Hamood v. Arab Community Center for Economic and Social Services d/b/a ACCESS

Summary

The court denied Plaintiff Sudoos Hamood’s supplemental motion in limine in her religious-accommodation action against ACCESS. The court held that Defendant could challenge the factual assumptions underlying Plaintiff’s rejection of a proposed accommodation, including the likelihood that men would see her uncovered face during a virtual class, while noting that the ruling was preliminary and subject to reconsideration during trial.

Holdings

1. Title VII does not bar an employer from examining the factual assumptions underlying an employee's rejection of a religious accommodation request. Defendant may present evidence that the risk Plaintiff fears is unlikely to support an argument that its proposed accommodation was reasonable.
2. The court denied Plaintiff's supplemental motion in limine because the challenged arguments and evidence were not categorically inadmissible and could be relevant to whether Defendant's proposed accommodation was reasonable.

Questions Presented

1. Whether the court should preclude Defendant from presenting evidence or argument that Plaintiff's concern about men seeing her uncovered face during virtual instruction was unreasonable, far-fetched, or unlikely.
2. Whether Title VII bars an employer from challenging the factual assumptions underlying an employee's rejection of a proposed religious accommodation when the employer does not challenge the sincerity of the employee's religious belief.

Disposition

other