In Brown v. Polk County, 61 F.3d 650 (8th Cir.1995) (en banc), the Court confronted a worded provision. The administrator of Polk County, Iowa, ordered that a county employee "immediately cease any activities that could be considered to be religious proselytizing, witnessing, or counseling...." Id. at 652. The Court held that this mandate violated the employee's rights under the Free Exercise Clause of the First Amendment because "it would seem to require no argument that to forbid speech 'that could be considered' religious is not narrowly tailored to the aim of prohibiting harassment...." Id. at 659. The Court noted, "Because the first reprimand related directly to religious activities by Mr. Brown, we agree with the district court that the defendants were well aware of the potential for conflict between their expectations and Mr. Brown's religious activities." Id. at 654. The court concluded that the employer violated Title VII when it fired Brown (without attempting accommodation) based on the religious activities giving rise to the first reprimand. See id. at 657. Brown thus stands for the precise proposition that the majority rejects: Religious conduct violating employment requirements may be sufficient to put an employer on notice of the need to accommodate the religious practice.