Wilson v. U.S. West Communications

After working for U.S. West Communications (U.S. West) (defendant) for almost 20 years, Christine Wilson (plaintiff) was transferred to a different facility that had no dress code. In August 1990, Wilson, a Roman Catholic, began wearing an anti-abortion button to work every day as part of a religious vow she made to herself. The button showed a color photograph of an unborn, pre-term fetus. The button caused major disruptions among Wilson’s co-workers, many of whom found the button offensive and disturbing for reasons unrelated to religion, including personal struggles with infertility, miscarriage, and infant death. Wilson’s supervisors received many complaints from other employees about the button, and some employees threatened to stop working until the issue was resolved. Shortly after Wilson began wearing the button, her two supervisors, who were also Roman Catholic, met with her about the workplace disruptions. The supervisors proposed three options: Wilson could wear the button in her cubicle only, cover the button while at work, or wear a different button with the same anti-abortion message but without the photo. Wilson refused any of these options, contending that she was a “living witness” for God and that offended co-workers should be told to avert their eyes. Wilson took some permitted leave, but when she returned, the disruptions continued, and she was again asked to either cover or replace the button or only wear it in her cubicle. When Wilson again refused, a supervisor sent her home and then fired her for missing three consecutive days unexcused. Wilson sued U.S. West, alleging religious discrimination under Title VII of the Civil Rights Act of 1964 (Title VII), 42 U.S.C. § 2000e et seq. The district court concluded that while Wilson made a prima facie showing of religious discrimination, U.S. West’s offer to cover the button while at work was a reasonable accommodation. The district court granted summary judgment to U.S. West, and Wilson appealed.