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Lizalek v. Invivo Corp.

Citation: 314 F. App'x 881Docket: No. 08-3626

Court: Court of Appeals for the Seventh Circuit; March 16, 2009; Federal Appellate Court

Narrative Opinion Summary

In this case, an employee of Invivo Corporation, identified with multiple religious identities, challenged his termination on the grounds of religious discrimination and retaliation under Title VII of the Civil Rights Act. The employee's unusual practice of using multiple identities in professional interactions caused considerable confusion and concern, leading to his termination for disruptive conduct and poor communication skills. He contended that his religious beliefs, which necessitated these identities, did not conflict with his employment duties. However, the district court upheld the termination, ruling that accommodating his behavior would impose an undue hardship on the employer, as it adversely affected both customer relations and internal communications. The court also concluded that the employee's claim of possible accommodations without cost lacked evidentiary support. Furthermore, the retaliation claim was dismissed, as the decision to terminate was made prior to the filing of any internal discrimination complaint. Consequently, the court affirmed the summary judgment in favor of Invivo, validating the lawfulness of the employee's termination based on the undue hardship and absence of retaliatory intent.

Legal Issues Addressed

Retaliation Under Title VII

Application: The court dismissed the retaliation claim, determining that the decision to terminate the employee preceded his internal discrimination complaint.

Reasoning: Additionally, his retaliation claim was dismissed as Invivo had decided to terminate him before he filed an internal discrimination complaint.

Summary Judgment Standard

Application: The court concluded that summary judgment was appropriate as the employee failed to provide evidence that accommodations could be made without cost.

Reasoning: Lizalek’s assertion that accommodations could be made without cost was unsupported.

Title VII of the Civil Rights Act - Religious Accommodation

Application: The court found that the employer was not required to accommodate the employee's religious practices as it would result in undue hardship on the employer.

Reasoning: The court granted summary judgment for Invivo, stating that accommodating Lizalek’s behavior would impose undue hardship on the company, as it negatively affected customer relations and internal communication.