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Philbrook, 479 U.S. 60, 69 (1986) (describing that "bilateral cooperation is ideal in the research for an satisfactory reconciliation of the demands of the employee’s religion and the exigencies of the employer’s business enterprise." (internal quotation marks and citation omitted)) see also Thomas v. Nat’l Ass’n of Letter Carriers, 225 F.3d 1149, 1155 n.5 (10th Cir. 1996) (if negotiations among employer and staff "do not produce a proposal by the employer that would eradicate the spiritual conflict, the employer have to either take the employee’s proposal or reveal that it would trigger undue hardship were being it to do so") Cooper v. Oak Rubber Co., fifteen F.3d 1375, 1378 (6th Cir. Cf. LaFevers v. Saffle, 936 F.2nd 1117 (10th Cir. Mann, 561 F.second 1282, 1286 (eighth Cir. Mann, forum.Zplatformu.Com 561 F.2nd 1282, 1285 (8th Cir. five (E.D.N.Y. Sept. 20, 2001) (holding that employer was not liable for disciplining an worker for tardiness exactly where the staff failed - till after his discharge - to describe that tardiness was because he attended a prayer company), aff’d on other grounds, 318 F.3d one hundred thirty (second Cir. 520, 531 (1993) (holding that despite the fact that animal sacrifice could feel "abhorrent" to some, Santeria is religious in nature and is secured by the First Amendment) Thomas v. Rev. Bd

1994) ("If the employer’s endeavours fail to remove the employee’s religious conflict, the stress remains on the employer to create that it is not able to moderately accommodate the employee’s beliefs without having incurring undue hardship.") EEOC v. Universal Mfg. 70 (referring to sensible accommodation as a single that "eliminates the conflict between employment requirements and religious practices") see also, e.g., EEOC v. Ilona of Hungary, Inc., 108 F.3d 1569 (seventh Cir. See, e.g., EEOC v. Firestone Fibers & Textiles Co., 515 F.3d 307 (4th Cir. 1997) (ruling that employer did not fulfill acceptable accommodation prerequisite by featuring to let Jewish employees take off a working day other than Yom Kippur, for the reason that that would not get rid of the conflict in between faith and work) Opuku-Boateng v. California, ninety five F.3d 1461, 1467 (ninth Cir. But, in apply, even these courts have not applied a regular that is materially distinct from the 1 described higher than, and they just take into account details that the Commission and other courts would examine as appropriate only to undue hardship. Some courts of appeals have appeared to advise that a fair accommodation want only reduce the conflict in between religion and get the job done, even in the absence of a exhibiting that other lodging would impose undue hardship

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