To establish a claim for employment discrimination based on religious beliefs, an employee must inform an employer of those beliefs prior to an alleged discriminatory action to establish a prima facie case.

Brown asserted claims of unlawful discrimination under Title VII, claiming the defendant unlawfully terminated her after failing to accommodate her unspecified religious beliefs. The court granted the defendant’s motion to dismiss on the basis that the plaintiff failed to allege sufficient facts to support the requisite elements of a Title VII religious discrimination claim because she failed to plead or identify a sincerely-held religious belief that conflicted with the defendant’s policy of annual flu vaccines. The plaintiff alleged only that she advised the defendant on a questionnaire that she was opposed to getting a flu shot, but she did not identify a particular religious belief she held that conflicted with the defendant’s requirement that all employees receive a flu vaccination. Because an employee’s religion often is unknown to the employer, employees must inform employers of their religious beliefs prior to an alleged discriminatory action to make out a prima facie case for discharge based on religion under Title VII.

_{Case Law Alerts, 1st Quarter, January 2019}

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