Title VII of the federal Civil Rights Act of 1964 - Interpretation

In Pinsker and Aurora Educ. Ass'n v. Joint Dist. No. 28J of Adams and Arapahoe Counties, 735 F.2d 388 (10th Cir. 1984), the court held that Title VII of the federal Civil Rights Act of 1964 "does not require employers to accommodate the religious practices of an employee in exactly the way the employee would like to be accommodated." Id. at 390. Further, Title VII "requires only 'reasonable accommodation,' not satisfaction of an employee's every desire." Wright v. Runyon, 2 F.3d 214, 217 (7th Cir. 1993). Also, the U.S. Supreme Court stated in Ansonia Bd. Of Educ. v. Philbrook, 479 U.S. 60, 93 L. Ed. 2d 305, 107 S. Ct. 367 (1986), that "where the employer has already reasonably accommodated the employee's religious needs, the statutory inquiry is at an end. The employer need not further show that each of the employee's alternative accommodations would result in undue hardship." 479 U.S. at 68. In determining whether an individual will be deemed an "employee" for Title VII purposes, "one must examine the economic realities underlying the relationship between the individual and the so-called principal in an effort to determine whether that individual is likely to be susceptible to the discriminatory practices which the act was designed to eliminate." Armbruster v. Quinn, 711 F.2d 1332, 1340 (6th Cir. 1983).