(CN) - A Massachusetts Jiffy Lube that imposed a hair-grooming policy did not properly address the religious needs of its Rastafarian employee, the Massachusetts Court of Appeal ruled.
F.L. Roberts & Co. vice president Richard Smith, who is in charge of Jiffy Lube stores, instituted the grooming policy on the advice of a consultant who said customers preferred clean-shaven employees.
Bobby J. Brown, who worked as a greeter and lube technician, practices Rastafarianism. The faith prohibits him from shaving or cutting his hair.
Brown said that Smith ordered him to stay in the lower bay unless he cut his hair and said that Smith claimed he did not have time to check people's religions.
Brown testified that working in the lower bay was cold and dangerous. Also, he said other employees were covered in grease when they had contact with customers.
Judge Ireland reversed the trial court's summary judgment because the defendants didn't work with Brown on an alternative accommodation.
"Because the defendant did not discuss alternatives with the plaintiff," Ireland wrote, the defendant cannot show conclusively that a total exemption from the grooming policy was the only possible accommodation."