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Conflict Between Workplace Ethics Course and Religion Goes Forward

Deluxe Corporation requires all of its employees to complete an online Ethics Compliance course. Employees must respond to multiple choice questions correctly or they will not be able to proceed to the next question. When Frederick Brennan went to take his course, he had a problem with one of the questions. He was required to respond to questions about transgender issues and his choice of response was not correct according to the course. Thus, he was unable to continue. Brennan asserted that his “Christian religious beliefs did not allow him to choose the answers required” by the ethics course. He asked that he be excused as an accommodation of his religion.
The Human Resources manager explained that the course used by Deluxe was intended to create a work environment that promoted inclusiveness and non-discrimination. She specifically advised Brennan via email, “It is important that as an employee of Deluxe you recognize that we do not expect you to change your values or beliefs but rather, as an employee, your behaviors at work are expected to uphold Deluxe’s standards and values.” Deluxe denied his request for accommodation and let him know that he would receive a 1% pay reduction as a disciplinary action. Brennan brought suit.
Before the court, Deluxe argued that it could not excuse Brennan from the Ethics course because it would be an undue hardship. The course complied with Equal Employment Opportunity Commission requirements on anti-discrimination guidance and how to perform the work. Brennan argued that he had enough to meet the initial requirements for a religious accommodation claim and whether it was an undue burden was a question of fact for trial. The district court agreed that he could proceed but did dismiss the claim that he was discriminated against based on his religion.