## Facts

- Sikiru Adeyeye worked as a production employee for Heartland Sweeteners, LLC in Indiana.
- Adeyeye’s father died in Nigeria; as the eldest son, Adeyeye believed he was religiously obligated to return to Nigeria for several weeks to conduct burial rites.
- In July 2009, Adeyeye submitted a written leave request for October stating he needed to participate in funeral rites involving animal sacrifice, that his presence was “compulsory,” and that absence would cause “spiritual death” to him and his family.
- In September 2009, he submitted a second written request seeking to use accrued vacation and additional unpaid leave for the same multi-week rites.
- Heartland denied the requests, citing the length of the absence and company policy.
- Adeyeye traveled to Nigeria anyway and, upon return, was terminated for taking unauthorized leave.
- Adeyeye sued under Title VII, alleging religious discrimination based on failure to accommodate and discharge.

## Issues

1. Whether Adeyeye’s written leave requests created a genuine issue of material fact that Heartland had notice the leave was sought for a religious observance, triggering Title VII’s accommodation duty.
2. Whether summary judgment could be affirmed on alternative grounds, including lack of sincerity or undue hardship from granting multi-week leave.

## Decision

- The Seventh Circuit reversed summary judgment for Heartland and remanded.
- The court held a reasonable jury could find Heartland had sufficient notice the request was religious based on references to compulsory burial rites, animal sacrifice, and spiritual consequences.
- The court held disputed facts also precluded summary judgment on sincerity and undue hardship.
- The court rejected the argument that suggesting Adeyeye resign to take leave constituted a reasonable accommodation.

## Legal Principles

- Title VII requires reasonable accommodation of an employee’s religious observance or practice unless the employer proves undue hardship on business operations.
- “Religion” under Title VII is broadly defined to include unfamiliar or non-mainstream beliefs and practices, even when intertwined with family or cultural obligations.
- A prima facie failure-to-accommodate claim generally requires: (1) a bona fide religious belief conflicting with a job requirement; (2) employer notice of the belief and conflict; and (3) adverse action for noncompliance.
- Notice is satisfied if the employee provides enough information for a reasonable employer to understand the request is religious in nature; the employee need not use formal religious terminology.
- Sincerity and undue hardship are often fact-bound questions unsuitable for resolution on summary judgment when the record supports competing inferences.
- An employer does not reasonably accommodate religious practice by offering the employee the option to quit instead of accommodating.

## Conclusion

The court held that Adeyeye’s letters could reasonably be read as requesting religious accommodation and that factual disputes about notice, sincerity, and undue hardship required trial rather than summary judgment.


Adeyeye v. Heartland Sweeteners, LLC, 721 F.3d 444 (7th Cir. 2013)