The California Department of Corrections and Rehabilitation (CDCR) faces a legal setback as the Court of Appeal upholds a ruling in favor of Teresa Brown, a Seventh-day Adventist who was denied employment due to her religious observance. On September 23, 2024, the case was filed by Brown in the Third Appellate District Court in Sacramento against CDCR. The crux of the case revolved around Brown's inability to work from sundown Friday to sundown Saturday, which she claimed was not reasonably accommodated by CDCR during her application process for a correctional officer position.
Brown's journey began in 2013 when she applied for a correctional officer role at CDCR, an entity managing over 30 adult institutions with a significant workforce. Despite indicating her willingness to work under various conditions on her application, Brown also specified that her religious beliefs prevented her from working during the Sabbath. This led to her application's rejection after CDCR concluded that accommodating such restrictions would impose undue hardship on their operations.
In response, Brown filed a lawsuit citing religious discrimination and failure to accommodate under the California Fair Employment and Housing Act. Although her claim of religious discrimination did not survive summary adjudication, she succeeded in proving that CDCR failed to explore reasonable accommodations for her Sabbath observance without undue hardship. The trial court initially ruled against Brown based on a "bona fide occupational qualification" defense but was later directed by an appellate court to reassess under specific statutory provisions focusing on accommodation efforts.
On remand, it became evident that CDCR had not sufficiently explored potential accommodations or engaged in an interactive process with Brown. Evidence presented indicated that other employees with similar unavailability had been accommodated through shift swaps and management-directed positions without significant operational disruption. Consequently, the trial court found in favor of Brown, leading CDCR to appeal the decision.
Despite arguments from CDCR about safety concerns and potential morale issues among officers if they accommodated Brown's schedule preferences, the appellate court affirmed the lower court's judgment. It highlighted that any accommodation-related hardships claimed by CDCR were not substantiated enough to override statutory obligations for religious accommodation.
Teresa Brown seeks remedial orders ensuring future compliance with accommodation requirements and costs recovery from this legal battle. Her attorneys successfully argued that no substantial evidence demonstrated that accommodating her Sabbath observance would result in undue hardship for CDCR.
Representing Teresa Brown is an unnamed legal team while CDCR's counsel remains unspecified. The case was presided over by Judges Renner, Earl, and Robie under Case ID C095798.