## Facts

- A public employer and a labor union were parties to a collective bargaining agreement requiring permanent bargaining-unit employees to become union members and pay dues.
- A permanent employee, a Seventh-day Adventist, objected to union participation, asserting religious conflict.
- The union treated the employee’s initial objections as directed to specific union practices (e.g., oath, Saturday meetings, strikes/demonstrations, and aspects of dues) and offered accommodations, including a modified affirmation, diversion of certain dues amounts to a nonprofit organization, and excusal from Saturday activities and demonstrations/strikes.
- After these accommodations were offered, the employee maintained that his religion barred any union participation and refused to join.
- The union initiated disciplinary proceedings under the union-security clause, and the employee was suspended from employment.
- The EEOC filed suit alleging Title VII religious discrimination based on the union’s failure to reasonably accommodate and its role in causing adverse employment consequences.
- The district court granted partial summary judgment to the EEOC and denied the union’s summary judgment motion; the union and the employer (joined under Rule 19) appealed.

## Issues

1. Whether summary judgment for the EEOC was proper on a Title VII religious-accommodation claim where the record contained evidence disputing whether the employee’s refusal to join the union was based on a bona fide, sincerely held religious belief.
2. Whether the district court improperly resolved fact-bound questions about sincerity and the nature of the asserted religious conflict at the summary judgment stage.

## Decision

- The First Circuit reversed the district court’s grant of summary judgment for the EEOC and remanded.
- The court held that the summary-judgment record presented a genuine dispute of material fact on an element of the EEOC’s prima facie case: whether the employee’s refusal to join the union stemmed from a bona fide, sincerely held religious belief.
- The court emphasized that the union produced evidence from which a factfinder could infer that the employee’s position shifted after accommodations were proposed and that the asserted religious basis for complete nonparticipation required factfinding.
- Because competing inferences were available, ordinary summary judgment standards required that disputed evidence be viewed in the union’s favor, making judgment as a matter of law improper.

## Legal Principles

- A Title VII failure-to-accommodate claim generally requires proof that: (1) the employee had a bona fide religious belief conflicting with a work-related requirement, (2) the employee informed the employer or union, and (3) the employee suffered adverse consequences for noncompliance.
- Title VII protects religious observance, practice, and belief, but the claimed belief or practice must be sincerely held; sincerity may be tested through evidence of conduct and the timing and content of asserted objections.
- Summary judgment is inappropriate when the record permits reasonable factfinders to reach different conclusions on a material element, including sincerity of a claimed religious belief.

## Conclusion

The First Circuit ruled that the EEOC was not entitled to summary judgment because the record allowed a reasonable factfinder to dispute whether the employee’s refusal to join the union was a sincere religious requirement, requiring further proceedings rather than resolution as a matter of law.


Equal Emp. Opportunity Comm'n v. Unión Indep. de la Autoridad de Acueductos y Alcantarillados de P.R., 279 F.3d 49 (1st Cir. 2002)