State Division of Human Rights v. Carnation Co., 42 N.Y.2d 875 (1977)
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An employer’s duty to accommodate an employee’s religious observance is limited by the undue economic hardship exception, which does not require a threat to the employer’s economic stability but can be established by a palpable increase in costs or risk to industrial peace.
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Summary
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The New York Court of Appeals addressed whether Carnation Company discriminated against an employee by failing to accommodate his religious observance of the Sabbath. The court held that the record was insufficient to determine if accommodating the employee would have caused undue economic hardship to the employer. The court clarified that undue hardship does not require a threat to the company’s economic stability, but can be established by a palpable increase in costs or risk to industrial peace. The case was remitted for an evidentiary hearing to determine if accommodating the employee’s schedule would create such hardship.
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Facts
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An employee alleged that Carnation Company discriminated against him based on his religious observance of the Sabbath. He claimed the company failed to accommodate his religious needs regarding his Saturday work schedule. The specific details of the employee’s position and the proposed accommodations are not explicitly stated in the opinion, but the core issue revolves around his request to observe his Sabbath without jeopardizing his employment.
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Procedural History
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The Division of Human Rights initially heard the case. The Human Rights Appeal Board issued an order that was favorable to the employee. The Appellate Division reversed the Appeal Board’s order. The New York Court of Appeals then reversed the Appellate Division’s order, reinstating the order of the Human Rights Appeal Board and remitting the case to the Division of Human Rights for an evidentiary hearing.
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Issue(s)
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Whether the employer, Carnation Company, demonstrated that accommodating the employee’s religious observance of the Sabbath would cause undue economic hardship, thereby excusing them from the requirement to accommodate the employee under New York Executive Law § 296(10)(c).
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Holding
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No, because the record was not sufficiently developed to determine, as a matter of law, whether retaining the complainant in his former position would have resulted in undue economic hardship to the employer. The case was remitted for an evidentiary hearing to determine the economic impact of accommodating the employee’s schedule. The court held that an undue economic hardship does not require a threat to the employer’s economic stability; a palpable increase in costs or risk to industrial peace would suffice.
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Court’s Reasoning
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The court focused on the