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70 (referring to realistic accommodation as 1 that "eliminates the conflict in between work requirements and spiritual practices") see also, e.g., EEOC v. Ilona of Hungary, Inc., 108 F.3d 1569 (7th Cir. 1994) ("If the employer’s attempts fail to do away with the employee’s religious conflict, the burden remains on the employer to set up that it is unable to moderately accommodate the employee’s beliefs without the need of incurring undue hardship.") EEOC v. Universal Mfg. Notwithstanding the distinct lawful specifications for figuring out when a failure to accommodate poses an undue hardship less than Title VII and the ADA, see supra notes 5 and 6, courts have endorsed a cooperative data-sharing procedure among employer and employee for religious accommodation requests, related to the "interactive process" used for incapacity accommodation requests under the ADA. Some courts of appeals have appeared to suggest that a fair accommodation require only lessen the conflict between religion and do the job, even in the absence of a demonstrating that other lodging would impose undue hardship. Tex. 2009) (keeping in Title VII circumstance that a ethical and ethical belief in the electricity of desires that is primarily based on spiritual convictions and traditions of African descent is a religious perception, and that this resolve does not flip on veracity but rather is dependent on a idea of "‘man’s mother nature or his spot in the Universe,’" even if considered by other people to be "eccentric" (quoting Brown v. Dade Christian Schs., Inc., 556 F.second 310, 324 (fifth Cir

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1993) (employee’s request for leave to take part in his wife’s spiritual conversion ceremony was enough to put employer on observe that this was pursuant to a religious exercise or belief an employer need to have have "only enough information about an employee’s spiritual requirements to permit the employer to fully grasp the existence of a conflict amongst the employee’s spiritual techniques and the employer’s career requirements"). 1990) (per curiam) (district courtroom "erred in ruling that, absent a displaying of undue hardship by an employer, accommodating only one of the two practices of the employee’s faith, equally of which conflicted with the employee’s operate obligations, contented as a issue of law the duty of ‘reasonable accommodation’") Baker v. Home Depot, 445 F.3d 541, 547-48 (2d Cir. 1997) (ruling that employer did not fulfill realistic lodging necessity by presenting to permit Jewish workers take off a day other than Yom Kippur, because that would not reduce the conflict among faith and operate) Opuku-Boateng v. California, 95 F.3d 1461, 1467 (9th Cir