Equal Employment Opportunity Commission v. Rent-A-Center, Inc.
917 F. Supp. 2d 112
D.D.C.2013Background
- EEOC sues RAC under Title VII for failing to reasonably accommodate Charles's Seventh Day Adventist Sabbath on Saturdays.
- Charles, a Store Manager, periodically worked Saturdays; he informed RAC of religious conflict and was initially told accommodation wouldn’t be allowed.
- RAC offered a temporary accommodation by transferring Charles to the Alabama Avenue store and not working Saturdays starting Sep 2006.
- Following a realignment, regional leadership concluded RAC could not continue the accommodation; Charles was terminated in Feb 2007 for refusing to work Saturdays.
- RAC argues Saturdays are the busiest, critical day and Store Manager role is uniquely essential; EEOC argues the accommodation caused little disruption; court grants summary judgment for RAC and denies fees.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Can RAC accommodate Charles without undue hardship? | EEOC contends accommodation is possible. | RAC argues accommodation would impose undue hardship. | Yes; court finds undue hardship and grants summary judgment for RAC. |
| Is there a prima facie Title VII religious discrimination claim? | EEOC asserts Charles was terminated for religious reasons. | RAC contends termination was for refusal to work Saturdays. | Not reached as RAC prevails on undue hardship ground. |
Key Cases Cited
- Trans World Airlines, Inc. v. Hardison, 432 U.S. 63 (U.S. 1977) (undue hardship standard governs religious accommodations)
- Bruff v. N. Miss. Health Servs., Inc., 244 F.3d 495 (5th Cir. 2001) (undue hardship considerations and empirical data not always required)
- Anderson v. General Dynamics Convair Aerospace Div., 589 F.2d 397 (9th Cir. 1978) (employer not required to implement accommodations that create undue burden)
- Draper v. U.S. Pipe & Foundry Co., 527 F.2d 515 (6th Cir. 1975) (consideration of burden borne by other employees in accommodation)
- EEOC v. Firestone Fibers & Textiles Co., 515 F.3d 307 (4th Cir. 2008) (diversity of opinions on what constitutes undue hardship)
- Christiansburg Garment Co. v. EEOC, 434 U.S. 412 (U.S. 1978) (fee-shifting standards for frivolous or groundless suits)