CACI VF-2512 Religious Creed Discrimination—Failure to Accommodate—Affirmative Defense—Undue Hardship (Gov. Code, §§ 12926(u), 12940(l))

VF-2512 Religious Creed Discrimination—Failure to Accommodate—Affirmative Defense—Undue Hardship (Gov. Code, §§ 12926(u), 12940(l))

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We answer the questions submitted to us as follows:

1.Was [name of defendant] [an employer/[other covered entity]]?

 Yes   No

If your answer to question 1 is yes, then answer question 2. If you answered no, stop here, answer no further questions, and have the presiding juror sign and date this form.

2.Was [name of plaintiff] [an employee of [name of defendant]/an applicant to [name of defendant] for a job/[other covered relationship to defendant]]?

 Yes   No

If your answer to question 2 is yes, then answer question 3. If you answered no, stop here, answer no further questions, and have the presiding juror sign and date this form.

3.Does [name of plaintiff] have a sincerely held religious belief that [describe religious belief, observance, or practice]?

 Yes   No

If your answer to question 3 is yes, then answer question 4. If you answered no, stop here, answer no further questions, and have the presiding juror sign and date this form.

4.Did [name of plaintiff]’s religious [belief/observance] conflict with a job requirement?

 Yes   No

If your answer to question 4 is yes, then answer question 5. If you answered no, stop here, answer no further questions, and have the presiding juror sign and date this form.

5.Did [name of defendant] know of the conflict between [name of plaintiff]’s religious [belief/observance] and the job requirement?

 Yes   No

If your answer to question 5 is yes, then answer question 6. If you answered no, stop here, answer no further questions, and have the presiding juror sign and date this form.

6.Did [name of defendant] reasonably accommodate [name of plaintiff]’s religious [belief/observance]?

 Yes   No

If your answer to question 6 is no, then answer question 7. If you answered yes, stop here, answer no further questions, and have the presiding juror sign and date this form.

7.Did [name of defendant] explore available ways to accommodate [name of plaintiff]’s religious [belief/observance]?

 Yes   No

If your answer to question 7 is yes, then answer question 8. If you answered no, skip question 8 and answer question 9.

8.Could [name of defendant] have accommodated [name of plaintiff]’s religious [belief/observance] without causing undue hardship to [name of defendant]’s business?

 Yes   No

If your answer to question 8 is yes, then answer question 9. If you answered no, stop here, answer no further questions, and have the presiding juror sign and date this form.

9.Was [name of plaintiff]’s failure to comply with the conflicting job requirement a substantial motivating reason for [name of defendant]’s [discharge of/refusal to hire/[other adverse employment action]] [name of plaintiff]?

 Yes   No

If your answer to question 9 is yes, then answer question 10. If you answered no, stop here, answer no further questions, and have the presiding juror sign and date this form.

10.Was [name of defendant]’s failure to reasonably accommodate [name of plaintiff]’s religious [belief/observance] a substantial factor in causing harm to [name of plaintiff]?

 Yes   No

If your answer to question 10 is yes, then answer question 11. If you answered no, stop here, answer no further questions, and have the presiding juror sign and date this form.

11.What are [name of plaintiff]’s damages?

[a.Past economic loss

[lost earnings $]

[lost profits $]

[medical expenses $]

[other past economic loss $]

Total Past Economic Damages: $]

[b.Future economic loss

[lost earnings $]

[lost profits $]

[medical expenses $]

[other future economic loss$]

Total Future Economic Damages: $]

[c.Past noneconomic loss, including [physical
pain/mental suffering:]  $]

[d.Future noneconomic loss, including [physical
pain/mental suffering:]  $]

TOTAL $

After [this verdict form has/all verdict forms have] been signed, notify the [clerk/bailiff/court attendant] that you are ready to present your verdict in the courtroom.

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