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Does CBP have to grant every request for accommodation of a religious belief or practice?

Does CBP have to grant every request for accommodation of a religious belief or practice?

No.  Title VII requires the agency to accommodate only those religious beliefs that are religious and “sincerely held,” and that can be accommodated without an undue hardship.  Although there is usually no reason to question whether the practice at issue is religious or sincerely held, if CBP has a bona fide doubt about the basis for the accommodation request, it is entitled to make a limited inquiry into the facts and circumstances of the employee’s claim that the belief or practice at issue is religious and sincerely held, and gives rise to the need for the accommodation.

Factors that – either alone or in combination – might undermine an employee’s assertion that he sincerely holds the religious belief at issue include: whether the employee has behaved in a manner markedly inconsistent with the professed belief; whether the accommodation sought is a particularly desirable benefit that is likely to be sought for secular reasons; whether the timing of the request renders it suspect (e.g., it follows an earlier request by the employee for the same benefit for secular reasons); and whether the agency otherwise has reason to believe the accommodation is not sought for religious reasons.

However, none of these factors is dispositive.  For example, although prior inconsistent conduct is relevant to the question of sincerity, an individual’s beliefs – or degree of adherence – may change over time, and therefore an employee’s newly adopted or inconsistently observed religious practice may nevertheless be sincerely held.  The agency also should not assume that an employee is insincere simply because some of his or her practices deviate from the commonly followed tenets of his or her religion.