Issue: Whether it is a violation of Title VII's requirement that religious conflicts be accommodated to the extent they do not cause undue hardship for an employer to terminate an employee who refused to sign a certificate of understanding agreeing to abide by the language in the employer's diversity policy to "value the differences among its employees" including those based on sexual orientation.

Facts: Employer promoted a new handbook that included language on respecting others and valuing diversity, including sexual orientation. Employees were to sign an acknowledgment of receipt and certificate of the understanding form indicating they received a copy of the handbook and would abide by the policies and practices. A Christian employee, who believes the Bible is divinely inspired, refused to sign, though he said he would not discriminate against other employees because of differences. However, he said his religious beliefs prohibited him from approving, endorsing, or esteeming behavior or values that are repudiated by the Bible. He was terminated for not signing the forms.

Decision: Yes, this is a violation of Title VII. The court said that the employer's diversity philosophy reflects a "legitimate and laudable business goal." However, the court attributed significant weight to the fact that the employer did not effectively inquire into the nature of the conflict the employee had, such that the employee and the employer could reach some agreement as to how that conflict might be resolved.

1. If you were Buonanno's manager, how would you have handled this situation?
2. Think about the issue of an employee deciding not to accept a co-worker because of religious reasons. If you were the manager, how would you balance the two (workplace requirement versus religion)? What if, as in Chapter 10, the employee's religion teaches him or her to hate blacks, Jews? Is it the same? Explain.
3. What considerations should an employer be concerned with when coming up with approaches to promote workplace cohesion and avoidance of discrimination claims?