Chalmers v. Tulon Company of Richmond

Charita Chalmers (plaintiff) worked for Tulon Company of Richmond (Tulon) (defendant) as a repoint-operations supervisor. Chalmers was an evangelical Christian who believed that the Lord was calling her to write letters to her coworkers about their relationships with God. Chalmers never informed anyone at Tulon about these beliefs. However, in September 1993, Chalmers wrote and mailed a letter to her supervisor, Richard LaMantia, at his home address. Chalmers told LaMantia in the letter that LaMantia needed to “get [his] life right with [the Lord]” and ask for God’s forgiveness because LaMantia had done things in his life that had displeased God. After receiving the letter, LaMantia informed Tulon’s Vice President of Administration that he could no longer work with Chalmers and recommended that Chalmers be terminated. While investigating LaMantia’s complaint, Tulon’s management learned that Chalmers had also sent one of her supervisees a letter in which she chastised the supervisee for committing adultery and threatened that God could afflict the supervisee with an illness as punishment for the supervisee’s behavior. Tulon management ultimately terminated Chalmers for exhibiting poor judgment in sending the letters to her coworkers. Chalmers subsequently sued Tulon, alleging religious discrimination in violation of Title VII of the Civil Rights Act of 1964 (Title VII). Chalmers alleged that Tulon had failed to accommodate her religious conduct. The district court granted summary judgment in Tulon’s favor, and Chalmers appealed.