The role of the judge in the burger joint case

Assume the role of the judge in the burger joint case. Analyze the legal issues presented by the parties and state how you would rule on each of the issues presented. Remember that your ruling should be based on your legal analysis and not on your own personal views. Use the IRAC method to apply the law to the facts and reach a legal conclusion based on your analysis.
Your legal analysis should summarize the legal framework that applies to religious discrimination cases under Title VII (see EEOC v. Alamo Rent-A-Car LLC [2006], Tiano v. Dillard Department Stores, Inc. [1998], and Cloutier v. Costco Wholesale Corp. [2004]) and then:
• Determine whether Ms. Djarra established a prima facie case of religious discrimination against her by Mr. Johnson.
• Discuss whether Mr. Johnson made a good faith effort to offer reasonable accommodations to Ms. Djarra or whether Mr. Johnson could not reasonably accommodate Ms. Djarra without undue hardship.
• Identify the types of damages available under Title VII and the type and amount of damages to be awarded to Ms. Djarra, if any.

Full Answer Section

         

The relevant legal principles, as informed by the cases provided, are:

  • Prima Facie Case: To establish a prima facie case of religious discrimination, a plaintiff must demonstrate three elements: (1) she holds a bona fide religious belief; (2) she informed her employer of a conflict between her religious belief and a job requirement; and (3) she was subjected to an adverse employment action (e.g., termination, demotion) because of her inability to comply with the conflicting job requirement due to her religious belief (See Tiano v. Dillard Department Stores, Inc. [1998]).
  • Reasonable Accommodation: Once a prima facie case is established, the burden shifts to the employer to show that they made a good faith effort to reasonably accommodate the employee's religious practice or that doing so would cause undue hardship (See EEOC v. Alamo Rent-A-Car LLC [2006]). A reasonable accommodation is one that eliminates the conflict between the religious practice and the job requirement.
  • Undue Hardship: Undue hardship means more than a de minimis (minimal) cost or burden on the employer. It is a lower standard than for disability accommodation. An accommodation that would cause an employer to bear more than a trifling cost, or would require the employer to infringe on the rights of other employees, would constitute an undue hardship (See Cloutier v. Costco Wholesale Corp. [2004]). This can include financial costs, safety concerns, or negative impacts on workplace efficiency or morale.

III. Analysis and Ruling

A. Ms. Djarra's Prima Facie Case of Religious Discrimination

Issue: Did Ms. Djarra establish a prima facie case of religious discrimination against Mr. Johnson?

Rule: To establish a prima facie case, Ms. Djarra must show: (1) bona fide religious belief, (2) conflict with job requirement communicated to employer, and (3) adverse employment action due to the conflict.

Application:

  1. Bona Fide Religious Belief: Ms. Djarra claims adherence to the Islamic faith, which requires the wearing of a hijab as an expression of religious modesty. There is no evidence presented to suggest that this is not a bona fide religious belief. Her consistent practice of wearing the hijab supports its sincerity.
  2. Informed Employer of Conflict: Ms. Djarra explicitly informed Mr. Johnson that her religious practice required her to wear a hijab. This directly conflicted with Mr. Johnson's uniform policy requiring a hairnet for all employees working with food. The conflict was clearly communicated at the outset of her employment, and again when the issue arose.
  3. Adverse Employment Action: Ms. Djarra was terminated from her employment because of her refusal to remove her hijab or substitute it with a hairnet, which she stated conflicted with her religious practice. Termination constitutes an adverse employment action.

Conclusion: Ms. Djarra has successfully established a prima facie case of religious discrimination. She holds a bona fide religious belief requiring a hijab, she informed Mr. Johnson of the conflict with the hairnet policy, and she was terminated as a direct result of this conflict. The burden now shifts to Mr. Johnson to demonstrate reasonable accommodation or undue hardship.

B. Mr. Johnson's Efforts for Reasonable Accommodation and Undue Hardship

Issue: Did Mr. Johnson make a good faith effort to offer reasonable accommodations to Ms. Djarra, or could he not reasonably accommodate Ms. Djarra without undue hardship?

Rule: The employer must demonstrate either a good faith effort at reasonable accommodation or that any accommodation would cause undue hardship (more than a de minimis burden). Undue hardship can include financial cost, safety concerns, or impact on other employees.

Application: Mr. Johnson's position is that the hairnet policy is a health and safety requirement to prevent hair from falling into food, and that a hijab cannot serve this purpose adequately, thus posing an undue hardship related to food safety. He offered to allow her to wear the hairnet over the hijab or offered a head covering provided by the restaurant that he believed would comply.

  1. Reasonable Accommodation Efforts: Mr. Johnson did offer two potential accommodations: wearing the hairnet over the hijab, or wearing a restaurant-provided head covering. The former was rejected by Ms. Djarra as it did not resolve her religious conflict (she wanted her specific hijab to be the primary head covering without an external, potentially uncomfortable or non-compliant hairnet directly over it). The latter implies an alternative head covering, but the core issue for Ms. Djarra was the type of head covering that integrated her religious practice while meeting the health standard. The question then becomes whether the

Sample Answer

         

Ruling on Djarra v. Johnson's Burger Joint

I. Introduction

This court presides over the case of Ms. Djarra, a former employee of Johnson's Burger Joint, alleging religious discrimination under Title VII of the Civil Rights Act of 1964. The defendant, Mr. Johnson, owner of the Burger Joint, disputes these claims. The central issues revolve around whether Ms. Djarra established a prima facie case of religious discrimination, whether Mr. Johnson fulfilled his duty to reasonably accommodate her religious practices or demonstrated undue hardship, and finally, the availability and appropriateness of damages.

II. Legal Framework for Religious Discrimination under Title VII

Title VII of the Civil Rights Act of 1964 prohibits discrimination based on religion. This includes not only religious beliefs but also religious practices,