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A female Muslim employee sued her former employer under Title VII and the District of Columbia Human Rights Act (DCHRA) for discrimination based on religion. The plaintiff claimed that she was suspended and then terminated from her job for failing to remove her religiously mandated head-covering (ḥijāb). The Court granted the defendant’s motion to dismiss, concluding that the plaintiff’s claim was untimely, having passed the statute of limitations for both Title VII and the DCHRA.

Muslim inmate John McGlothlin brought a case under §1983, alleging that the prison chaplain and other prison officials violated his right to free exercise under the First Amendment. The plaintiff claimed that Muslim inmates were treated differently from fellow inmates of other religious beliefs, exemplified by comparing the announcements on the bulletin board for Muslims with one run by the Christian Fellowship. A report by the U.S. Magistrate recommended that this case should be dismissed, and the District Court agreed. Specifically, the Court found that the plaintiff’s claims against the prison’s non-denominational chaplain should be dismissed as the chaplain was not a state actor; it further dismissed the claims against the other officials because the plaintiff’s claims failed to demonstrate a disparity of treatment based on religion.

The Plaintiffs, two Muslim prisoners, challenged prison policies that 1) failed to provide adequately nutritional ḥalāl meals, and 2) denied them the ritual end-of-Ramadan feast. The District Court found that the ḥalāl meals provided did not substantially burden the Plaintiffs' religious practice. The District Court also decided that although the denial of the ritual feast marking the end of Ramadan substantially burdened the Plaintiffs' beliefs, the prison demonstrated that this policy was the least restrictive means of achieving the government's interest in security.

William Knuckles and several other inmates, all adherents of the Nation of Islam, filed a §1983 claim against prison officials, alleging a violation of their First and Fourteenth Amendment rights. Specifically, they alleged that they were not allowed to correspond with their religious leaders, receive books and periodicals, "wear Muslim medals," or have a special dietary plan. In finding that the inmates were entitled to be visited by qualified ministers, the Court cautioned that all meetings should remain of a religious nature and could be supervised by prison officials.

Plaintiff James McRoy claimed that prison officials violated his First Amendment free exercise rights by cancelling some of the scheduled Muslim prayer services without notice, limiting the number of services that Muslim inmates could attend each week, limiting the number of Muslim inmates who could attend each service at any given time, subjecting Muslim inmates to strip searches before they could leave their cells to attend services, prohibiting imams from bringing religious publications onto the prison’s premises, and prohibiting Muslim inmates from exclusively living together in one of the prison’s living units. The prison officials, however, claimed that their actions resulted from a lack of volunteers to organize services and the need to curtail inmate movement on some days because of heightened security concerns. The Court held that McRoy did not sufficiently demonstrate that a jury could conclude that he had been subjected to a violation of his rights. It thus entered summary judgment in favor of the defendants.

A former Islamic prison chaplain sued his former employer, the State of Maryland, under Title VII, alleging that the State created a hostile work environment, subjected him to constructive discharge, and was liable for breach of contract for failing to abide by the terms of an earlier attempted settlement. The plaintiff alleged that he was harassed because of his religion for several years, including being involved in physical altercations with other non-Muslim employees, while working as an Islamic chaplain, and that this led to a hostile work environment and to his constructive discharge. The Court dismissed the contract claim, as the state has sovereign immunity under the Eleventh Amendment; but the Court denied the State’s motion for summary judgment on the other two counts, concluding that the plaintiff had established a prima facie case of discrimination.

A Lebanese Muslim physician sued his former employer, represented by Secretary of Veteran Affairs Jim Nicholson, alleging religious and national-origin discrimination under Title VII. The plaintiff claimed that the VA Medical Center, his place of employment, subjected him to a hostile work environment based on his identity as both Lebanese and Muslim [presumably related to his observance of Islamic ritual law] and that his supervisors retaliated against him for filing a claim with the EEOC. He further argued that the employer's discrimination ultimately led to his termination. The Court granted the defendant’s motion for summary judgment, concluding that the plaintiff had failed to exhaust his administrative options before initiating a lawsuit in court, and that he had not demonstrated that his termination was retaliatory.  

Representing an Arab-American Muslim former employee of the Omni Hotels, the EEOC sued the hotel chain under Title VII, alleging religious and national-origin discrimination. The plaintiff claimed that the company fired the employee from his position because he was vocal in his community regarding American-Islamic relations following the events of 9/11. The company argued that his termination resulted from the employee’s lackluster sales at the hotel he was managing, and that the plaintiff resigned for his own personal reasons. The court granted the defendant’s motion for summary judgment, concluding that, while the plaintiff made out a prima facie case of discrimination, it failed to provide evidence showing that the defendant’s defense was a pretext for discriminatory intent.

A Muslim-naturalized American citizen of Egyptian national origin sued Homeland Secretary Michael Chertoff, along with officials at the Transportation Security Administration, under Title VII, as well as under the Civil Service Reform Act (CSRA), the Fifth Amendment, the Freedom of Information Act, and the Privacy Act, alleging discrimination based on religion and national origin. The plaintiff was suspended from work with the Federal Aviation Administration after he failed to obtain a security clearance renewal following 9/11, and the plaintiff alleged that his security clearance was not renewed because he was Egyptian and Muslim. The defendant claimed that the Administration did not control who receives a security clearance, and that their action suspending him was merely a result of his failure to maintain his previous level of clearance. The Court held that the plaintiff failed to make a prima facie case of religious or national-origin discrimination [with no allegation of barring practices of Islamic ritual law, for example] as articulated by McDonnell Douglas, and that without the security clearance, he was no longer qualified for his job. Accordingly, the Court granted the defendant’s motion for summary judgment.

Mr. Zafar Hasan, a Muslim of Indian heritage, sued his former employer, Foley & Lardner LLP, under Title VII, alleging discrimination based on religion, race, national origin and color. The plaintiff claimed that his work assignments were cut and he was ultimately terminated because he was Muslim. For support, he points to the cut in his assignments that occurred immediately after 9/11, a comment made by one partner that “those people [Muslims] don’t belong here…they should kick them all out,” a warning by another partner to be careful about displaying articles the plaintiff had written on his view that Islam is a peaceful religion, and the fact that the other two Muslims in his department were either transferred or terminated in the same time period. The defendant company responds that it cut Mr. Hasan’s work and then terminated him due to poor work performance. The Circuit Court reversed and remanded the District Court for the Northern District of Illinois’s grant of the defendant’s motion for summary judgment, concluding that the plaintiff had presented enough direct evidence of religious discrimination to allow the case to move forward.

The EEOC represented a group of Muslims suing their former employer, Norwegian Cruise Lines, under Title VII, alleging religious and national-origin discrimination. The plaintiffs claimed that these discriminatory motives caused the company to target them for increased scrutiny, to create a hostile work environment by allowing their co-workers to verbally harass them (in part, by referring to them as terrorists), and finally, to terminate them. The plaintiffs further entered a complaint for negligent infliction of emotional distress on these bases. The defendants argued that they terminated the plaintiffs for inconsistent answers given to background questions and because they were “positive matches in the FBI database.” The Court dismissed the claim of negligent infliction of emotional distress, but concluded that the discrimination case could go forward as plaintiffs had established a prima facie discrimination case such that a jury could find that the company’s reasons given for terminating the plaintiffs were pretexts for a discriminatory reason.

A Pakistani Muslim bank employee suffering from irritable bowel syndrome (IBS) sued his former employer, Bank of America, under Title VII alleging discrimination on the basis of religion and national origin; under the American Disabilities Act (ADA) for discrimination on the basis of disability; and under Title VII and the ADA for retaliatory firing following his filing a complaint with the Equal Employment Opportunity Commission (EEOC).  Specifically, the plaintiff argued that his religious beliefs required him to take several prayer breaks throughout the workday, and that this practice ultimately led to his firing. The defendant responded that the employee was fired because of poor work performance. The Court found that the plaintiff failed to make out a prima facie case of discrimination, and that, even if he did, the defendant had provided a legitimate, non-discriminatory reason for terminating his employment that the plaintiff did not dispute. The Court entered summary judgment in favor of the defendant company and dismissed the retaliation claim, concluding that the plaintiff had established no connection between the EEOC filing and his termination. 

Plaintiff Skwikar Abdelkader alleged a Title VII violation against her former employer, Sears, for failing to accommodate her religion (Islam). The plaintiff alleged that Sears failed to accommodate her religious beliefs by asking her for work on Fridays (the day of communal Muslim prayer services) and on Muslim holidays; she also alleged that the company retaliated against her after she reported the alleged discrimination internally to the Human Resources department. The defendant responded that they neither forced her to work those days nor punished her for refusing to do so; it further noted that she was fired because she violated company policy by allowing a cashier to use her management discount card without the direct supervision required. The Court concluded that the plaintiff failed to present a prima facie case of discrimination or retaliation, finding that the company equally punished non-Muslims for misuse of the discount card. On that basis, the Court held that no disparate treatment occurred and therefore granted the defendant’s motion for summary judgment.

The plaintiff, a Muslim occupational health physician, sued his former employer, the Department of Veteran Affairs and its Secretary, Jim Nicholson, under Title VII, alleging religious discrimination and retaliation for filing a discrimination claim with the Equal Employment Opportunity Commission (EEOC). He filed the claim after he heard his supervisor refer to Muslims as a threat and after his supervisor’s wife made comments about how she and her husband do not like Muslims and the way they live—presumably referring to his observance of prayers, fasting, and other aspects of Islamic ritual law. The plaintiff discovered that his position was being eliminated sometime after these comments were made, but continued to consult with his former employer about infectious diseases. Three months following his position’s elimination, the plaintiff saw a job advertisement for the same position at his former place of employment and filed a claim with the EEOC for discrimination. Immediately after his supervisor found out about his claim, the plaintiff contends that he was no longer allowed on the property and that other employees were barred from contacting him for consultations. The Court concluded that the timing was questionable enough that a jury could find that the events described were examples of retaliation. The Court reversed and remanded the decision of the District Court for the Southern District of Mississippi to grant Defendant’s motion for summary judgment, allowing the case to go forward. The parties ultimately settled the case, and the case was closed in December of 2008.

At a meeting in Lucknow on February 5, 2023, the All India Muslim Personal Law Board (AIMPLB) passed a resolution opposing the Indian government’s proposed Uniform Civil Code. The Board noted that the proposed UCC was “neither relevant nor beneficial for a multi-religious, multi-cultural and multi-lingual country like India.” The Board further expressed concerns that the UCC would divide India along religious and cultural lines, and that it would erode safeguards around religious freedom and equality.

The plaintiff, Michael Mootry, sued prison officials for implementing a policy that he claimed constituted a violation of his First Amendment rights. The policy banned inmate ministers from leading religious services without the direct supervision of a hired chaplain or volunteer. As a result of this policy, for two years, Muslim inmates were not accommodated with a hired chaplain to supervise jumu'a (Friday prayer) services. The Court denied the defendants' motion to dismiss because it found that the defendants knew about the plaintiff being prevented from participating in the prayer services, that this was an ongoing issue, and that they did nothing to correct the situation.

Plaintiff Dorian Davis challenged the Kern Valley State Prison policy that prohibited Muslim prisoners from purchasing and possessing prayer oils in their cells. The prison officials, however, claimed that a compelling governmental interest made their policy the least restrictive means of ensuring prison safety. The District Court agreed with them, determining that the prison did not violate the plaintiff's First Amendment rights because the Muslim chaplain had previously provided contraband to prisoners; in addition, it found that RLUIPA rights were not violated because the prison had to cancel Friday prayer services until another Muslim chaplain could be hired.

The plaintiff, Amr Elmenayer, sued his former employer, ABF Freight Systems, for failure to accommodate his religious practices and disparate treatment due to religion under Title VII. The plaintiff alleged that his supervisor failed to grant his reasonable request to attend Friday (jumu'a) prayer services. He also alleged that he was treated more harshly than other non-Muslim employees when he was terminated for failing to report an accident in a timely fashion, as per the company's policy. The defendant argued that it did try to accommodate the plaintiff’s religious practices by encouraging him to bid for a shift that would not conflict with his prayer duties. The Court granted the defendant’s motion for summary judgment, concluding that the plaintiff had not made out a prima facie case of discrimination. This decision was affirmed in Elmenayer v. ABF Freight Sys., 318 F.3d 130 (2d Cir. 2003).

Plaintiff Tabari Strong, a Muslim prisoner in Beeville, Texas, filed a lawsuit alleging that the prison's grooming policy requiring all inmates to be clean-shaven violated his statutory rights under RLUIPA. He also claimed that the policy violated his right to exercise his religion under the First Amendment, and that enforcement of the policy violated his right to equal protection under the Fourteenth Amendment. The plaintiff filed a motion for summary judgment, claiming that he is entitled to a declaratory judgment. The District Court refused to grant the plaintiff's request for injunctive relief as an "extraordinary remedy," but maintained that it would be contrary to justice not to grant the relief requested by the plaintiff to have a quarter-inch beard.

The plaintiff sued her former employer, Neiman Marcus, under Title VII, alleging discrimination based on religion, race, color, and national origin; failure to accommodate her religion; failure to stop harassment; and retaliation for her filing of a religious and national origin discrimination claim with the Equal Employment Opportunity Commission (EEOC), which allowed her suit to proceed in court. The defendant company argued that, because of the statue of limitations, the plaintiff failed to make a claim. Many of the plaintiff’s claims, including allegations of her co-worker directing racial epithets at her, and being compelled to work on religious holidays, were time-barred and thus could not be introduced to the court. The court found that the plaintiff failed to make a prima facie case of discrimination as required by McDonnell Douglas, concluding that she did not prove that she was treated differently because of her religion, race, or national origin. Accordingly, the Court granted summary judgment in favor of the defendant company on these claims; however, the Court denied the company’s motion for summary judgment on the hostile work environment claim, concluding that a jury could consider allegations that the company permitted so-called sale-stealing, when an employee rings up the sale of a client that a co-worker was working with thereby receiving their commission, to be an adverse employment action in the claim that was not time-barred, and thus the suit on this issue could move forward.