In recent years, the Supreme Court has ruled that when a conflict exists between an employee’s religious practices and company policies, the employer must make accommodations for the employee. However, this law can be misinterpreted when there is no direct conflict and the employer believes that their policy is important for all employees.
Considering the facts of this case, did Arconic Corporation wrongfully discriminate against Daniel Snyder when they terminated his employment for his religious expression in the workplace?
As mentioned above, Title VII protects religious accommodations for employees whose beliefs or practices conflict with aspects of the workplace. While an employee's core religious beliefs themself cannot violate a workplace rule, the Court clarified that actions stemming from those beliefs, such as prayer rituals or specific attire, might create conflicts with established workplace policies.
In this scenario, Arconic did not force Snyder to participate in any action that would have gone against his religious beliefs. They did not ask him to wear a rainbow pin or affiliate himself with any other aspect of Pride Month that they were promoting. Snyder’s case differs from others involving Title VII such as EEOC v. Abercrombie & Fitch as he was not required to do anything to work his job that would explicitly go against his religious beliefs. Instead, they forbade Snyder, as well as other employees, from making statements expressing hostility toward others. This policy had nothing to do with religious beliefs, but instead a general protection of their employees. It is also important to note that Synder did not ask for any religious accommodation to this rule prior to posting the comment. When asked for religious accommodations about working on Sundays, Arconic compiled. However, this was a well-known policy about diversity and inclusion and Snyder violated it without asking for any accommodation.
Snyder claims that Title VII protects his ability to speak freely about his religious beliefs. However, Title VII mandates “favored treatment” when there is a conflict between religious practices and employment requirements. In Altman v. Minnesota Department of Corrections, the Eighth Circuit held that there must be an actual conflict between religious practices and employment requirements for the employee’s Free Exercise rights to be violated. There was no indication or argument from Snyder that his religion would require him to post messages to the use of rainbow imagery, therefore leading Title VII to not be applicable in this sense. It is also important to note that Snyder was not unable to complete his job due to the diversity and inclusion policy. The Court concluded that Snyder was fired because of violating a religiously neutral policy.
In my opinion, Arconic interpreted Snyder's message as potentially creating a hostile work environment for a protected group, which violated their company policy. They based this interpretation on the content of the message, regardless of Snyder's claimed intent. He posted this comment without Arconic being aware that his religious beliefs were in conflict or asking for an accommodation. Based on the facts of the case, Snyder was asking the Court to go against previously established precedent cases as his argument focused on what happened after he posted his message on the intranet. If Snyder’s religious beliefs truly compelled him to post the message on the intranet page, it does not make sense to ask for an alternative solution of no longer being able to post messages on the intranet page. I agree with the Court’s and Arconic's decision in Snyder’s termination.
9 comments:
Hi Kendall! This is a very interesting case to pick for your Blog Post discussion and I agree with your overall analysis and conclusion for the case. As you mentioned, the applicable law here is Title VII of the Civil Rights Act. This provision requires employers to make reasonable accommodations for their employees who file religious exemptions. As the facts of the case suggest, there was no accommodation request made by Snyder to not be affiliated with Spectrum because of his religious beliefs. Instead he went straight to the employer's private network to voice his complaints. The nature of the network being private is an important aspect of this case as well. The Court has historically ruled that when there is a limited public forum opened by a public entity, then all religious views need tobe respected. Since this was a private forum, strict censorship is allowed. This is entirely different than previous cases in which the court system ruled in favor of religious protections. He made zero attempt to exempt himself and by instantly posting a relatively hostile comment on the private network, simultaneously created a hostile work environment for those who identify with the LGBTQ community. The company has a stronger interest in promoting a safe work environment for all employees. Therefore, their interests should outweigh those of Snyder's.
Kendall,
You chose a compelling case to analyze. Like Anthony, I, too, agree with your overall analysis and personal summation. Your references to Title VII of the Civil Rights Act of 1974 really strengthened your argument.
Like yourself, I am siding with Arconic and the Court. As the facts of the case suggest, Synder went out of his way to express his religious beliefs. The company did not force him to participate in any action that burdened these beliefs. Because of this, I do not believe Snyder should be protected on the basis of the Free Exercise Clause of the First Amendment. As Arconic stated, such actions demonstrate hostility towards other employees, and because of this, Snyder should rightfully be terminated.
This case regarding Daniel Snyder and the Arconic Corporation is a very interesting First Amendment case. I was conflicted as there are compelling arguments for both sides but I ultimately agree with your ruling that it was not unconstitutional for the Arconic Corporation to fire Daniel Snyder. As you mentioned the Title VII of the Civil Rights Act of 1974 ensures that employees must make reasonable accommodations to ensure that other employees are respected but clearly Snyder was not willing to do this. The decision to fire Snyder was not due to his religious beliefs but because of the hostile environment created for other employees. Also since the Arconic Corporation allowed for individuals to not work on Sundays it is clear that they are not hostile towards religion and are willing to work with individuals to accommodate their sincerely held religious beliefs.
Kendall, this was an excellent post. I agree with you that Synder’s free exercise rights were not violated when Arconic Corporation terminated his employment due to his statements made on the intranet. Whereas due to the protections afforded under this act, Synder had previously been granted a religious accommodation to not work on Sundays, I do not believe the protections of Title VII extend to comments he freely chose to make on the intranet page. Not only did his job not require him to post on the page, but as you mentioned, posting messages on the page was not a requirement of his religion. However, I believe that despite violating the diversity and inclusion standards, there was a less restrictive means available than outright firing Synder. Additionally, it seems to me that the facts are murky as to whether he truly thought he was making his comment on the anonymous survey or whether he was aware that his comment would get sent to all 13,000 employees.
Hi Kendall, I certainly agree with your comments and analysis of this case. Title VII of the Civil Rights Act of 1974 states that accomodations need to be made for religious exemptions, but Snyder made no claims prior to his comments of needing a religious exemption. By going to the employers private network, this means that he does not have the right to say anything he feels is right, and he is subject to termination as Free Speech and religious views are not fully protected in private forums. Additionally, this comment can be seen as hostile or create a disruption in the workforce as it attacks a minority group within the company. I agree with your analysis and conclusion that Snyder's termination was lawful and not a violation of his First Amendment rights.
Kendall, your insights on the Snyder case at Arconic Corporation are spot-on. I agree that while Snyder's termination wasn't a direct violation of his free exercise rights, his comments on the internet fell outside the protections of Title VII. Despite having a religious accommodation, his posts didn't align with his obligations. Also, I do think there could have been a less severe response, given the uncertainty around his intent. Regarding Arconic's decision, I believe it wasn't unconstitutional. They were within their rights under Title VII to maintain a workplace free from hostility. Their willingness to accommodate religious beliefs, as seen in their Sunday work policy, reflects a commitment to diversity and inclusion. Overall great job!
Hi Kendall,
This was a really interesting post! I agree with your analysis that Snyder’s free exercise rights were not violated. As you mentioned, Snyder was not asked to perform any action that went against his religious beliefs. He chose to express his opinion on the private company network where conduct can be regulated. Also, I agree that Snyder was not targeted because of his religious beliefs specifically. Although his expression was derived from his faith, it created a hostile work environment that could put other employees at risk; however, I wonder if this idea could be exploited and wrongly applied in future cases. Religious speech is constitutionally protected, but taking offense is not. I worry that employees could feel discouraged from expressing their religion at work for fear of losing their job because their employer found their beliefs “dangerous.”
Great post Kendall. I agree with you that this case constituted a first amendment violation. I liked how you mentioned that Snyder was asking the Court to rule against their prior precedents they had established earlier on. I also don't think its fair for Snyder to request that the capacity to post messages be withdrawn from the intranet page if his religious values truly motivated him to publish the message there, and I like your interpretation of Arconic's position.
Hi Kendall,
This was a great post! I agree with you on your analysis of this case. I agree that Snyder's termination was based on a policy that was for everyone, and not based off a religious accommodation that was violated. I think that Arconic could have given him a lesser punishment than the one that they gave him because there was some confusion on Synder's intent of the comment he left on the internet, but I agree that Arconic was not violating any of Synder's religious rights because they accommodated to him by giving him Sundays off. Great job on the post!
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