Adeyeye v. Heartland Sweeteners, LLC

In July and September 2019, lawful permanent resident Sikiru Adeyeye (plaintiff) submitted two requests for authorized leave to return to Nigeria to participate in his father’s funeral ceremony, to be held in October 2019. Adeyeye’s requests indicated that his attendance was required and that as the oldest son, he had to perform certain burial rites over the course of four to five weeks, which included animal sacrifice, so that his siblings would not die also. Adeyeye sought to use a mix of vacation time and unpaid leave. Under Title VII of the Civil Rights Act of 1964 (Title VII), if an employee notified an employer of the need to take time off in order to participate in religious services or practices, a covered employer had to provide reasonable accommodation to the employee’s request if providing the accommodation would not present an undue hardship on the employer. Title VII’s protections extended to religious practices that might be less familiar in the modern American context. Despite Title VII’s prohibition on religious discrimination by employers, Adeyeye’s employer, Heartland Sweeteners, LLC (Heartland) (defendant), denied Adeyeye’s leave requests and fired him after he took unauthorized leave and returned to work. Adeyeye sued Heartland for failing to offer an accommodation of his religion. At trial, Heartland argued that Adeyeye’s requests were insufficient to place Heartland on notice of the religious nature of his request for time off. A district court granted summary judgment to Heartland. Adeyeye appealed.