Christian employee who objects to secular counseling loses religious accommodation claim

Howard Friedman, Religion Clause

In Valenzisi v. Stamford Board of Education, (D CT, June 5, 2013), a Connecticut federal district court dismissed a claim by high school math teacher challenging his termination on, among other grounds, Title VII and 1st Amendment claims of failure to accommodate his religious beliefs. Teacher Frank Valenzisi was required to obtain a “fit for duty” medical evaluation before he could resume teaching after claims of aggressive behavior, difficulty recognizing people and bizarre behavior in a meeting with the deputy superintendent.  Valenzisi objected to the requirement, and sued claiming that as a born-again bible-believing Christian he objected to secular counseling. The court held that there is a question of whether the fitness-for-duty evaluation involved secular counseling, but even if it did Valenzisi did not show that he had requested an accommodation from his employer.