Sikiru Adeyeye asked his employer, Heartland Sweeteners, for several weeks of unpaid leave to return to his native Nigeria to lead his father’s burial rites.
He explained that his attendance was “compulsory”; that it was “important” for him to be there “according to our custom and tradition”; that if he failed to participate, he and his family would suffer spiritual death; and he explained that the rites included killing five goats. After the company denied Adeyeye’s request, he traveled to Nigeria anyway and was fired.
Although the U.S. District Court in Indianapolis granted summary judgment for Heartland, the U.S. Court of Appeals for the 7th Circuit in Chicago reversed the decision and held that a jury could find that Adeyeye’s requests provided Heartland with “fair notice” of the religious nature of his request since employers are required to “be alert enough to grasp that the request is religious in nature … [and if it] is not certain, managers are entitled to ask the employee to clarify the nature of the request.” Adeyeye v. Heartland Sweeteners, No. 12-3820, 7th Cir., (July 31, 2013).
IMPACT: Employers are required to accommodate an employee’s requests relating to religious beliefs if they have fair notice that the request is religious in nature. An extended funeral rite is rare, but employers must consider the issue of religious accommodation when it comes to time off for funerals or other religious rites.