Equal Employment Opportunity Commission v. Unión Independiente de la Autoridad de Acueductos y Alcantarillados de Puerto Rico

David Cruz-Carrillo, a member of the Seventh-Day Adventist Church, began working as a temporary employee for the Autoridad de Acueductos y Alcantarillados (AAA) in Puerto Rico and became a permanent employee several years later. Cruz-Carrillo did not disclose his religious beliefs in his application, but his application reflected that he attended Seventh-Day Adventist schools. The Seventh-Day Adventist faith forbids its members from becoming members of labor organizations. Unión Independiente de la Autoridad de Acueductos y Alcantarillados (the union) (defendant) maintained a collective-bargaining agreement with AAA that contained a union-security clause. Under the union-security clause, when Cruz-Carrillo became a permanent employee of AAA, he was required to join the union. According to the union, Cruz-Carrillo did not initially object to union membership. Instead, Cruz-Carrillo objected at different points to taking a union-loyalty oath, paying union dues, attending union meetings on Saturdays, and joining union strikes or demonstrations. The union accommodated each of Cruz-Carrillo’s issues: it modified its standard loyalty oath so that it was merely an affirmation, transferred any portion of Cruz-Carrillo’s dues not directly used to pay his fringe benefits to a nonprofit organization, and exempted Cruz-Carrillo from the union’s demonstrations and Saturday meetings. Only at that point did Cruz-Carrillo reject the union’s proposals and claim that his faith prevented him from participating in the union. The union eventually initiated disciplinary proceedings against Cruz-Carrillo for failing to become a union member, and he was suspended from employment at AAA. Cruz-Carrillo filed a complaint with the Equal Employment Opportunity Commission (EEOC) (plaintiff). The EEOC sued the union on Cruz-Carrillo’s behalf in federal court, alleging that the union discriminated against Cruz-Carrillo based upon his religion in violation of Title VII. The district court granted the EEOC’s summary-judgment motion. The union appealed. The union conceded that the Seventh-Day Adventist faith opposes union membership but contested that Cruz-Carrillo does not always adhere to Seventh-Day Adventist practices. For example, Cruz-Carrillo divorced, worked five days instead of the six days required of Seventh-Day Adventists, and took an oath before a notary when he became a public employee.