Wash. Court of Appeals published opinion — 383814_pub.pdf

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See Ansonia, 479 U.S. at 70. In addition, some courts have held that a reasonable

accommodation must not impact the employee’s benefits or status. See Dallan F. Flake,

Restoring Reasonableness to Workplace Religious Accommodations, 95 WASH. L. REV.

1673, 1715 (2020).

In Ansonia, a teacher’s religious beliefs required him to refrain from performing

secular work on six designated Holy Days. The school’s collective bargaining agreement

allowed teachers to take up to three days of paid leave each year to observe mandatory

religious holidays. Beyond that, the teacher could take unpaid leave. The bargaining

agreement also provided three days of paid personal days that could be used for purposes

not otherwise specified in the contract. After the teacher’s request to use his paid

personal days for religious purposes was rejected, the teacher filed suit alleging failure to

accommodate.

The United States Supreme Court held that an employer has an obligation to

provide a reasonable accommodation, but not necessarily the accommodation preferred

by the employee. Ansonia, 479 U.S. at 68. Once an employer is found to have provided

a reasonable accommodation, the inquiry stops, and there is no need to show that

alternative accommodations requested by the employee would cause an undue hardship.

Id. at 68-69.

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For the current opinion, go to https://www.lexisnexis.com/clients/wareports/.

No. 38381-4-III
Suarez v. State

Ultimately, the Court remanded the case for further factual findings on whether

the school’s leave policy constituted a reasonable accommodation. In doing so, the Court

noted that generally a policy of allowing a teacher to take unpaid leave for holidays in

excess of the leave granted by the collective bargaining agreement would be a reasonable