July 21, 2026

Title VII

In order to state a prima facie case of failure to accommodate religious belief or practice under Title VII, a plaintiff must demonstrate (1) that he actually required an accommodation of his religious practice, and (2) that the employer’s desire to avoid the actually required prospective accommodation was a motivating factor in (3) an adverse employment decision.

Bergin v. N.Y. State Unified Court System, 2d Cir. July 15, 2026)