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The Muslim plaintiff sued her former employer, Supervalu Holdings, under Title VII, alleging religious discrimination. Specifically, she argued that the company overlooked her for a position with more responsibility because of her religion. The court held that the plaintiff failed to establish a prima facie case of discrimination, as she neither proved that non-Muslims were treated better, nor did she allege that she suffered an adverse employment action (as the higher-level position did not offer additional compensation or benefits). Thus, this Court affirmed the U.S. District Court for the Western District of Pennsylvania’s granting of the defendant’s motion for summary judgment.

Prison inmate Lawrence Cochran filed a §1983 claim against prison officials for allegedly violating his First Amendment rights by not allowing him to have food in his cell at night to break the Ramadan fast and by limiting his attendance of religious services. The Court granted the motion for summary judgment in favor of the defendants, holding that incarceration necessarily curtails some freedom, and that, in this context, the curtailment did not go so far as to place a substantial burden on Muslim inmates’ ability to practice their religion.

The plaintiff, Raymond Miller, brought this action pursuant to 42 U.S.C. § 1983, alleging that the defendants, employees at the St. Lawrence County Correctional Facility (New York), violated his free exercise rights under the First Amendment by restricting his ability to practice Islam. The plaintiff alleged that the defendants only allowed him to wear his kufi headgear when inside his cell. The District Court granted the defendants' motion for summary judgment, determining that the defendants' policies were not irrational or unreasonable, and that the plaintiff had failed to demonstrate "that a more reasonable accommodation could have been made."

An Indian Muslim physician, who formerly worked at a Veteran Affairs Medical Center, sued the Secretary of Veteran Affairs under Title VII, alleging discrimination based on race, religion, and national origin; the failure to promote; retaliation; a hostile work environment; and constructive discharge.  The defendant argued that the plaintiff did not receive a promotion due to unsatisfactory work performance. Concluding that the plaintiff did not prove he suffered an adverse employment action and therefore failed to make out a prima facie case of discrimination, the Court granted the defendant’s motion for summary judgment.

An Iranian Muslim professor sued his former employer, Case Western Reserve University, under Title VII, alleging discrimination on the basis of religion and nation origin. Specifically, the plaintiff alleged that he was denied scheduled performance reviews and ultimately tenure because of his race and religion. The University argued that the professor was not qualified for tenure. The Court denied the defendant’s motion for summary judgment, concluding that the plaintiff’s qualification for tenure is a matter of fact, and as such, must be decided by a jury. The case was ultimately settled on June 26, 1998.

A Muslim former Naval engineer sued the Secretary of the Navy under Title VII, alleging discrimination based on religion and national origin. Specifically, the plaintiff claimed that he was subjected to ethnic slurs and jokes, leading to a hostile work environment. The Court adopted the report by the magistrate judge granting the motion for summary judgment in favor of the defendant, concluding that the plaintiff failed to exhaust proper administrative remedies before bringing the case to court. The Court further noted that it lacked subject matter jurisdiction over the compensatory damage issue.

A Muslim worker sued the defendant, the Philadelphia Housing Authority, under Title VII and §1983, claiming that he was terminated from employment due to his Muslim religion and in retaliation for acting as a witness in other cases against his employer. The defendant argued that he was terminated due to his participation in several crimes, such as forgery and theft. The Court found no evidence of a connection between the inappropriate remarks that were made toward the plaintiff, and the plaintiff's termination more than a year later. Thus, in 2002, the Court granted the defendant’s motion for summary judgment.

Plaintiff Tabari Strong, a Muslim prisoner in Beeville, Texas, filed a lawsuit alleging that the prison's grooming policy requiring all inmates to be clean-shaven violated his statutory rights under RLUIPA. He also claimed that the policy violated his right to exercise his religion under the First Amendment, and that enforcement of the policy violated his right to equal protection under the Fourteenth Amendment. The plaintiff filed a motion for summary judgment, claiming that he is entitled to a declaratory judgment. The District Court refused to grant the plaintiff's request for injunctive relief as an "extraordinary remedy," but maintained that it would be contrary to justice not to grant the relief requested by the plaintiff to have a quarter-inch beard.

Plaintiff Lavotte Saunders, a Muslim African-American male, brought this claim of discrimination based on race and religion against the Respondent, the Plaintiff’s former employer Apothaker & Associates. Two days after the Plaintiff was hired, he was fired on the basis of having a criminal record, but later discovered that several other employees of the Respondent had criminal records (including felony convictions) and were not fired. Therefore, the Plaintiff brought suit on the basis that he was fired as a result of disparate treatment due to religious discrimination under Title VII of the Civil Rights Act and the New Jersey Law Against Discrimination. The Respondent filed a motion for summary judgment. The Court found that claims of discrimination are subject to the McDonnell Douglas Corp. v. Green burden shifting analysis: First, the Plaintiff had to state a prima facie case, and then the burden shifted to the Respondent to “articulate some legitimate, non-discriminatory reason for the employee’s termination.” The Court found that the Plaintiff failed to state a prima facie case, because he could not prove that he was qualified for the position in the first place. Therefore, the Court granted the Respondent’s motion for summary judgment.

The Court reversed the U.S. District Court for the Southern District of New York’s grant of summary judgment in favor of defendant prison officials, John McGinnis, Patrick McGann, and Gordon Lord. Plaintiff Wayne Ford sued under § 1983, alleging a violation of his First Amendment rights by the denial of his request to attend the Eid al-Fitr feast (the holiday at the end of Ramadan); prison officials had moved the event to fall several days after its official occurrence in order that it coincide with a weekend. Defendants argued that their denial of plaintiff inmate’s request to attend the event did not amount to a constitutional violation because the event, once moved, no longer fell on a date of religious significance. The Court concluded that summary judgment was inappropriate because the matter required closer scrutiny of the Turner/O’Lone Test (which balances prisoners' religious accommodation requests with legitimate penological concerns) than the District Court accorded it before finding in favor of either party.

Plaintiff Horace Crump, an inmate in the Michigan Department of Corrections, brought this compliant against the Respondent, Deputy Warden Winn at the Saginaw Correctional Facility, for changing the Muslim prayer time. Specifically, the Plaintiff alleged that the Respondent changed the Muslim prayer time in such a way as to place a substantial burden on the Plaintiff’s free exercise of his religion, and that this was done in retaliation for having complained about his and other Muslim inmates’ complaints during Ramadan. The Respondent filed a motion for summary judgment, and the case was referred for a report and recommendation by a magistrate judge. The magistrate judge determined that the Plaintiff did not suffer a substantial burden, because while the Respondent did not offer a specific penological justification for changing the prayer time, the prison immediately reinstated the religiously required Friday prayer time, such that the Plaintiff did not in fact suffer a “substantial burden” on the practice of his religion. The magistrate judge then found that the fact that the Plaintiff did not suffer a substantial burden on the practice of his religion also showed that he did not suffer adverse action, a necessary element of his retaliation claim. For these reasons, the magistrate judge recommended that the Respondent’s motion for summary judgment be granted, and that the complaint be dismissed with prejudice.

The Court granted the defendant Marriott International’s motion for summary judgment in part and denied it in part. Plaintiff Nagy Edrisse sued Marriott and several of its employees under Title VII, § 1981, the New York State Human Rights Law, and the New York City Human Rights Law. The plaintiff alleged that the hotel created or tolerated a hostile work environment in that his direct manager made frequent derogatory racial, religious, and ethnic statements, including asking the plaintiff whether he was going to blow up the building and whether he was a terrorist. Furthermore, the plaintiff claimed that the hotel fired him out of discriminatory animus based on his religion, race, and ethnicity. The defendant argued that the plaintiff was fired due to inappropriate behavior at the workplace (including using racial slurs directed at fellow employees), rather than his race, religion, or ethnicity. The Court dismissed the claim against the employees who were not directly involved, but denied summary judgment for the defendants, holding that the facts were sufficient to make out a prima facie case to move forward. In other words, the Court concluded that a jury could consider the evidence presented to be severe and pervasive enough to allow for a finding of a hostile work environment.

The Court denied defendant Merrill Lynch’s motion for summary judgment, adopting the opinion of the magistrate judge, which held that the employee established a prima facie case of discrimination. Plaintiff Abdul-Giyath Mayale-Eke sued his former employer and direct supervisor under Title VII, §1981, the Rhode Island Fair Employment Act, and the Rhode Island Civil Rights Act. The plaintiff alleged that, as a Muslim who had immigrated from Nigeria, he was treated differently and ultimately fired from his position as an investment specialist because of his race, national origin, and religion; specifically, he claimed that he was frequently asked questions about his heritage and was subject to derogatory comments. Defendant Merrill Lynch claimed that it fired plaintiff after giving him numerous warnings of his failure to meet set performance standards. The Court ultimately denied the defendant’s motion for summary judgment, concluding that the plaintiff had alleged enough specific facts to make the claim not just conceivable but plausible before a jury.

Masroor Siddiqui, a Muslim of Pakistani origin, sued his former employer, Autozone, under Title VII, alleging race-based harassment; discrimination based on race, ethnicity, national origin, and religion; and retaliation. The plaintiff claimed that he was subjected to a hostile work environment when, after 9/11, he was barraged with racial epithets. He further alleged that he was passed by for promotions because of his race, religion, and national origin (citing comments from his supervisor that they would never promote “people like him”), and that he was ultimately terminated as a result of these factors. The defendant argued that, even if the court found that the plaintiff had made out a prima facie case of discrimination, the company legitimately denied the promotion of, and ultimately fired, the employee because of poor work performance. The Court entered summary judgment in favor of the defendant on the hostile work environment claim, concluding that no jury would consider the evidence produced by the plaintiff severe or pervasive enough for a hostile work environment claim; however, the Court denied the motion for summary judgment in respect to the promotion claim, allowing the case to go forward.

The plaintiff sued her former employer, Neiman Marcus, under Title VII, alleging discrimination based on religion, race, color, and national origin; failure to accommodate her religion; failure to stop harassment; and retaliation for her filing of a religious and national origin discrimination claim with the Equal Employment Opportunity Commission (EEOC), which allowed her suit to proceed in court. The defendant company argued that, because of the statue of limitations, the plaintiff failed to make a claim. Many of the plaintiff’s claims, including allegations of her co-worker directing racial epithets at her, and being compelled to work on religious holidays, were time-barred and thus could not be introduced to the court. The court found that the plaintiff failed to make a prima facie case of discrimination as required by McDonnell Douglas, concluding that she did not prove that she was treated differently because of her religion, race, or national origin. Accordingly, the Court granted summary judgment in favor of the defendant company on these claims; however, the Court denied the company’s motion for summary judgment on the hostile work environment claim, concluding that a jury could consider allegations that the company permitted so-called sale-stealing, when an employee rings up the sale of a client that a co-worker was working with thereby receiving their commission, to be an adverse employment action in the claim that was not time-barred, and thus the suit on this issue could move forward.

A Pakistani Muslim plaintiff sued her former employer, JP Morgan Chase, under Title VII and the Age Discrimination in Employment Act (ADEA), alleging that she was subjected to a hostile work environment, constructive discharge, and disparate treatment. Specifically, the plaintiff alleged that she received a lower salary than her co-workers in the same position and that her reasonable requests to work a different shift so she could care for her daughter were denied. The Court granted the defendant’s motion for summary judgment. The Court concluded that the incidents that the plaintiff cited to support her claim of a hostile work environment were not severe or pervasive enough to allow a jury to find for the plaintiff. Furthermore, the court did not see any adverse employment action as a result of alleged disparate treatment (which is an element that the McDonnell Douglas Corp. v. Green test for discrimination requires in cases lacking direct evidence). Finding that the plaintiff failed to establish a prima facie case of discrimination or retaliation, the Court granted the motion for summary judgment in favor of the defendant.

Muslim plaintiff Iqbal Sulehria sued his employer, the New York City Department of Correction, and related officials under Title VII, §1983, and New York State and City anti-discrimination laws, alleging religious and national origin discrimination as well as retaliation for filing a claim with the Equal Employment Opportunity Commission (EEOC) and through the prison administration. Specifically, the plaintiff claimed that his co-workers and managers harassed him for being Muslim after the events of 9/11. The harassment consisted of verbal taunts, intrusive searches, withholding promotions, denying him use of the bathroom, forcing him to work in substandard conditions, and having his face imposed on the body of Osama bin Laden in photos left on the plaintiff’s desk. The Court upheld a magistrate judge’s report granting the City partial summary judgment, dismissing the retaliation and failure-to-promote claims, because the Court found that the plaintiff failed to establish a prima facie case; however, the Court denied the City’s motion for summary judgment as to the hostile work environment claim, concluding that a jury could see the events as alleged to be severe and pervasive enough to allow the claim to go forward.

Plaintiff Peter McDaniels sued various prison officials, alleging that they intentionally failed to provide him with pre-sunrise meals during Ramadan and with an Eid al-Fitr meal at the conclusion of Ramadan, in violation of his First Amendment rights to free exercise of religion. The Plaintiff also contended that the lack of provision of ḥalāl meat and deprivation of an Arabic Qurʾān for nine months were discriminatory violations of his rights. The Respondents moved for summary judgment. The District Court granted the Respondents' request for summary judgment on the Ramadan meals issue, stating that the Plaintiff failed to show that such failures to provide a meal on isolated incidents imposed a significant restriction on his religious practice. However, the District Court decided that the Respondents did not meet their burden of demonstrating that the religious diet policy furthers a compelling government interest and is the least restrictive means of furthering that compelling interest. The District Court dismissed the plaintiff's claim that the Respondents deprived the Plaintiff of his rights by not allowing him access to a Qurʾān, finding that the Respondents were not required to provide the Plaintiff with an Arabic Qurʾān or dates to be used in his devotional practice, given the absence of any showing that Respondents prevented him from obtaining such items. The Plaintiff did not seek injunctive relief, but the Court found that the individual Respondents were entitled to qualified immunity, so they could not be held liable for personal damages under RLUIPA.

Plaintiff Abdus Shahid brought this claim against the Respondent, the Borough of Eddystone, for discrimination against him on the basis of race, national origin and religion after the Respondent deliberately engaged in a four-year-long campaign to prevent him from living in or renting out a property he owned in Eddystone because it did not want a Muslim in the area. Following the complaint, the Respondent filed a motion for summary judgment, which the District Court previously granted in part and denied in part, holding that while the Plaintiff was barred by the Heck v. Humphrey and Rooker-Feldman doctrines from challenging the validity of his convictions for violating Eddystone ordinances, there were also genuine issues of material fact that precluded summary judgment on the remaining claim that Eddystone denied him a certificate of occupancy and preventing him from renting the property because of his race, religion and national origin. Following a jury trial, the Court analyzed testimony evidence about alleged statements by Eddystone officials acknowledging the existence of a discriminatory housing policy and evidence that similarly situated white property owners were treated more favorably. However, the Court determined that the Plaintiff failed his burden of proof with regards to his claim that the Respondent violated his Fourteenth Amendment right to equal protection, because he produced no concrete credible evidence showing that he was treated differently than white property owners, and that the Respondent’s actions were anything other than genuine attempts to enforce the Eddystone housing code. The Court concluded that the Plaintiff failed to establish that the Respondent discriminated against him on the basis of race, religion or national origin. Therefore, the Court entered judgment in favor of the Respondent.

This case was brought on appeal from the U.S. District Court for the Western District of Virginia, which granted summary judgment in favor of the defendants, prison officials (Warden Jack Lee, Assistant Warden Gene Shinault, and Correctional Officer K. Lester). Petitioner Leroy Lovelace was removed from a “pass list” (which gives inmates access to Ramadan prayer services and special meals) after prison officials claimed that he broke his fast by eating during the day. Lovelace argued that his removal was due to his complaints about expired food, and was thus in violation of his First Amendment right to free exercise of religion, the Fourteenth Amendment right to due process, and the requirements of Section 3 of the Religious Land Use and Institutionalized Persons Act (RLUIPA) (protecting prisoners from having their religious practices substantially burdened, without a compelling government interest). Section 3 of RLIUPA states that “No government shall impose a substantial burden on the religious exercise of a person residing in or confined to an institution, as defined in section 1997 of this title, even if the burden results from a rule of general applicability, unless the government demonstrates that imposition of the burden on that person--is in furtherance of a compelling governmental interest; and is the least restrictive means of furthering that compelling governmental interest.” 42 U.S.C.A. §2000cc-1(a). The Court vacated the grant of summary judgment in favor of Officer Lester, the prison official who reported the alleged fast breaking, as well as against Warden Lee, who was in charge of overseeing the prison, concluding that both officials played direct roles in the incident. The Court remanded the case to the district court to determine whether the plaintiff had made out a valid due process claim, and the Court affirmed the remainder of the district court’s grant of summary judgment in favor of the defendants.