Religious Discrimination Complaint

Below is what a religious discrimination complaint might look like. Do not use it yourself; instead, seek a lawyer’s advice before doing anything. Complaints are factually and legal-specific, so this is not to be used even as a sample:

Complaint

1.         The Plaintiff, Jane Doe, sues Defendant A.B.C. Company, pursuant to the Civil Rights Act of 1964 (Title VII), for failure to accommodate and religious discrimination.

2.         The Honorable Court has original jurisdiction pursuant to Title VII.

3.         Venue is appropriate in the Gainesville Division pursuant to the local rules because Defendant conducts business in Alachua County, Florida.

4.         Plaintiff resides in Gainesville, Florida.

5.         The discriminatory actions occurred in the State of Florida 

6.         Defendant employs over 500 employees.

7.         Plaintiff began working for Defendant on or about June 18, 2011.

8.         On or about July 30, 2021, Plaintiff first notified Defendant of her sincerely held religious belief.

9.         Defendant could have offered a reasonable accommodation to Plaintiff that did not cause an undue hardship.

10.       Despite the clear opportunity, Defendant callously chose not to make reasonable accommodations for Plaintiff.

11.       Defendant denied Plaintiff's religious accommodation request on or about October 14, 2011.

12.       Defendant placed Plaintiff on unpaid paid leave on or about October 11, 2011.

13.       Defendant terminated Plaintiff on or about December 1, 2011.

14.       The Plaintiff's position at the time of her termination was Gardener. In this role, she was responsible for maintaining the landscaping of the company's premises, a task she performed diligently and without any performance issues.

15.       The Plaintiff, a deeply devout Christian, is a resident of Gainesville, Florida.

16.       Plaintiff was baptized by the Church in Gainesville.

17.       Plaintiff engages in Christian fellowship.

18.       Plaintiff studies the bible.

19.       Plaintiff's diet is dictated by her family's religious beliefs.

20.       Plaintiff does not believe in altering her body.

21.       Plaintiff regularly practices her faith, which includes attending church services, participating in Christian fellowship, and studying the bible. These practices are central to her religious identity and are deeply important to her.

22.       Defendant mandated the COVID-19 vaccine.

23.       The Plaintiff does not believe that the COVID-19 vaccine may be taken in accordance with God's will.

24.       Plaintiff specifically believes that the COVID-19 vaccine violates her sincerely held religious belief.

25.       Plaintiff worked remotely.

26.       Plaintiff's supervisors supported the accommodation of working remotely.

27.       Defendant instituted a Covid-19 vaccine policy, which required all employees to be fully vaccinated as a condition of employment. This policy was implemented without considering the potential impact on employees' religious beliefs.

28.       Defendant's COVID-19 vaccine policy discarded with the views of people like Plaintiff.

29.       Defendant rejected Plaintiff's sincerely held religious beliefs.

30.       Defendant took the position that Plaintiff's sincerely held religious beliefs were not theology and did not deserve Title VII protection.

31.       Defendant judged Plaintiff's religious beliefs and held that they were not sound.

32.       Defendant demanded that Plaintiff comply with Defendant's religious interpretations, which included the belief that Defendant's vaccine is safe and effective and that all employees should be fully vaccinated. Plaintiff, however, does not share these interpretations and believes that they are not in line with her own religious beliefs.

33.       Plaintiff teleworkDefendantfendant part-time beginning on or about 2011.

34.       Plaintiff and many others worked from home 100% of the time from on or about March 2001.

35.       Plaintiff was able to work fully remotely for Defendant.

36.       The Plaintiff comes from a Christian family that opposes abortion.

37.       The Plaintiff was baptized on January 6, 1916.

38.       The Plaintiff sincerely holds the religious belief that she cannot take the COVID-19 vaccine.

39.       Plaintiff believes that the vaccines run afoul of her religious beliefs in multiple ways.

40.       Plaintiff's rDefendantbeliefs comport with 29 C.F.R. § 1605.1.

41.       Plaintiff requested an accommodation from Defendant's COVID-19 vaccine policy and engaged in multiple discussions with her supervisors and the company's HR department to find a solution that would allow her to continue her employment without compromising her religious beliefs. However, these discussions did not result in a satisfactory resolution.

42.       Defendant chose to institute a vaccine policy.

43.       The defendant demanded that all employees be fully vaccinated.

44.       Defendant denied Plaintiff's accommodation request.

45.       Defendant did not engage in good faith in the interactive process.

46.       Defendant could have offered Plaintiff an accommodation.

47.       Defendant denied Plaintiff's accommodation request because Defendants were against Plaintiff's religious beliefs.

48.       Defendant sought to make Plaintiff's sincerely held religious beliefs a political issue.

49.       Plaintiff proposed reasonable accommodations to Defendant, including working remotely, wearing additional personal protective equipment, and undergoing regular testing for COVID-19. These accommodations would have allowed Plaintiff to continue her employment without compromising her religious beliefs.

50.       Defendant neither accepted Plaintiff's proposed accommodation requests nor made any counterproposals.

51.       Defendant simply did not want to provide accommodation for Plaintiff.

52.       Defendant acted in reckless disregard of Defendant.

53.       Defendant willfully violated Title VII.

54.       Defendant intentionally violated Title VII to promote its political views.

55.       Plaintiff's religious views were not agreeable to the Defendant.

56.       Plaintiff lost her job because of her religion.

57.       Defendant is engaged in interstate commerce as it accepts monies from insurance companies located outside of Florida, it treats patients that Defendant Florida as well as outside of Florida, it purchases equipment that is made out-of-Defendantd it accepts Medicare and Medicaid.

58.       Defendant receives federal funds.

59.       Title VII required Defendant to engage in the interactive process with Plaintiff.

60.       Title VII required Defendant to provide an accommodation to Plaintiff.

61.       Defendant had a duty to accommodate Plaintiff pursuant to 29 C.F.R. § 1605.2(b)(1).

62.       Defendant was not justified in denying Plaintiff an accommodation.

63.       Defendant is unable to demonstrate that accommodating Plaintiff would pose an undue hardship.

64.       Plaintiff filed a charge of discrimination with the U.S. Equal Employment Opportunity Commission (EEOC) within 180 days of being denied an accommodation.

65.       The Plaintiff filed a charge of discrimination within 180 days of being discharged.

66.       The EEOC investigated Plaintiff's charge of discrimination.

67.       The EEOC found reasonable cause.

68.       The EEOC issued a notice of right to sue letter.

69.       PDefendant'sles her Complaint within 90 days of receiving her notice of right to sue.

70.       All preconditions to bringing suit have been accomplished.

71.       Plaintiff has suffered damages as a result of Defendant's violations of Title VII.

72.       Defendant permitted Plaintiff to lose her job in whole or in part because of her sincerely held religious beliefs.

73.       The decision to terminate Plaintiff was motivated by Plaintiff's sincerely held religious views.

74.       Plaintiff was an employee in good standing.

Count I – Failure to Accommodate

75.       Plaintiff reincorporates paragraphs 1 through 74 as if Defendant herein.

76.       Plaintiff was entitled to a reasonable accommodation.

77.       Plaintiff proposed reasonable accommodations.

78.       Defendant did not accommodate Plaintiff.

79.       Because Defendant refused to accommodate Plaintiff, she lost her job.

Wherefore, Plaintiff demands trial by jury, judgment, back pay, front pay if reinstatement is not feasible, compensatory damages, attorneys' fees, costs, and any other relief the Court deems just.

Count II - Discrimination 

80.       Plaintiff reincorporates paragraphs 1 through 74 as if fully stated herein.

81.       Defendant discriminated against Plaintiff on account of her religion.

82.       The defendant had a policy that discriminated against certain religious views.

83.       Defendant discharged Plaintiff because of her religious views. 

Wherefore, Plaintiff demands trial by jury, judgment, back pay, front pay if reinstatement is not feasible, compensatory damages, attorneys' fees, costs, and any other relief the Court deems just.