## Facts

- Ronald Philbrook, a public high-school teacher and member of the Worldwide Church of God, was religiously required to refrain from secular work on designated holy days, missing about six schooldays per year.
- The school board’s collective-bargaining agreements provided (1) three paid days annually for religious holidays and (2) three paid days for “necessary personal business,” but barred using personal business leave for matters covered by other leave categories, including religious holidays.
- After using the three paid religious-holiday days, Philbrook covered additional holy days by taking unauthorized unpaid leave, rescheduling required medical appointments to fit within permitted leave, or working despite his beliefs.
- Philbrook asked the board to allow him either to use personal business leave for religious observance or to pay for a substitute teacher while receiving full pay for additional days off.
- The board rejected both proposals.
- Philbrook pursued administrative remedies and then sued under Title VII, alleging religious discrimination and failure to reasonably accommodate under 42 U.S.C. § 2000e(j).

## Issues

1. Whether Title VII religious-accommodation claims require courts to apply a specific prima facie and burden-shifting proof framework in every case.
2. Whether an employer that offers a reasonable accommodation must accept an employee’s alternative reasonable proposal absent a showing of undue hardship.
3. Whether the board’s leave policy and its actual operation provided a reasonable accommodation for Philbrook’s religious observance.

## Decision

- The Supreme Court reversed the Second Circuit’s legal rule, vacated in part, and remanded.
- The Court held that Title VII does not require an employer to accept an employee’s preferred accommodation when the employer has already provided a reasonable accommodation.
- The Court declined to prescribe a mandatory proof scheme for all religious-accommodation cases, noting the case had been fully tried on the ultimate question.
- The Court remanded because the record did not permit a determination whether the leave policy, as applied in practice, actually provided a reasonable accommodation.

## Legal Principles

- Under Title VII, an employer must “reasonably accommodate” an employee’s religious observance or practice unless doing so would impose an undue hardship on the employer’s business.
- Once an employer demonstrates that it offered a reasonable accommodation, the statutory inquiry ends; the employer need not prove that each employee-proposed alternative would create undue hardship.
- “Reasonable accommodation” does not require eliminating every conflict between work and religious practice; partial accommodations, including unpaid leave, may be reasonable depending on circumstances.
- “Undue hardship” follows the standard that accommodation may be denied when it would impose more than a de minimis cost on the employer.
- Whether a policy constitutes a reasonable accommodation can depend on how the policy is implemented in practice, not only on its written terms.

## Conclusion

The Court rejected a rule requiring employers to adopt an employee’s preferred accommodation when the employer has provided a reasonable one, but remanded for fact-finding on whether the school board’s leave policy actually functioned as a reasonable accommodation for the teacher’s required religious absences.


Ansonia Bd. of Educ. v. Philbrook, 479 U.S. 60 (1986)