## Facts

- Charita D. Chalmers worked at Tulon’s Richmond, Virginia facility, starting in 1988 as a repoint operator and later becoming a repoint-operations supervisor.
- Chalmers was an evangelical Christian who believed she had a religious obligation to address co-workers’ spiritual condition.
- In September 1993, Chalmers mailed a religious letter to her supervisor, Richard LaMantia, at his home, urging him to “get [his] life right with [the Lord]” and seek forgiveness for conduct displeasing to God.
- LaMantia’s wife interpreted the letter as implying an affair, causing marital conflict and a workplace confrontation.
- During Tulon’s investigation, management learned Chalmers had also sent a similar letter to a subordinate’s home, chastising the subordinate for adultery and warning that God could afflict her with illness as punishment.
- Tulon concluded the letters reflected poor judgment and significantly harmed workplace relationships, and it terminated Chalmers.
- Chalmers sued under Title VII, alleging religious discrimination based on failure to accommodate her religiously motivated letter-writing and claiming the termination was unlawful.

## Issues

1. Whether Chalmers established a prima facie Title VII religious-accommodation claim, including that Tulon had actual notice of a need to accommodate her religious practice.
2. Whether the conduct at issue—sending unsolicited, personal religious admonitions to co-workers’ homes—was reasonably accommodable without undue hardship or infringement of co-workers’ rights.

## Decision

- The Fourth Circuit affirmed summary judgment for Tulon.
- The court held Chalmers did not provide Tulon notice that her religion required the letter-writing conduct, so Tulon’s duty to accommodate was not triggered.
- The court further held that, even with notice, the letters were not the type of religious conduct susceptible to reasonable accommodation under Title VII because of their intrusive and disruptive character.
- The court accepted Tulon’s stated reason for discharge—poor judgment and workplace disruption—as legitimate and not shown to be pretext for religious bias.
- A dissent would have allowed a jury to assess whether termination was justified or reflected inadequate tolerance for religious expression.

## Legal Principles

- An employer’s Title VII duty to accommodate religious practice arises only when the employee provides actual notice of a conflict between religious practice and workplace requirements.
- Title VII does not require accommodation of religious conduct that intrudes on co-workers’ privacy or personal rights, or that creates significant workplace disruption.
- Religious accommodation is limited where the requested accommodation would impose undue hardship, including harm to workplace relationships and the rights and sensibilities of other employees.
- An employer may lawfully discipline or discharge an employee for nonreligious, legitimate business reasons (e.g., poor judgment and disruption), absent proof those reasons are a pretext for discrimination.

## Conclusion

The Fourth Circuit held that Title VII did not require Tulon to accommodate Chalmers’ unsolicited, accusatory religious letters to co-workers’ homes, particularly where Tulon lacked notice of any religious need for such conduct, and where the conduct foreseeably disrupted workplace relations and implicated co-workers’ rights.


Chalmers v. Tulon Co. of Richmond, 101 F.3d 1012 (4th Cir. 1996)