Dive Brief:
- A Christian former employee of Honeywell alleged the company illegally discriminated against him on the basis of his religion when it fired him for refusing to retake a mandatory unconscious bias training, according to a lawsuit filed Feb. 28.
- In Wright v. Honeywell International, Inc., the plaintiff said he completed the training in 2022 but claimed that it “exemplified a belief system that divides human beings into discreet groups based on immutable characteristics,” ideas that “implicitly and explicitly reject” his sincerely held religious beliefs. He further alleged that Honeywell asked him to complete the training a second time in 2024 and would not grant his request for religious accommodation when he asked for an exemption or for alternative training.
- The plaintiff claimed that Honeywell’s HR department threatened immediate termination over his refusal to complete the training in violation of Title VII of the 1964 Civil Rights Act. Honeywell did not respond to a request for comment.
Dive Insight:
Honeywell previously faced a challenge to its mandatory unconscious bias training program from an Illinois employee who was allegedly fired for refusing to complete it. The plaintiff in the case, Vavra v. Honeywell International, Inc., alleged that his firing constituted race discrimination under state and federal laws. The 7th U.S. Circuit Court of Appeals sided with Honeywell and agreed with a district court in holding that the plaintiff’s refusal did not constitute protected activity.
There are some differences between the two cases’ circumstances, however. Aside from the different categories of discrimination alleged by the plaintiffs, the employee in Vavra had never accessed the training or its contents. This undermined his claim, per the 7th Circuit, because an employee must have some knowledge of an employer’s opposed conduct in order to show an objectively reasonable belief that such conduct violated Title VII.
In Wright, the employee requested an exemption after already completing the training once, per the complaint. He claimed that Honeywell “categorically denied” his request without engaging in any interactive process or offering an alternative to the training.
But an employee’s sincerely held religious belief may not necessarily be enough to exempt them from mandatory training. In 2022, a Maryland federal jury concluded that an employee’s religious beliefs did not conflict with a mandatory ethics course that required him to answer questions about the harassment of a transgender co-worker.
At the same time, the Wright plaintiff alleged that accommodating his religious beliefs would not have posed an undue hardship. That language is key given a 2023 U.S. Supreme Court decision that raised the bar employers must meet to deny an employee’s religious accommodation request within the context of Title VII. Specifically, the high court said employers must show that a proposed accommodation presents a burden that is substantial in the overall context of an employer’s business in order to show undue hardship.
“It would not have been an undue hardship for a corporation with Honeywell’s resources to provide an accommodation to [the plaintiff] in the form of non-objectionable training or, for example, not requiring him to retake training he had already completed,” according to the complaint. “Said differently, it would have been a near zero cost to permit those employees — such as [the plaintiff] — with a religious objection to only submit to the training once.”
Management-side attorneys who previously spoke to HR Dive noted that employers may seek to change their training policies around sensitive subjects such as unconscious bias, especially in the diversity, equity and inclusion context, given a volatile political climate on the topic. For example, employers could make such training voluntary. Other possibilities include specifying that the intent of training is not to change employees’ beliefs or values but to establish expectations and standards of conduct.
