Ansonia Board of Education v. Philbrook

In Ansonia Board of Education v. Philbrook, 479 U.S. 60, 69, 107 S.Ct. 367, 372, 93 L.Ed.2d 305 (1986), the Supreme Court held that an employer is not required to select the employee's proposal of reasonable accommodation and that any reasonable accommodation by the employer is sufficient to comply with the statute. 479 U.S. at 68-69, 107 S.Ct. at 372. "The employer violates the statute unless it 'demonstrates that it is unable to reasonably accommodate ... an employee's ... religious observance or practice without undue hardship on the conduct of the employer's business.' " Id. at 68, 107 S.Ct. at 371 (quoting 42 U.S.C. Sec. 2000e(j)). When the employer reasonably accommodates the employee's religious beliefs, the statutory inquiry ends. Id. The employer need not show that the employee's proposed accommodations would cause an undue hardship. Id. Undue hardship is at issue "only where the employer claims that it is unable to offer any reasonable accommodation without such hardship." Id. at 68-69, 107 S.Ct. at 372. In Ansonia Board of Educ. v. Philbrook, 479 U.S. 60, 107 S.Ct. 367, 93 L.Ed.2d 305 (1986), the Supreme Court held that the employer need only demonstrate that the proffered accommodation is reasonable, not that it is the most reasonable or the employee's preferred accommodation. "Thus, 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." (Id. at 68, 107 S.Ct. at 372.)