By: Ty Hyderally, Esq. and Jamie Davila, Esq.

September 21, 2025

The EEOC has recently issued three significant federal appellate decisions that clarify the federal government’s obligations under the federal anti-discrimination laws and provide guidance with regard to the meaning of ‘undue hardship’ in religious accommodations and the protection of the dignity of new mothers at work.

The first two EEOC decisions provide a clear statement of the federal government’s obligation under Title VII to provide its employees with effective and reasonable accommodations for their religious beliefs unless doing so would impose an undue hardship on the government’s operations.

On August 4, 2025, the EEOC rendered a decision in Augustine B. v. VA, EEOC Appeal No. 2023004016. In this case, the Complainant, a Veteran’s Administration doctor, disclosed to the VA that she was Muslim and needed some accommodations so that she could attend Friday weekly prayer services at her mosque.  The physician offered to work additional hours Monday through Thursday and Friday morning to make up for her being excused from work Friday afternoon, so that she would still work the requisite 40 hour work week. After several months of back and forth discussions, the VA finally agreed to permanently excuse Complainant from Friday afternoon work.  However, the VA refused to allow her proposed schedule and instead insisted that she either start working six days a week or transfer to a part-time position with significantly fewer hours.  The physician chose the part-time position because she felt compelled to do so.  The EEOC investigated the matter and found there to be no legitimate reason for the VA to deprive the Complainant two days off from work every week.  The EEOC found that the VA was not able to provide any reasonable explanation for why the doctor had to work Saturdays as opposed to longer workdays during the week.  The EEOC further found that the part-time offer was not reasonable due to the severe reduction in pay to the Complainant and that the Complainant’s request for accommodation would not jeopardize patient care.  The Commission thus found a violation of Title VII of the Civil Rights Act of 1964 (Title VII), as amended, 42 U.S.C. § 2000e et seq., which pertains to religious discrimination.

In Andy B. v. Federal Reserve Board of Governors, the Complainant, a former law enforcement officer with the Federal Reserve, requested a religious exemption to the Federal Reserve’s COVID-19 vaccine mandate. The Federal Reserve denied the request and swiftly fired Complainant. The appeal was based on whether the Federal Reserve unlawfully deprived the Complainant of an effective reasonable accommodation for his religious beliefs in violation of Title VII. The EEOC found that it did as the Complainant’s religious beliefs were sincere, and the Federal Reserve did not persuasively show that an effective accommodation would have imposed an undue hardship on its operations. The EEOC was also persuaded that the Complainant was subjected to unlawful harassment based on his religious beliefs and his request for religious accommodation.

In the third decision from the EEOC, Kasie L. v. United States Postal Service, the Complainant was a new mother working at the United States Postal Service Processing & Distribution Center in Columbus, Ohio. A manager first allowed the Complainant to use a vacant conference room, which was private and clean, to express breast milk for her newborn son as needed. Later, another manager stepped in to prohibit the Complainant from using the conference room. The second manager instructed Complainant to use the employee bathroom for her lactation needs instead.  The EEOC found the United States Postal Service liable for discriminatorily requiring a new mother to use the employee bathroom for her lactation needs when other clean private areas were readily available. The EEOC concluded that the USPS’ decision to exclude its employees from available, clean and private spaces for lactation was tainted by discriminatory bias and therefore unlawful.  This finding is consistent with the Pregnant Workers Fairness Act which requires employers to provide reasonable accommodation to workers affected by pregnancy, childbirth, or related medical conditions, unless doing so would cause undue hardship.

If you feel that you are being a target of discriminatory treatment or not being accommodated due to your religious beliefs, or if you have any questions regarding your rights as an employee, you should seek out an experienced attorney who concentrates in employment law. Our firm has been concentrating in employment law for over twenty-two (22) years!

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