Nigerian Man Can Bring Religious Bias Suit, 7th Circ. Says
Law360, Los Angeles (July 31, 2013, 6:09 PM ET) -- The Seventh Circuit on Wednesday reopened a Nigerian expatriate's religious discrimination suit alleging his U.S. employer fired him after he took leave to lead his father's burial rites in Nigeria, ruling a jury could reasonably find he had given his employer adequate notice of the religious nature of the ceremony.
The three-judge panel reversed the lower court's ruling granting summary judgment to Heartland Sweeteners LLC, ruling Sikiru Adeyeye's requests for five weeks of unpaid leave to preside over his father's burial rites contained sufficient details to convey the ceremony's religious character.
"A reasonable jury could certainly find that the letter's multiple references to spiritual activities and the potential consequences in the afterlife provided sufficient notice to Heartland that Adeyeye was making a religious request," U.S. Circuit Judge David Hamilton said in the opinion.
Attorneys for Adeyeye and Heartland did not immediately respond to requests for comment Wednesday.
Adeyeye, who moved from Nigeria to the U.S. in 2008, sued Carmel, Ind.-based Heartland for religious discrimination under Title VII in August 2011. He is described in court documents as a Christian whose beliefs incorporate elements of traditional African religious practices.
Following his father's death in Nigeria in May 2010, Adeyeye made two requests to Heartland for five weeks of unpaid leave to preside over his father's burial rites, according to the opinion. Heartland denied both requests, but Adeyeye still went to Nigeria in October 2010 to lead the rites, and upon returning to Indiana, he was fired, court documents said.
U.S. District Judge William T. Lawrence granted summary judgment in favor of Heartland in December, saying Adeyeye's two written requests for leave didn't offer sufficient details for a reasonable jury to find that he had provided notice to Heartland of the religious character of his requests.
But the Seventh Circuit disagreed, holding that, while the letters didn't contain explicit references to religion, they included enough details to raise a genuine issue of fact as to whether Heartland was aware of the requests' religious nature. The letters referred to a "funeral ceremony," a "funeral rite" and animal sacrifice, and Adeyeye indicated it was his customary duty as the first-born and only son in his family to lead the burial rites, the opinion said.
Adeyeye said that, if he failed to participate in the ceremony, he and his family members would suffer "at least a spiritual death," according to the opinion.
While the religious practices and beliefs Adeyeye referred to are not as familiar as those closer to the "modern American mainstream," Judge Hamilton wrote, Title VII protections "are not limited to familiar religions."
Heartland had argued that it was entitled to summary judgment because Adeyeye had participated in his father's funeral rites not because of sincere religious beliefs but out of his perceived duties as a son, which are not protected under Title VII. But the appeals court said the evidence Adeyeye presented was sufficient to show his request to attend his father's funeral stemmed from his own personally and sincerely held religious beliefs.
Furthermore, examining an individual's conscious and subconscious motives for holding beliefs is not appropriate territory for the courts, Judge Hamilton wrote.
"We are not and should not be in the business of deciding whether a person holds religious beliefs for the 'proper' reasons," the opinion said.
The appeals court reversed Judge Lawrence's decision granting summary judgment to Heartland and remanded the case for further action.
U.S. Circuit Judges David Hamilton and Diane Sykes and U.S. District Judge J.P. Stadtmueller sat on the panel for the Seventh Circuit.
Adeyeye is represented by Jeffrey A. Macey of Macey Swanson & Allman.
Heartland is represented by James Braden Chapman II of Benesch Friedlander Coplan & Aronoff LLP.
The case is Sikiru Adeyeye v. Heartland Sweeteners LLC, case number 12-3820, in the U.S. Court of Appeals for the Seventh Circuit.
--Editing by Elizabeth Bowen.
The three-judge panel reversed the lower court's ruling granting summary judgment to Heartland Sweeteners LLC, ruling Sikiru Adeyeye's requests for five weeks of unpaid leave to preside over his father's burial rites contained sufficient details to convey the ceremony's religious character.
"A reasonable jury could certainly find that the letter's multiple references to spiritual activities and the potential consequences in the afterlife provided sufficient notice to Heartland that Adeyeye was making a religious request," U.S. Circuit Judge David Hamilton said in the opinion.
Attorneys for Adeyeye and Heartland did not immediately respond to requests for comment Wednesday.
Adeyeye, who moved from Nigeria to the U.S. in 2008, sued Carmel, Ind.-based Heartland for religious discrimination under Title VII in August 2011. He is described in court documents as a Christian whose beliefs incorporate elements of traditional African religious practices.
Following his father's death in Nigeria in May 2010, Adeyeye made two requests to Heartland for five weeks of unpaid leave to preside over his father's burial rites, according to the opinion. Heartland denied both requests, but Adeyeye still went to Nigeria in October 2010 to lead the rites, and upon returning to Indiana, he was fired, court documents said.
U.S. District Judge William T. Lawrence granted summary judgment in favor of Heartland in December, saying Adeyeye's two written requests for leave didn't offer sufficient details for a reasonable jury to find that he had provided notice to Heartland of the religious character of his requests.
But the Seventh Circuit disagreed, holding that, while the letters didn't contain explicit references to religion, they included enough details to raise a genuine issue of fact as to whether Heartland was aware of the requests' religious nature. The letters referred to a "funeral ceremony," a "funeral rite" and animal sacrifice, and Adeyeye indicated it was his customary duty as the first-born and only son in his family to lead the burial rites, the opinion said.
Adeyeye said that, if he failed to participate in the ceremony, he and his family members would suffer "at least a spiritual death," according to the opinion.
While the religious practices and beliefs Adeyeye referred to are not as familiar as those closer to the "modern American mainstream," Judge Hamilton wrote, Title VII protections "are not limited to familiar religions."
Heartland had argued that it was entitled to summary judgment because Adeyeye had participated in his father's funeral rites not because of sincere religious beliefs but out of his perceived duties as a son, which are not protected under Title VII. But the appeals court said the evidence Adeyeye presented was sufficient to show his request to attend his father's funeral stemmed from his own personally and sincerely held religious beliefs.
Furthermore, examining an individual's conscious and subconscious motives for holding beliefs is not appropriate territory for the courts, Judge Hamilton wrote.
"We are not and should not be in the business of deciding whether a person holds religious beliefs for the 'proper' reasons," the opinion said.
The appeals court reversed Judge Lawrence's decision granting summary judgment to Heartland and remanded the case for further action.
U.S. Circuit Judges David Hamilton and Diane Sykes and U.S. District Judge J.P. Stadtmueller sat on the panel for the Seventh Circuit.
Adeyeye is represented by Jeffrey A. Macey of Macey Swanson & Allman.
Heartland is represented by James Braden Chapman II of Benesch Friedlander Coplan & Aronoff LLP.
The case is Sikiru Adeyeye v. Heartland Sweeteners LLC, case number 12-3820, in the U.S. Court of Appeals for the Seventh Circuit.
--Editing by Elizabeth Bowen.
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