## Facts

- Great Lakes operated a Holiday Inn in Milwaukee and hired Melvin D. Reed as executive housekeeper.
- Reed’s duties included ensuring Gideon Bibles were placed in hotel rooms.
- Management typically met with the Gideons when Bibles were delivered; Reed was expected to accompany the manager to the delivery meeting.
- Reed attended the meeting without objecting in advance; the Gideons read from the Bible and prayed.
- Reed became offended and left the meeting early.
- The manager confronted Reed later that day; Reed insisted he would not be forced to attend a religious event.
- After a heated exchange, the manager fired Reed, stating insubordination as the reason.
- Reed sued under Title VII for religious discrimination and failure to accommodate, and challenged his termination as unlawful.
- During discovery, Reed did not disclose his religious beliefs or identify a specific religious basis for his objection.
- The district court granted summary judgment to Great Lakes and sanctioned Reed (and separately sanctioned his attorney) for filing what it viewed as frivolous litigation.

## Issues

1. Whether Reed presented sufficient evidence that he was terminated “because of” religion (including lack of religion) under Title VII.
2. Whether Great Lakes had a Title VII duty to accommodate Reed’s religious beliefs or practices when Reed did not communicate a religious conflict before or during the workplace event.
3. Whether sanctions against Reed for bringing the lawsuit were justified and, if so, in what amount.
4. Whether the court of appeals had jurisdiction to review the sanction imposed on Reed’s attorney when the notice of appeal did not identify her as an appellant.

## Decision

- Affirmed summary judgment for Great Lakes on the Title VII claim.
- Held Reed failed to establish that his discharge was because of religion, rather than for workplace conduct characterized as insubordination.
- Held Reed failed to support an accommodation theory because he did not inform the employer of a religious conflict that would trigger an obligation to attempt reasonable accommodation.
- Vacated the sanctions imposed on Reed and remanded for reconsideration of whether sanctions were appropriate.
- Dismissed the attorney’s challenge to her personal sanction for lack of appellate jurisdiction because the notice of appeal did not clearly indicate she intended to appeal.

## Legal Principles

- Title VII religious-discrimination liability requires proof that an adverse employment action occurred “because of” the employee’s religion, including nonbelief.
- Title VII does not impose a general ban on employer-sponsored religious activity; it prohibits discrimination and may require reasonable accommodation of a genuine, religiously based conflict.
- An employer’s accommodation duty is generally triggered only after the employee provides sufficient notice that a job requirement or workplace practice conflicts with the employee’s religious beliefs or practices.
- A plaintiff’s refusal to articulate any religious belief or the religious nature of an objection can defeat both disparate-treatment and accommodation theories by preventing proof of religious motivation and obstructing accommodation analysis.
- Appellate jurisdiction over an attorney’s personal sanction requires a notice of appeal that clearly indicates the attorney is an appellant seeking review of that sanction.

## Conclusion

The Seventh Circuit held that Title VII did not support Reed’s claim because the record did not link his termination to religion and he did not communicate a religious conflict requiring accommodation, while also vacating and remanding the sanctions against Reed and declining to review his attorney’s separate sanction for lack of jurisdiction.


Reed v. Great Lakes Cos., 330 F.3d 931 (7th Cir. 2003)