## Facts

- Christine L. Wilson, a long-time employee of U.S. West, worked as an information specialist supporting engineers with telephone cable-location records.
- Wilson, a Roman Catholic, made a religious vow to wear a particular anti-abortion button until abortion ended or she could no longer “fight the fight.”
- The button (about two inches wide) displayed a color photograph of a fetus and included the phrases “Stop Abortion” and “They’re Forgetting Someone.”
- Wilson began wearing the button at work in August 1990; the workplace had no formal dress code.
- Coworkers complained that the graphic image triggered strong emotional reactions, made some feel physically ill, and led some to avoid Wilson’s work area.
- To address workplace disruption, U.S. West offered Wilson options: cover the button while at work, wear a different anti-abortion button without the photograph, or wear the button in a way that was not visible to coworkers.
- Wilson refused, asserting her vow required that specific button be worn visibly.
- U.S. West terminated Wilson after she continued to wear the button uncovered at work.
- Wilson sued under Title VII for religious discrimination; the parties stipulated her religious beliefs were sincerely held.
- After a bench trial, the district court found a prima facie case but entered judgment for U.S. West based on reasonable accommodation and undue hardship findings; Wilson appealed.

## Issues

1. Whether the district court clearly erred in finding that Wilson’s religious vow required wearing the button, but not visibly displaying that specific graphic image at work as a “living witness.”
2. Whether U.S. West satisfied Title VII by offering reasonable accommodations, and whether Wilson’s requested accommodation (visible display) would impose an undue hardship on the employer.

## Decision

- The Eighth Circuit affirmed judgment for U.S. West.
- The district court did not clearly err in finding Wilson’s vow did not require visible workplace display of the specific graphic button.
- U.S. West offered reasonable accommodations by permitting Wilson to keep the button on her person while reducing its visual impact on coworkers.
- Allowing continued visible display of the graphic image, given the documented coworker distress and disruption, would impose an undue hardship.

## Legal Principles

- Under Title VII, once an employee establishes a prima facie case of religious discrimination, the employer avoids liability by showing it offered a reasonable accommodation or that further accommodation would impose an undue hardship.
- “Reasonable accommodation” does not require the employer to provide the employee’s preferred accommodation if an effective, less burdensome alternative is offered.
- An accommodation may be denied when the requested practice causes workplace disruption or burdens that qualify as undue hardship under the governing standard.

## Conclusion

The court held that U.S. West met its Title VII obligations by offering alternatives that allowed Wilson to honor her vow to wear the button while minimizing workplace disruption, and that permitting the button’s continued visible display would have imposed an undue hardship.


Wilson v. U.S. W. Commc'ns, 58 F.3d 1337 (8th Cir. 1995)