimination because he refused to provide a Social Security number based on sincerely held religious beliefs.
- He sought monetary and injunctive relief for the employer’s refusal to hire or termination for not supplying an SSN.
- FirstEnergy contended it was required by federal law to collect employee SSNs and thus could not accommodate Yeager’s refusal.
- The district court dismissed Yeager’s complaint under Fed. R. Civ. P. 12(b)(6) for failure to state a claim.
- The Sixth Circuit reviewed de novo and addressed whether an employer must accommodate a religious practice when the accommodation would violate federal law.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Title VII/Ohio law requires accommodation when accommodation would violate a federal statute | Yeager: refusal to provide SSN is protected religious practice; employer must accommodate | FirstEnergy: collection of SSNs is mandated by federal law, so accommodation would force violation of statute | Court: Employer need not accommodate where accommodation would require violating federal law |
| Whether failure to provide SSN is an "employment requirement" for prima facie claim | Yeager: his religious belief conflicted with employer requirement | FirstEnergy: SSN collection is a statutory requirement, not a mere employment rule | Court: SSN collection is a legal requirement that defeats prima facie claim |
| Whether employer must show "undue hardship" if prima facie established | Yeager: burden shifts to employer to show undue hardship | FirstEnergy: violating federal statute is per se undue hardship | Court: violating federal law constitutes undue hardship — employer not liable |
| Whether district court improperly considered outside materials | Yeager: district court relied on materials beyond the pleadings | FirstEnergy: identification of applicable federal statute is appropriate judicial notice | Court: treating the IRS requirement as a legal matter was proper; no improper reliance on outside facts |
Key Cases Cited
- Abbott v. Crown Motor Co., 348 F.3d 537 (6th Cir. 2003) (same analysis applies to Title VII and Ohio Chapter 4112 religious-discrimination claims)
- Tepper v. Potter, 505 F.3d 508 (6th Cir. 2007) (elements of prima facie religious discrimination claim)
- Smith v. Pyro Mining Co., 827 F.2d 1081 (6th Cir. 1987) (framework for religious accommodation claims)
- Sutton v. Providence St. Joseph Med. Ctr., 192 F.3d 826 (9th Cir. 1999) (accommodation that violates federal law imposes undue hardship)
- Weber v. Leaseway Dedicated Logistics, Inc., 166 F.3d 1223 (10th Cir. 1999) (same conclusion regarding federal-law conflict)
- D’Ambrosio v. Marino, 747 F.3d 378 (6th Cir. 2014) (standard of review and pleading plausibility)