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An employer may accommodate the employee’s religious perception by substituting an substitute system or strategy that does not conflict with the employee’s religious perception or by excusing the personnel from that component of the teaching program that poses a conflict, if doing so would not pose an undue hardship. 8 (E.D. Wash. May 3, 2017) (keeping plaintiff could move forward with retaliatory termination claim when he was fired for alleged lousy functionality two days immediately after he complained to administration about supervisor’s proselytizing, management took no steps to look into, and supervisor confronted him about complaint). Alternatively, an worker might argue merely that mandating attendance in a religious provider, devoid of exception, adversely impacts the phrases and situations of work based mostly on faith. For a discussion of both of those Title VII and Establishment Clause statements arising from holiday break decorations in federal govt work context, see, e.g., Spohn v. West, No. 00 CIV. Cir. 2014) (collecting instances) see also nine Lex K. Larson, Employment Discrimination § 154.10, at 154-105 & n.25 (2nd ed. 2014) ("In addition to the activities specifically shielded by the statute, courts have observed that requesting fair accommodation is a shielded exercise."). In a associated context, most courts have assumed or held that requests for disability accommodation are secured activity