Brown v. Polk County, Iowa

61 F.3d 650 (1995)

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Brown v. Polk County, Iowa

United States Court of Appeals for the Eighth Circuit
61 F.3d 650 (1995)

SC

Facts

Isaiah Brown (plaintiff) worked for the Polk County government (defendant). Brown and other employees said prayers in Brown’s office prior to the workday and during certain meetings. The prayers were voluntary, and those during meetings were spontaneous and sporadic. Brown also discussed his Christianity with other employees. The county administrator reprimanded Brown for promoting religion and directed Brown to cease all religious activities at work and remove all religious items from his office, including the Bible in his desk. Later that year, the administrator reprimanded Brown for lack of judgment related to the county budget. Two weeks later, Brown was fired. Brown sued the county for religious discrimination in violation of Title VII of the Civil Rights Act of 1964 (Title VII). Brown also claimed that the county’s actions violated the Free Exercise Clause. The county administrator testified that Brown’s religious activities were a factor in the decision to fire him but that the firing was due to the confluence of multiple factors. The district court ruled in favor of the county on all issues. Brown appealed.

Rule of Law

Issue

Holding and Reasoning (Arnold, J.)

Dissent (Fagg, J.)

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