An Atheist Religiously Discriminated at Workplace

An Atheist Religiously Discriminated at Workplace

Paul Mathis’ case of religious discrimination at workplace is a highly controversial issue across the whole of Pennsylvania. Mathis being an atheist was fired from his office as a result of denying consent to the company’s belief in Christianity. Mathis had been working as a sheet metal installer for Christian Heating & Air Conditioning Inc. for almost two years, when eventually one day it was discovered by his employer that he covered a part of his ID badge, containing the employer’s mission statement.

He was asked to uncover his badge and remove the tape, to which neither he agreed, nor he removed the tape over the covered tagline which conflicted his beliefs as an atheist. Later that day, he was fired from his employment.

As a result, Mathis brought in an administrative proceeding against his employer for a reasonable accommodation, alleging that he was denied a reasonable religious accommodation under Title VII and that he suffered a retaliatory discharge due to his religious beliefs. Consequently, the Unemployment Compensation Board of Review (UCBR) denied him the benefits pursuant to 43 P.S. § 802(e) from the Pennsylvania Unemployment Compensation Service Center. Benefits were further denied on an appeal as the UCBR inferred that under state employment laws, Mathis voluntarily chose to quit the job by not uncovering the said lines. This was upheld by the Commonwealth Court. Mathis v. Unemployment Comp. Bd. of Review, 64 A.3d 293, 295-296 (Pa. Commw. Ct. 2013).

Aggrieved by the decision, Mathis then filed a charge against the employer in the U.S. Equal Employment Opportunity Commission which on March 29, 2013, issued dismissal and a notice of rights advising Mathis about his right to file a suit within 90 days. Mathis followed by filing a suit at the Federal Court on June 27, 2013, wherein he asserted two claims – (1) denial of a reasonable religious accommodation and (2) employment termination in retaliation to his religious beliefs. The court dismissed his claim concluding that plaintiff was barred by collateral estoppel from litigating issues essential to his failure to accommodate claim and thus dismissed that claim. Mathis subsequently filed a motion on February 20, 2015, for clarification of court’s order. He cited P.S. § 829, stating that “[n]o finding of fact or law, judgment, conclusion or final order made with respect to a claim for unemployment compensation under this act may be deemed to be conclusive or binding in any separate or subsequent action or proceeding in another forum.” To this, the Court determined that plaintiff was not barred from litigating his claims. Mathis v. Christian Heating & Air Conditioning, Inc., Civil Action No. 13-cv-3740, 2015 U.S. Dist. LEXIS 30397.

Debbie Kaminer, a professor of law at Baruch College, pointed out an interesting turning point for the case, which is that had the company referred to itself as a religious organization, it could have afforded the right under Title VII, to take certain actions that nonreligious organizations are not allowed to take.