Could animal sacrifice be part of a religious accommodation? Court says yes
This may be the strangest bereavement request ever — but that didn’t mean the company could deny this staffer the chance to attend his father’s funeral.
Here are the details of the case:
Sikiru Adeyeye is a Nigerian national who worked as a material handler for Heartland Sweeteners.
Adeyeye’s father, who lived in Nigeria, died in May 2010. Adeyeye reported to his supervisors that he’d need to travel to Nigeria for several weeks for the funeral.
Adeyeye made two formal requests for leave to his managers, saying that it was mandatory for him to attend the funeral. If he didn’t perform certain rituals (including slaughtering five goats), Adeyeye added, he believed that he and his siblings would die.
Both of Adeyeye’s requests were denied “due to business need” — Adeyeye’s absence “for that period of time would negatively affect the business.”
Each denial did offer Adeyeye the alternative to “voluntarily terminate” his employment and reapply once he returned, but noted that there was no guarantee that he’d be rehired.
Adeyeye went to the funeral anyway and was subsequently fired.
Should company have granted his request?
Adeyeye filed suit, claiming that the company should have accommodated his religious accommodation request.
A trial court ruled in favor of the company, but Adeyeye won on appeal, sending the case back to a jury.
Yes, most jurisdictions don’t require companies to offer paid or unpaid bereavement leave, the court noted.
But Adeyeye’s letters, which made reference to the “funeral rite” and a “funeral ceremony,” could be enough for a jury to conclude they were sufficient notice of a religious accommodation request.
Foley & Lardner attorney Larry Perlman has the takeaway for HR:
The court concluded that although these religious beliefs may not be as familiar as some modern American practices, the law protects all sincerely held religious beliefs, and if the company had questions as to whether the request was religious, it could have asked the employee for further explanation.
The case is Adeyeye v. Heartland Sweeteners, LLC.
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