Telfair v. Federal Express Corp., 934 F. Supp. 2d 1368

FedEx hired Travis Telfair in 1991 and Garrett Telfair in 1995; both are African-American Jehovah’s Witnesses.
Plaintiffs reported to operations manager Matthew Lemke and senior manager Joe Mauceri, who knew their religious beliefs.
No disciplinary actions against either plaintiff for performance; no derogatory comments about religion were shown.
FedEx created a seniority-based redeployment system; participants could bid for new positions or take a 90-day unpaid leave.
In Feb 2009, FedEx redeployed five part-time morning couriers, including the Telfairs, to a Tuesday-Saturday shift; two Caucasian couriers at same location were not redeployed.
The plaintiffs requested religious accommodations to be off Saturdays; FedEx refused, directing redeployment and offering other positions; plaintiffs declined and later were placed on unpaid leave and deemed to have voluntarily resigned.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Prima facie race discrimination	Tel-fairs claim failure to identify similar comparators outside protected class.	FedEx shows lack of similarly situated non-Jehovah’s Witness comparators willing to accept redeployment.	No prima facie discrimination shown; summary judgment for FedEx on race claim.
Prima facie religious discrimination	Tel-fairs claim comparators outside religion were treated more favorably.	No suitable comparators outside protected class; redeployment consistent with policy.	No prima facie religious discrimination shown; summary judgment for FedEx on religion claim.
Adverse action for discrimination	Transfer to unpaid leave and later termination constitute adverse action.	Action motivated by accommodation of religious beliefs; not an adverse action.	Termination at end of leave is adverse action; but no discrimination established due to lack of valid comparators.
Religious accommodation	Saturday field ministry is bona fide religious belief requiring accommodation.	Accommodations offered were reasonable and consistent with seniority system; no undue hardship.	FedEx’s accommodations were reasonable as a matter of law; summary judgment for FedEx on FCRA/Title VII accommodation claim.

McDonnell Douglas Corp. v. Green, 411 U.S. 792 (Supreme Court, 1973) (establishes the prima facie case framework for discrimination claims)
Texas Dept. of Community Affairs v. Burdine, 450 U.S. 248 (Supreme Court, 1981) (burden shifting after prima facie case)
Trans World Airlines, Inc. v. Hardison, 432 U.S. 63 (Supreme Court, 1977) (reasonable accommodation limits under seniority systems)
Union Independiente de la Autoridad de Acueductos y Alcantarillados de Puerto Rico v., 279 F.3d 49 (1st Cir. 2002) (separates sincerity of beliefs from doctrinal adequacy in Title VII cases)
United States v. Seeger, 380 U.S. 163 (Supreme Court, 1965) (test for sincerity of religious belief)
Reyes v. New York State Office of Children and Family Services, 2003 WL 21709407 (S.D.N.Y. 2003) (sincerity-of-belief inquiry in religious discrimination cases)
E.E.O.C. v. Joe’s Stone Crabs, Inc., 296 F.3d 1265 (11th Cir. 2002) (direct versus indirect evidence; framework for discrimination claims)
Hamilton v. Southland Christian School, Inc., 680 F.3d 1316 (11th Cir. 2012) (distinguishes direct vs. indirect evidence in discrimination)
Beadle v. Hillsborough County Sheriff’s Dept., 29 F.3d 589 (11th Cir. 1994) (reasonableness of accommodations under Title VII)
U.S. Airways, Inc. v. Barnett, 535 U.S. 391 (Supreme Court, 2002) (seniority systems and accommodation conflict analysis)