EEOC v. Walmart Stores East, L.P.
United States Court of Appeals for the Seventh Circuit
992 F.3d 656 (2021)
- Written by Abby Roughton, JD
Facts
Walmart Stores East, L.P. (Walmart) (defendant) operated a store in Hayward, Wisconsin, that was open 24 hours per day, seven days per week. The store was run by a manager who was assisted at all times by assistant managers. In 2016, Walmart offered Edward Hedican a job as one of eight full-time assistant managers for the Hayward store. After Hedican received the offer, Hedican told Walmart that he was a Seventh-day Adventist who could not work between sundown Friday and sundown Saturday. Human-resources manager Lori Ahern considered whether Walmart could accommodate Hedican’s religious requirements but concluded that accommodating Hedican would be too burdensome. The Hayward store scheduled its full-time assistant managers on a rotation, and Ahern believed that having one full-time assistant manager unavailable at times could leave the store shorthanded or unfairly require the other full-time assistant managers to cover extra weekend shifts. Ahern suggested to Hedican that Hedican could apply for an hourly management position, which would not be subject to the same rotation schedule as the eight full-time assistant managers. Hedican did not apply for an hourly position and instead filed a discrimination charge with the Equal Employment Opportunity Commission (EEOC) (plaintiff). The EEOC brought a failure-to-accommodate suit against Walmart on Hedican’s behalf. Walmart moved for summary judgment, asserting that although Title VII of the Civil Rights Act of 1964 (Title VII) forbids employers from discriminating on religious grounds, no actionable discrimination exists if the employer could not reasonably accommodate an employee’s religious practices without a resulting undue hardship on the conduct of the employer’s business. Walmart argued that offering Hedican the opportunity for an hourly management position satisfied Walmart’s duty to accommodate Hedican’s religious practice but that imposing any greater responsibility on Walmart would result in undue hardship. The trial court agreed and granted summary judgment in Walmart’s favor. The EEOC appealed, asserting, among other things, that Walmart could have allowed Hedican to trade shifts with other full-time assistant managers or assigned Hedican to a fixed shift that never included Fridays or Saturdays.
Rule of Law
Issue
Holding and Reasoning (Easterbrook, J.)
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