Sikiru Adeyeye v. Heartland Sweeteners, LLC
2013 U.S. App. LEXIS 15610
| 7th Cir. | 2013Background
- Adeyeye, a Nigerian-born U.S. permanent resident, requested leave from Heartland Sweeteners in 2010 to travel to Nigeria and perform his deceased father's burial rites, describing participation as "compulsory" and spiritually necessary.
- He submitted two written requests (one for five weeks, later modified to one week vacation + three weeks unpaid leave); Heartland denied the requests and he nonetheless traveled and performed the rites.
- Upon returning and reporting to work, Heartland terminated Adeyeye for being absent without available earned time under its attendance policy.
- Adeyeye sued under Title VII alleging failure to accommodate his sincerely held religious beliefs; the district court granted summary judgment to Heartland on the ground Adeyeye failed to give notice that his leave was religious in nature.
- The Seventh Circuit reviewed de novo and examined notice, sincerity, causation, and undue hardship; it reversed the district court and remanded, finding genuine disputes of material fact on each key element.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Notice of religious nature of leave request | Adeyeye's letters explicitly referenced funeral rites, "compulsory" participation, spiritual consequences, animal sacrifice — sufficient to notify Heartland | Heartland argued the letters did not fairly notify it the request was religious and plaintiffs failed to invoke a clear religious script | Court: Letters were sufficient to create a genuine factual dispute on whether Heartland had notice; summary judgment on notice was improper |
| Sincerity / personal religious belief | Adeyeye asserted the rites were part of his sincerely held religion (blend of Christianity and family customs) and he felt spiritually compelled to perform them | Heartland argued Adeyeye acted from filial duty or his father’s beliefs, not his own sincerely held religion | Court: Evidence (deposition, declaration, conduct, financial risk) sufficed for a jury to find Adeyeye held sincere religious beliefs; sincerity is for factfinder |
| Causation (termination because of religious observance) | Adeyeye contended he was fired for being absent to observe religious rites; termination letter cited unauthorized absence | Heartland contended termination resulted from policy-based absence, not religious animus | Court: Causation was established as a factual issue — he was absent for religious observance and fired as a result; cannot be resolved for defendant at summary judgment |
| Undue hardship (reasonableness of unpaid leave) | Adeyeye requested one week vacation + three weeks unpaid leave; unpaid leave is a recognized accommodation and Heartland’s staffing (high turnover, temporary pool) showed no inevitable undue hardship | Heartland argued any disruption or cost (rearranging, substitutes) imposed undue hardship; cited de minimis language from Hardison | Court: Heartland failed to prove undue hardship as a matter of law; evidence of turnover and temporary staffing creates a factual dispute; voluntary termination offer was not a reasonable accommodation |
Key Cases Cited
- United States v. Seeger, 380 U.S. 163 (defining religion for federal exemption contexts)
- Redmond v. GAF Corp., 574 F.2d 897 (7th Cir. 1978) (religion includes sincerely held personal beliefs; notice and sincerity framework)
- Porter v. City of Chicago, 700 F.3d 944 (7th Cir. 2012) (elements for failure-to-accommodate claim)
- Baz v. Walters, 782 F.2d 701 (7th Cir. 1986) (burden on employer to prove undue hardship)
- Anderson v. Liberty Lobby, Inc., 477 U.S. 242 (summary judgment standard)
- Ansonia Board of Education v. Philbrook, 479 U.S. 60 (unpaid leave as reasonable accommodation)
- Trans World Airlines, Inc. v. Hardison, 432 U.S. 63 (seniority systems and undue hardship discussed; "de minimis" language relied upon by employers)
- EEOC v. Ilona of Hungary, Inc., 108 F.3d 1569 (7th Cir. 1997) (termination for religious observance and undue hardship allocation)
- Reed v. Great Lakes Cos., 330 F.3d 931 (7th Cir. 2003) (notice requirement; employers not charged with detailed knowledge of sect-specific practices)
- Thomas v. Review Bd. of Indiana Employment Sec. Div., 450 U.S. 707 (courts should not dissect religious beliefs; sincerity inquiry limited)
- Grayson v. Schuler, 666 F.3d 450 (7th Cir. 2012) (sincerity and imperfect observance do not defeat protection)
- Vinning-El v. Evans, 657 F.3d 591 (7th Cir. 2011) (personal religious faith entitled to protection)