Takeaway: Harassment based on religion is prohibited. It can be based on any of the following: an individual's affiliation with a particular religious group; characteristics, such as dress, associated with a particular religion; the perception or belief that a person is a member of a particular religious group, whether correct or not; or an individual's association with a person or organization of a particular religion.
A federal district court recently refused to dismiss a former employee's claim that a supervisor's attempts to religiously indoctrinate her through a letter and individual meetings created a hostile work environment in violation of Title VII of the Civil Rights Act of 1964.
The plaintiff asserted that in the fall of 2019, her supervisor discussed her Christian faith [GC1] with the plaintiff during one-on-one meetings. In one meeting, the supervisor told the plaintiff that she was involved in her church, taught Sunday school and did not consume alcohol or curse due to her religious beliefs. On a second occasion, the plaintiff disclosed to the supervisor that she was a practicing Hindu, with the intention to discourage the supervisor from attempting to convert the plaintiff.
In April 2020, the supervisor sent an e-mail from her personal account to the plaintiff's personal e-mail account, asking the plaintiff to "consider that the letter is coming from a place of concern." The plaintiff understood this letter as an attempt to convert her to Christianity, but...
Earlier this month, in United States ex rel. Zafirov v. Florida Medical Associates, Inc., the Eleventh Circuit joined four other circuits in holding that the qui tam provisions of the False Claims ...