Complete the attached 3-4 page assignment. APA format with references

Before you begin this assignment, be sure to familiarize yourself with the following information including laws and their amendments.

Anti-Defamation League. (2012) Religious Accommodation in the Workplace: Your Rights and Obligations. Retrieved at 

https://www.adl.org/sites/default/files/documents/assets/pdf/civil-rights/religiousfreedom/religfreeres/ReligAccommodWPlace-docx

Gepp, R. (2017). Religious accommodation in the workplace: Guidance for Avoiding Legal Trouble. HR Daily Advisor. Retrieved from 

Religious Accommodation in the Workplace: Guidance for Avoiding Legal Trouble

HR Hero. (2017) Americans with Disabilities Act (ADA) and ADA Amendments Act (ADAAA). Retrieved at 

http://topics.hrhero.com/americans-with-disabilities-act-ada-and-ada-amendments-act-adaaa/

Katz, H. C., Kochan, T. A., & Colvin, A. J. S. (2017).Employment law. An introduction to U. S. collective bargaining and labor relations. Ithaca: Cornell University Press, pg. 71-79. Retrieved from Skillsoft Books in the Trident Online Library.

The U.S. Equal Employment Opportunity Commission. Enforcement Guidance on Reasonable Accommodation and Undue Hardship under the Americans with Disabilities Act. Retrieved at 

https://www.eeoc.gov/policy/docs/accommodation.html

There are primarily two U.S. governmental agencies responsible for enforcing EEO laws. The two agencies are the Equal Employment Opportunity Commission (EEOC) and the Office of Federal Contract Compliance Programs (OFCCP).

Assignment:

Address the following questions in preparing a paper of 3 to 4 pages (not including cover page or reference page.)

1. Summarize the reasonable accommodation expectations concerning religion and disability that employers must meet under the law.

2. From your readings/research (stating employers by name), describe one specific private sector workplace example of a reasonable accommodation for religion, and one specific private sector workplace example of a reasonable accommodation for disabilities.

Use at least 3 reputable books and/or journal articles found in the Trident Online Library, plus 3 applicable background readings to support your discussion.

Cite all sources utilized to write your paper.

Books and Journals from Trident Online Library

Creta, M. (2014). THE ACCOMMODATION OF LAST RESORT: THE AMERICANS WITH DISABILITIES ACT AND REASSIGNMENTS. Boston College.Law School.Boston College Law Review, 55(5), 1693-1729. Retrieved from

https://search-proquest-com.ezproxy.trident.edu/docview/1664533187?accountid=28844

Brooks, R., & Kleiner, B. H. (2003). How to comply with the americans with disabilities act. Equal Opportunities International, 22(6), 9-16. doi:http://dx.doi.org.ezproxy.trident.edu:2048/10.1108/02610150310787568

Law, C. L., & Harris, E. (2019). Religious discrimination and accommodations in the U.S. military: Best practices for leaders. North American Journal of Psychology, 21(1), 189-206.

Reproduced with permission of the copyright owner. Further reproduction prohibited without permission.

How to Comply with the Americans with Disabilities Act
Brooks, Robert;Kleiner, Brian H
Equal Opportunities International; 2003; 22, 6/7; ProQuest One Academic
pg. 9

Reproduced with permission of the copyright owner. Further reproduction prohibited without permission.

Reproduced with permission of the copyright owner. Further reproduction prohibited without permission.

Reproduced with permission of the copyright owner. Further reproduction prohibited without permission.

Reproduced with permission of the copyright owner. Further reproduction prohibited without permission.

Reproduced with permission of the copyright owner. Further reproduction prohibited without permission.

Reproduced with permission of the copyright owner. Further reproduction prohibited without permission.

Reproduced with permission of the copyright owner. Further reproduction prohibited without permission.

______________________________

Author info: Correspondence should be sent to: Dr. Charlie Law, Department of

Psychology, 111 Lake Hollingsworth Drive, Lakeland, FL 33801. E-mail:

claw@flsouthern.edu

North American Journal of Psychology, 2019, Vol. 21, No. 1, 189 – 206.

 NAJP

Religious Discrimination and Accommodations

in the U.S. Military:

Best Practices for Leaders

Charlie L. Law
1

Erica Harris
2

1
Florida Southern College

2
Defense Equal Opportunity Management Institute

The current study investigates the experiences of religious minorities in

the United States (U.S.) Military. Specifically, we predicted that Muslim

and Jewish individuals in the military would perceive higher levels of

religious discrimination than

Christians.

Furthermore, we predicted that

those religious minorities would be more likely than Christians to

experience negative workplace outcomes. Results indicate that Muslim

and Jewish individuals are more likely than Christians to experience

religious discrimination. Muslim and Jewish individuals are also more

likely to report lower job satisfaction and lower organizational

commitment than Christians. Finally, we found that experiencing

religious discrimination negatively affects workplace outcomes

regardless of one’s religious affiliation, although that discrimination was

particularly detrimental to the job satisfaction for Muslim individuals.

We conclude with recommendations for commanders, including the

recommendation that military leaders increase their knowledge of Equal

Opportunity (EO) policies and directives, expand support for diverse

religious needs, search for and implement tried-and-true policies for

dealing with religious discrimination, and use methods other than religion

to help promote personal growth in their subordinates.

Keywords: Religion, Accommodations, EO, Discrimination, Diversity,

Military

Religious accommodation issues are becoming increasingly important

in the U.S. workplace. Although religious discrimination claims are far

outpaced by race and gender claims, the Equal Employment Opportunity

Commission (EEOC, 2013) reports that religious workplace

discrimination claims are the fastest growing type of discriminatory

complaint. While religious discrimination claims increased 91% since

2000, sex-based and race-based complaints increased only about 10%

190 NORTH AMERICAN JOURNAL OF PSYCHOLOGY

and 14%, respectively. One reason for the increased number of religious

discriminatory claims may be that Americans are more attuned to

religious diversity after the terrorist bombings of 9/11 and the

“Islamaphobia” that ensued. The EEOC reports that religious

discrimination cases from Muslim employees increased 250%

immediately after the terrorist attacks which constituted between 20%

and 28% of all religious discrimination cases (EEOC, 2011).

It is important to note the difference between Equal Employment

Opportunity (EEO) and Equal Opportunity (EO) policy. The primary

distinction is that EEO policy applies to the civilian workforce while EO

policy applies to uniformed personnel in the U.S. Military. Thus, military

commanders may use EEO policy as a guide when dealing with a strictly

military audience, but they have significantly more latitude in applying

that law to military members. This latitude is important because it allows

a commander to address military-specific concerns when it comes to

accommodations. For example, if a requested accommodation would

hinder military readiness, a commander can decline the accommodation

under EO policy. This type of consideration is not possible under EEO

policy. While the EEOC tracks discrimination claims, there is no such

mechanism for EO claims in the U.S. Military.

The current research investigates some of the issues that the U.S.

Military faces with respect to religious accommodations. First, we

present an overview of the legal issues involved with religious

accommodations in the workplace. Second, we investigate the religious

demographics of military members and the possibility that religious

minorities are more likely to experience negative workplace outcomes.

Third, we investigate the possibility that religious discrimination leads to

negative workplace outcomes. Finally, we present recommendations for

military leaders regarding religious diversity and religious

accommodations

in the military.

Legal considerations for religious accommodations
A review of the legal implications of religious accommodations

suggests that there are three sources of guidance for organizations: the

First Amendment to the U.S. Constitution, Title VII of the Civil Rights

Act of 1964, and subsequent Supreme Court rulings. The First

Amendment to the U.S. Constitution states that: “Congress shall make no

law respecting an establishment of religion or prohibiting the free

exercise thereof.” This phrase is commonly broken into its two

component parts: a) The Establishment Clause, which indicates that the

government cannot favor one religion over another and b) The

Expression Clause, which indicates that people should be free to express

their religious beliefs without fear of reprisal.

Law & Harris DISCRIMINATION IN THE MILITARY 191

Title VII of the Civil Rights Act prohibits the unfair treatment of

employees (or employment applicants) based on their religious beliefs or

practices (in addition to their sex, race, color, and national origin).

Employers cannot base employment decisions such as hiring, promotion

and training opportunities, discipline, and employment termination on

one’s religious beliefs or practices. Furthermore, employers must protect

their employees from verbal or physical harassment in the workplace and

should provide reasonable accommodations for employees’ religious

beliefs and practices (Dean, Safranski, & Lee, 2014).

While the First Amendment to the Constitution and Title VII of the

Civil Rights Act seem to be straightforward in establishing legal

precedent for religious accommodations in the workplace, a number of

lawsuits provide further clarification and guidance for organizations in

providing religious accommodations. These cases emerged primarily as

challenges to the wording of Title VII of the Civil Rights Act, which

states that an employer must provide a reasonable accommodation for

religious practices of its employees unless the accommodation would

result in undue hardship (Hollon & Bright, 1982).

There are several important issues regarding the “reasonable

accommodations” requirements. First, employees requesting

accommodations must have “sincerely held” religious beliefs or

practices. Second, the employer must be given notice that the employee

requires accommodations. For example, an employee that would like

accommodations for religious garb must first give notice to the employer

about the requirement. If an employer is not given the opportunity to

reasonably accommodate an employee, the organization cannot be held

accountable. Third, the employer only has to offer an accommodation

that results in a de minimis cost or burden to the organization (Kelly,

2008). A stringent requirement to accommodate religion could

conceivably result in undue hardship for an employer. With the vast

majority of Americans claiming some type of religious affiliation

(Kosim, et al., 2001), accommodations of all religious beliefs at the same

level as race or sex accommodations could be monstrously burdensome.

Therefore, organizations are only required to offer an accommodation

that does not result in undue cost or expense to the employer. For

example, an employee might request a day of paid vacation for a

religious service, but an organization can offer a shift-swap with other

employees as an alternative that would allow the employee to engage in

the religious observation though not in the way the employee originally

requested.

Religion in the U.S. Military

Hunter and Smith (2010) investigated the religious practices of

members in the U.S. Military. They found that the majority of military

192 NORTH AMERICAN JOURNAL OF PSYCHOLOGY

members identified as Christian (nearly 66%), the second highest group

was the Nonreligious (26%), while Atheists/Humanists made up

approximately 4%. Given these disparate percentages, it is likely that the

U.S. military is not immune from the challenges of increased religious

diversity. For example, in 2009 thousands of Christian Bibles were sent

to a chapel at Bagram Air Base in Afghanistan from private American

religious organizations (Parco, 2013). While this may not seem

problematic, the Bibles were printed in the local Pashto and Dari

languages. This indicates that the Bibles were probably meant as a tool

for proselytizing to local Afghan people. Additionally, Sharlet (2009)

reported that the words “Jesus Killed Mohamed” were printed in red

Arabic lettering on the side of a Bradley Fighting Vehicle in Iraq, and

that same year, ABC News reported that rifles used in Iraq and

Afghanistan included Bible verse numbers on the rifle sights of U.S. and

Allied weapons. While these allegations are troubling, one could argue

that they originate outside the U.S. Military by private organizations.

Thus, although U.S. Commanders may not actively engage in behaviors

that go against military orders, their passivity may be construed as

implicit acceptance of religious discrimination.

However, there are numerous examples of inappropriate religious

behaviors that are actively facilitated by military commanders. In 2010,

allegations emerged that about 80 soldiers stationed at Fort Eustis were

punished for choosing to not attend a Christian concert. Pressuring

soldiers to attend and punishing those who did not attend constitutes

discrimination. The soldiers who did not attend were restricted to their

barracks (e.g., not released from duty), could not go anywhere on Post

(e.g., the library), and were forced to complete maintenance duties. They

were not even allowed to sit on their beds or hold their cell phones or

laptops (Rodda, 2010). Those who went to the concert were not punished

like those who did not attend the concert.

While the example at Fort Eustis is a startling example of religious

intolerance, most cases in the U.S. Military are at the individual level. In

2010, Specialist Zachari Klawonn filed a lawsuit claiming

“Islamaphobia” when he was stationed at Fort Hood. He was prevented

from praying and fasting, which are part of the Five Pillars of Islam. His

Qur’an was destroyed, and other soldiers hurled bottles at him. Similarly,

Private First Class Naswer Abdo claimed he was harassed by his fellow

soldiers because of his religious identity. He was asked to play the part of

the terrorist when engaging in training exercises. One soldier told Abdo

“F*ck you and your god that doesn’t exist. Your prophet’s a pedophile.

God can’t save you.” (ABC News, 2014). Clearly, examples of very

overt religious discrimination exist in the U.S. Military.

Law & Harris DISCRIMINATION IN THE MILITARY 193

Although most would note the hostile nature of the aforementioned

examples of religious discrimination, most cases are more subtle or

ambiguous in nature. In San Antonio, an Air Force sergeant claimed that

he was removed from his unit because he espoused his religious

objections to gay military members (Levy, 2013). Representative Randy

Forbes complained that the Air Force overemphasizes religious neutrality

at the expense of those who wish to express their religious beliefs in the

military. This example shows the problems that military commanders

may face regarding religion in the workplace. They must protect their

subordinates against unwanted religious harassment, yet they must also

protect the rights of their subordinates to express their religious beliefs.

Accommodations should not exclusively protect the rights of religious

minorities; they should equally protect all military members.

Religious discrimination and workplace outcomes
There is a rich tradition of research on religion and behavior (Allport

& Ross, 1967), dating back to Allport’s (1950) distinction of a

dichotomous nature of religiosity (intrinsic vs. extrinsic). Those who are

intrinsically motivated typically behave in a way that is consistent with

their faith while those who are extrinsically motivated participate in

religion for personal gain or social activities (Knotts, 2003). Altemeyer

and Hunsberger (1992) found that religious fundamentalism (e.g., belief

that there is only one set of religious teachings that is true) is negatively

related to attitudes toward out-groups (Altemeyer, 2003). However,

researchers have not adequately addressed the role of religion and the

effects of religious discrimination in the workplace.

Recent research suggests that religious minorities are more likely to

face discrimination in their workplace. Tanenbaum (2013) noted that

over 56% of non-Christian workers perceived religious bias in their

organization. Although research indicates that Muslims (King & Ahmad,

2010), Atheists (Edgell, Gerteis, & Hartman, 2006), and Nonreligious

(Cragun, Kosmin, Keysar, & Hammer, 2012) individuals may all be the

targets of hostility. Cantone and Wiener (2017) found that Jewish and

Muslim workers are the most likely religious group to submit complaints

to the EEOC alleging harassment. More recently, research indicates that

discrimination against Jewish and Muslim Americans is not decreasing,

but rather increasing (Anti-Defamation League, 2017; Greenhouse,

2010). Thus, the current research investigates the experiences of Jewish

and Muslim military members as compared to Christians. Specifically,

we believe that:

Hypothesis 1: Muslim (H1a), and Jewish (H1b) individuals are more

likely to perceive religious discrimination in their organizations than

Christians.

194 NORTH AMERICAN JOURNAL OF PSYCHOLOGY

Although a substantial amount of work on religion and the workplace

remains, limited research addresses the role of spirituality and religion in

predicting various workplace outcomes. For example, research shows

that spirituality is positively related to organizational commitment, work

satisfaction, job involvement, organization-based self-esteem (Milliman,

Czaplewski, & Ferguson, 2003), and job satisfaction (Altaf & Awan,

2011), while religiosity (e.g., religious beliefs and practice) is related to

both job satisfaction and organizational commitment. (Kutcher, Bragger,

Rodriguez-Srednicki, & Masco, 2010).

Although some research does address the importance of employee

religiosity and spirituality in facilitating valued workplace outcomes,

there is a dearth of data regarding the workplace outcomes for religious

minorities, particularly for those who face discrimination in their

workplace. According to Cantone and Wiener (2017), research on

religious discrimination in the workplace remains scarce. In fact, Ruggs

et al. (2013) reviewed leading psychology journals and found only one

article that addressed religious discrimination in the workplace. Although

the limited research that does exists shows that religious minorities may

be the targets of discrimination (King & Ahmad, 2010), the impact of

that discrimination on employees’ job satisfaction and organizational

commitment is unclear.

Cunningham (2010) proposed a model for predicting job satisfaction

for those who are religiously dissimilar from their coworkers. He found

that when people believed their coworkers shared the same level of

religiosity, their religious personal identity increased. However, when

people perceived they were religiously different from their coworkers,

their job satisfaction decreased. It is likely, therefore, that religious

minorities possess lower levels of job satisfaction than religious

majorities. Consistent with Cunningham’s model, we examined the

possibility that religious dissimilarity leads to decreased job satisfaction

and decreased organizational commitment. Specifically, we predict that:

Hypothesis 2: Christians will have higher job satisfaction than

Muslim (H2a), and Jewish (H2b) individuals.

Hypothesis 3: Christians will have higher organizational commitment

than Muslim (H3a), and Jewish (H3c) individuals.

Hypothesis 4: Religious discrimination predicts organizational

outcomes such that those who perceive more religious discrimination in

their organizations will have lower job satisfaction (H4a) and lower

organizational commitment (H4b).

Law & Harris DISCRIMINATION IN THE MILITARY 195

METHOD

Participants and procedures

In July 2009, 6,384 participants voluntarily completed the Religious

Identification and Practices Survey (RIPS; Hunter & Smith, 2010).

These same participants also completed the Defense Equal Opportunity

Management Institute Organizational Climate Survey (DEOCS). All

branches of the military were sampled, with 133 from the Air Force,

2,115 from the Army, 220 from the Coast Guard, 1,783 from the Marine

Corps, and 2,132 from the Navy. Eighty-four percent of survey

respondents were male while 16% were female. The most frequent age

reported was 22-30 years old. Each survey is described in further detail

below. Christians (n = 3,921), accounted for the majority of the sample,

while Jewish (n = 68) and Muslim (n = 27) participants made up about

three percent of the sample.

Measures

Religious denomination. One item was used from the RIPS (Hunter &

Smith, 2010), which asked participants “What is your present religion, if

any?” Respondents could choose from a list of 256 religious

denominations. Although inclusion of such a large number of religious

denominations is commendable, it is not realistic to conduct statistical

analyses on such a large breadth of choices. Therefore, data were recoded

into the following seven categories: Christian, Jewish, Muslim,

Traditionally Eastern, Pagan, Atheist/Humanist, and Nonreligious. Given

the nature of the current research and the low number of many religious

denominations in our sample, we focused only on those individuals who

indicated they were Christian, Muslim, or Jewish.

Religious discrimination. Three items measured religious

discrimination (α = .87). Participants rated their agreement on each item

on a 5-point Likert scale (1 = Strongly Agree, 5 = Strongly Disagree). An

example item from this construct is: “A supervisor favored a worker who

had the same religious beliefs as the supervisor.”

Job satisfaction. Five items measured participants’ job satisfaction (α

= .85). Participants were asked to rate their satisfaction for each item on a

5-point Likert scale (1 = Very Satisfied, 5 = Very Dissatisfied). An

example item from this construct is: “The chance to acquire valuable

skills in my job that prepare me for future opportunities.”

Organizational commitment. Seven items measured participants’

organizational commitment (α = .87). Participants were asked to rate

their agreement on each item on a 5-point Likert scale (1 = Strongly

Agree, 5 = Strongly Disagree). An example item from this construct is: “I

find that my values and the organization’s values are very similar.”

196 NORTH AMERICAN JOURNAL OF PSYCHOLOGY

RESULTS

Given these unequal sample sizes, we first conducted an analysis of

variance (ANOVA) to determine if the assumptions for ANOVA were

met. Specifically, we used Levene’s test for equal variance to check the

assumption of equal sample variance. Levene’s test indicated unequal

variance across all of our dependent variables. Therefore, we conducted

Kruskal-Wallis tests for our first three hypotheses.

For our first hypothesis, we predicted that Muslim (H1a) and Jewish

(H1b) individuals are more likely than Christians to report religious

discrimination. A Kruskal-Wallis H test showed there was a statistically

significant difference in perceptions of religious discrimination among

the three groups (H(2) = 19.29, p < .001. Follow-up pairwise com

–

parisons using a Bonferroni correction for multiple tests shows that

Muslim participants (M = 3.84, SD = 1.28) perceived more religious

discrimination than Christian participants (M = 4.45, SD = .77, χ2 = 2.55,
p = .03). Similarly, Jewish participants (M = 4.04, SD = .95) were more

likely to perceive religious discrimination in their organization than

Christian participants (χ2 = 3.60, p = .001). However, there was no

difference between Muslim and Jewish participants (χ2 = .23, p = .82) in
perceptions of religious discrimination. Therefore, Hypothesis 1 was

supported.

For our second hypothesis, we predicted that Muslim (H2a) and

Jewish (H2b) individuals will have lower job satisfaction than Christian

participants. A Kruskal-Wallis H test showed there was a statistically

significant difference in job satisfaction among the three groups (H(2) =

10.18, p = .006). Follow-up pairwise comparisons using a Bonferroni

correction for multiple tests shows Muslim participants (M = 2.60, SD =

1.18) had lower job satisfaction than Christian participants (M = 2.10, SD

= .83, χ2 = 2.21, p = .02). Jewish participants (M = 2.30, SD = .79) also

had lower job satisfaction than Christian participants (χ2 = 2.33, p =
.027). There was no difference between Muslim and Jewish participants

(χ2 = .63, p = .531). Therefore, Hypothesis 2 was supported.
For our third hypothesis, we predicted that Muslim (H3a) and Jewish

(H3b) individuals will have lower organizational commitment than

Christian participants. A Kruskal-Wallis H test showed there was a

statistically significant difference in organizational commitment among

the three groups (H(2) = 6.62, p = .036). Follow-up pairwise comparisons

using a Bonferroni correction for multiple tests shows Muslim

participants (M = 2.83, SD = .92) had lower organizational commitment

than Christian participants (M = 2.49, SD = .87, χ2 = 2.05, p = .041).
However, there was no difference between Jewish participants (M = 2.62,

SD = .80) and Christian participants (χ2 = 1.59, p = .113) or between

Law & Harris DISCRIMINATION IN THE MILITARY 197

Muslim and Jewish participants (χ2 = .84, p = .377). Therefore,
Hypothesis 3 was partially supported.

For our fourth hypothesis, we predicted that religious discrimination

would be related to job satisfaction and organizational commitment.

Specifically, we believed that religious discrimination would be

negatively related to both job satisfaction (H4a) and organizational

commitment (H4b). We conducted regression analyses to test this

hypothesis. We found that religious discrimination was a significant

predictor of both job satisfaction (β = -.34, Adjusted R² = .098) and

organizational commitment (β = -.38, Adjusted R² = .119). Therefore,

Hypotheses 4a and Hypothesis 4b were both supported. To further

understand the relationship between religious discrimination and

organizational outcomes, we conducted a follow-up regression analysis

for each of the three religious denominations in the current study. As

Table 1 shows, religious discrimination is a significant predictor of job

satisfaction for Christian, Muslim, and Jewish individuals in our study.

However, that discrimination accounts for less than 10% of the variance

in job satisfaction for Christians, while accounting for 30% of the

variance in job satisfaction for Muslim individuals. Similarly, religious

discrimination accounted for 12% of the variance in organizational

commitment for Christians, while accounting for 18% of the variance for

Muslim participants.

TABLE 1 Summary of Regression Analysis for Variables Predicting Job

Satisfaction & Organizational Commitment

Christian Muslim Jewish
B β Adj.

R2

B β Adj

. R2

B β Adj

. R2

Job Sat. -.34 -.32 .09*

**

-.52 -.57 .11** -.29 –

.35

.30*

*

Org.

Commit.

-.38

-.34

.12*

**

-.26

-.36

.10

-.37

–

.44

.18*

**

*p<.05, **p<.01, ***p<.001 Job Sat. = Job Satisfaction; Org. Commit. = Organizational

Commitment

DISCUSSION

The current research investigated the impact of religious

discrimination on valued workplace outcomes (e.g., job satisfaction and

organizational commitment) and demonstrated the importance of

managing religious diversity in the workplace. Our results indicate a

198 NORTH AMERICAN JOURNAL OF PSYCHOLOGY

complex relationship between religious minority status, perceived

discrimination, and workplace outcomes. Muslims and Jewish

individuals were more likely than Christians to report that religious

discrimination occurred within their organization. Furthermore, Muslim

and Jewish individuals reported lower levels of job satisfaction.

However, the relationship between religious minority status and

organizational commitment was less consistent. Muslim individuals

reported lower organizational commitment than Christians, but the same

relationship did not hold true for Jewish participants. There was no

difference between Jewish and Christian individuals in organizational

commitment. Finally, we found that perceived discrimination predicted

lower job satisfaction and organizational commitment regardless of

religious affiliation. Importantly, this indicates that one does not need to

be a religious minority to experience detrimental effects of religious

discrimination. Indeed, we found that religious discrimination negatively

affects job satisfaction for Christian, Muslim, and Jewish individuals.

However, that religious discrimination seems to have a greater negative

effect for Muslim individuals. Almost a third of the variance in job

satisfaction was due to religious discrimination for Muslim participants

while only 9% and 11% of variance in job satisfaction was due to

religious discrimination for Christian and Jewish participants

respectively. This suggests that while religious discrimination can be

problematic for an organization regardless of the target, it has particularly

pernicious effects for Muslim employees. This is an important finding

because it indicates that religious discrimination negatively affects

employees, regardless of their religious affiliation. Christian individuals

who perceive there is religious discrimination in their units are just as

likely to suffer from the negative effects of that discrimination as are

religious minorities, albeit the effects may not be as strong as they are for

Muslim employees.

Theoretical and practical implications
The current research shows the risk that organizations take when they

fail to address religious discrimination in their organization. Indeed, our

research suggests employees who face discrimination, regardless of their

religious affiliation, are less satisfied with their jobs, and less committed

to their jobs. Ultimately, this may negatively affect organizations as

employees’ performance may decrease. Judge, Carl, Joyce, and Gregory

(2001) conducted a meta-analysis on the relationship between job

satisfaction and performance, and found a moderately strong correlation

(.30) between those two constructs. This indicates that performance

increases as job satisfaction increases. As job satisfaction decreases, as it

does for those in our study who experience religious discrimination,

Law & Harris DISCRIMINATION IN THE MILITARY 199

performance is likely to also decrease. Thus, it is imperative for

organizations to strive to avoid religious discrimination and strive for the

inclusion of religious minorities.

Why should researchers and practitioners care about religion,

specifically in the workplace? As Duffy, Reid, and Dik (2010) suggest,

religion may not be a discreet aspect of a persons’ life. That is, religious

beliefs are not something that workers discard when they walk through

the door of their workplace, and it is likely that those religious beliefs

influence employees in numerous ways throughout their workday.

Practitioners would be remiss to ignore workers’ religious beliefs.

Instead, organizational leaders should embrace the potential benefits of

understanding and accommodating those beliefs.

Bennett (2008) suggests several ways in which organizations might

better accommodate religious diversity in the workplace. First, he

suggests that organizations implement strategies that comply with

policies and laws that protect employees’ rights to express their religion.

This should be done in such a way that employees do not suffer negative

consequences such as hostility and discrimination and is the absolute

bare minimum that an organization must accomplish to avoid litigation.

Second, he suggests organizations implement strategies that go

beyond the legally mandated protections. Organizations may promote a

climate that is tolerant and accepting of religious diversity by

encouraging open expression of religious beliefs. Of course, this is a fine

line, inasmuch as open expression of one’s religious beliefs may be

considered harassment by others.

Third, organizations can realize the benefits of their workers’

religious and spiritual beliefs by encouraging employees to use their

religious beliefs only when relevant to organizational decision-making.

For example, it would be inappropriate for employees to use their

religious beliefs as a means for discriminating against fellow co-workers,

but their religious beliefs may be beneficial when faced with a business-

related ethical decision.

Fourth, and finally, organizations can make efforts to maximize

strategic growth through utilizing religious and spiritual diversity of its

employees. This may be achieved when the broader mission of an

organization is influenced by the religious beliefs of its members. For

example, an organization may elect to be more environmentally

conscious (e.g., instituting a recycling program) based on the religious

values of the employees.

Implications for military commanders

It is not difficult to find examples of the intricacies military

commanders face regarding religious accommodations when compared to

200 NORTH AMERICAN JOURNAL OF PSYCHOLOGY

their civilian counterparts. For example, Sikh Americans are currently

prohibited from wearing a turban and keeping a well-maintained beard

while in uniform, which is an important part of their religious beliefs.

While they have the opportunity to apply for waivers (three such waivers

have been approved since 2009), there is no guarantee that the waiver

will be granted and Sikh Americans must violate their religious beliefs

while they wait for the decision on the appeal. In November 2015, a

group of 27 General Officers signed a letter to the Secretary of Defense

asking that Sikh Americans be given the same opportunity to serve in the

U.S. Military without violating their religious beliefs. This is only one

example of the difficulties commanders have in regards to religious

accommodation issues.

Perhaps the most important steps the U.S. Military can take in

reducing religious discrimination is to ensure that commanders possess

sufficient knowledge of EO policies, instructions, and directives related

to religious accommodations. Indeed, this is vitally important in a

military setting when the leader is effectively representing the U.S.

Government. Commanders must know what types of religious behavior

are acceptable versus unacceptable. The authors do not advocate that

religion should be absent from the U.S. Military. Completely abolishing

religion from military units would violate the U.S. Constitution. Instead,

we believe that commanders must be provided with information and

training on the intricacies of religious expression in the workplace

throughout their professional military education. For example, in the Air

Force, officers should be provided this training in Squadron Officer

School, Air Command and Staff College, and finally, in Air War

College.

However, knowledge of EO policies and directives is not enough.

Parco (2013) gives several recommendations for ways in which the U.S.

Military may proceed. Perhaps his most important recommendation is

that commanders should be accountable to a “Grade School Standard”

for inappropriate speech (e.g., advocating or denigrating religious

beliefs). He argues that if junior military members are held accountable

for their inappropriate speech, that senior military members should be

held to the same standard. While we agree that commanders should be

held accountable for their speech, we believe this statement is not strong

enough. Military leaders should be held to a higher standard when it

comes to unacceptable behavior and inappropriate religious speech, in

particular.

Finally, we recommend that commanders utilize the knowledge and

expertise that military Chaplains provide. Hunter and Smith (2010)

suggest that military commanders may be placed in an unfair position

when trying to accommodate religious requests from subordinates and

Law & Harris DISCRIMINATION IN THE MILITARY 201

recommend that military Chaplains may be useful in helping

commanders make those decisions. They outlined several factors that

commanders must consider when making religious accommodations.

First, the commander must determine the religious importance of the

requested accommodation. Second, military commanders should consider

the cumulative impact of repeated accommodations. And third, they

should attempt to find alternate accommodations if necessary.

Furthermore, it is likely that military Chaplains could help military

commanders in at least two ways. First, it is unlikely that most military

commanders are knowledgeable on the myriad of world religions. Trying

to determine the religious significance of subordinates may be a daunting

task if the commander is unfamiliar with different religious doctrines.

Military Chaplains possess the knowledge and expertise to better

understand those requests and the importance of those requests. For

example, if a Muslim subordinate asks for time off for a religious Holy

Day, the commander may not know the religious significance of the Holy

Day. However, military Chaplains can advise on the religious

significance of that request, thus removing much of the burden from the

commander. Second, Chaplains may be able to help recommend suitable

alternative accommodations when needed. For example, it might not be

possible for a commander to give time off for a religious celebration.

Furthermore, a commander may not understand the religious significance

of that celebration, making it difficult to find an acceptable alternate

accommodation. Military Chaplains, who have more knowledge of the

religious celebration, can advise commanders and help find an alternate

accommodation that meets the subordinate’s religious needs.

Limitations and future directions

There are two areas that must be addressed in the U.S. Military. First,

some military members may believe they have the right to proselytize to

other military members. As military leaders, proselytizing could be

construed as the establishment of religion by the government. However,

prohibiting proselytizing may violate the free exercise clause. According

to Drab (2007), the resolution to this issue may lie in education. Drab

suggests that education should be an integral part of professional military

education as a way to assuage problems with religious discrimination, in

general, and proselytizing, specifically. The current research does not

address this very important issue. Rather, we focus on the experiences of

religious minorities and the effects of religious discrimination on

organizational outcomes. Future research should better address the types

of religious discrimination that occur, mainly, the effects of proselytizing

in the military.

202 NORTH AMERICAN JOURNAL OF PSYCHOLOGY

Second, the military must address how commanders should facilitate

differences between religious doctrine and military policies. For

example, research shows that religious fundamentalism, which is

described as an authoritarian set of beliefs which are believed to be the

fundamental truth (Altemeyer & Hunsberger, 2004), is consistently

linked to negative attitudes toward homosexuals in samples of Hindu,

Muslim, Jewish, and Christian individuals (Hunsberger, 1996), self-

reported negativity toward lesbian/gay/bisexual individuals (Altemeyer,

2003; Altemeyer & Hunsberger, 1992; Laythe, Finkel, & Kirkpatrick,

2001), and explicit (but not implicit) attitudes toward homosexuals

(Jonathan, 2008). With the recent lifting of restrictions on Lesbian, Gay,

Bisexual, and Transgender (LGBT) military members, the military must

address the possible conflict between deeply held religious beliefs which

condemn homosexuality and the military policy which allows LGBT

individuals all the same protections afforded to their heterosexual

counterparts.

One limitation of the current research is that it does not address the

role of religious accommodations for beliefs that are contrary to one’s

morals. If a Christian believes that homosexuality is morally wrong,

should that person be allowed to openly express their beliefs to gay and

lesbian military members, or would that constitute harassment? Future

research should investigate if these types of situations affect

organizational outcomes for military members. A second limitation to the

current study is the small representation of religious minorities. Although

previous research indicates Muslims and Jewish individuals may be the

most likely to be discriminated against, it would be useful to investigate

other religious minority groups (e.g., Hindu, Native American, or Earth-

based religions). However, as the current study demonstrates, it may not

be methodologically feasible to find a sample from such a small

population of those religious minorities in the military. Indeed, our

Muslim and Jewish sample was fairly small compared to the Christian

sample. It is likely that other religious minorities would be even more

difficult to include in a random sample.

Finally, the current research used a rudimentary variable that should

be expanded in future research. We used religious affiliation to predict

religious discrimination. Although it is theoretically important to

understand how religious minorities experience discrimination in the

workplace, there is a wealth of information that is missing from the

analysis. For example, although one may identify as Christian, their

religious identity may be peripheral in their lives. There are many people

who attend church services infrequently but still affiliate with their

religion. On the other hand, one may have very strong spiritual beliefs

that do not correspond to any organized religion. To remedy this, future

Law & Harris DISCRIMINATION IN THE MILITARY 203

research should use well-established measures of religiosity (e.g.,

intrinsic vs. extrinsic religiosity or Quest Orientation) to better

understand the role of religion in the workplace.

Conclusion

It is likely that religion plays a role in many peoples’ day-to-day

activities, including their workplace activities. Our research shows that

religious discrimination may negatively affect employers and

organizations, regardless of religious beliefs held by employees. This

may be particularly important in the U.S. Military for several reasons.

First, there are highly-publicized reports of religious discrimination in the

U.S. Military, particularly, in the U.S. Air Force. Second, military

commanders are often perceived, rightly or not, as extensions of the

government. Therefore, it is essential that military commanders err on the

side of caution when addressing complaints of religious discrimination or

religious harassment. Third, and finally, religious discrimination is

clearly something that organizational leaders and military leaders cannot

ignore. These leaders should be fully trained and equipped with the

appropriate tools to solve religious accommodations and/or religious

harassment issues within their organizations.

REFERENCES
ABCnews. (2014). Muslim soldiers allege discrimination in U.S. military.

Retrieved on November 4, 2014, from http://abcnews.go.com/WN/army-

discrimination-muslim-army-specialist-zachari-klawonn-

shares/story?id=10372314

Allport, G. W. (1950). The individual and his religion: A psychological

interpretation. New York: Macmillan.

Allport, G. W., & Ross, J. M. (1967). Personal religious orientation and

prejudice. Journal of Personality and Social Psychology, 5, 432-443.

Retrieved from http://www.apa.org/pubs/journals/psp/index.aspx

Altaf, A., & Awan, M. A. (2011). Moderating affect of workplace spirituality on

the relationship of job overload and job satisfaction. Journal of Business

Ethics, 104, 93-99. doi: 10.1007/s10551-011-0891-0

Altemeyer, B., & Hunsberger, B. (1992). Authoritarianism, religious

fundamentalism, quest, and prejudice. International Journal for the

Psychology of Religion, 2, 113-133. Retrieved from http://www.tandfonline.

com/loi/hjpr20#.

V1baqP72a71

Altemeyer, B. (2003). Why do religious fundamentalists tend to be prejudiced?

International Journal for the Psychology of Religion, 13, 17-28. Retrieved

from http://www.tandfonline.com/loi/hjpr20#.V1baqP72a71

Altemeyer, B., & Hunsberger, B. (2004). A revised religious fundamentalism

scale: The short of it. International Journal for the Psychology of Religion,

14, 47-54. Retrieved from http://www.tandfonline.com/loi/hjpr20#.

V1baqP72a71

204 NORTH AMERICAN JOURNAL OF PSYCHOLOGY

Anti-Defamation League. (2017). U.S. Anti-Semitic incidents spike 86 percent so

far in 2017 after surging last year, ADL finds. Retrieved from

https://adl.org/news/press-releases/us-anti-semitic-incidents-spike-86-percent-

so-far-in-2017

Bennett, M. F. (2008). Religious and spiritual diversity in the workplace. In M.

A. Moodian, (Ed.), Contemporary leadership and intercultural competence:

Exploring the cross-cultural dynamics within organizations (pp. 45-59).

Thousand Oaks, CA: Sage.

Cantone, J. A., & Wiener, R. L. (2017). Religion at war: Evaluating hostile work

environment religious discrimination claims. Psychology, Public Policy, and

Law, 23(3), 351-366. http://dx.doi.org/10.1037/law0000132

Cragun, R. T., Kosmin, B., Keysar, A, Hammer, J. H., & Nielsen, M. (2012). On

the receiving end: Discrimination toward the non-religious in the United

States. Journal of Contemporary Religion, 27, 105-127. doi:10.1080/

13537903.2012.642741

Cunningham, G. B. (2010). The influence of religious personal identity on the

relationships among religious dissimilarity, value dissimilarity, and job

satisfaction. Social Justice Research, 23, 60-76. doi: 10.1007/s11211-010-

0109-0

Dean, K. L., Sanfranski, S. R. & Lee, E. S. (2014). Religious accommodations in

the workplace: Understanding religious identity threat and workplace

behaviors in legal disputes. Employee Rights and Responsibilities Journal,

26, 75-94. doi: 10.1007/s10672-013-9232

Drab, J. W. (2007). Constructing religious empathy in the US Military. Research

report submitted in partial fulfillment of the graduation requirements at Air

Command and Staff College Air University.

Duffy, R. D., Reid, L., & Dik, B. J. (2010). Spirituality, religion, and career

development: Implications for the workplace. Journal of Management,

Spirituality, and Religion, 7, 209-221. doi: 10:1080/14766086.2010.500004

Edgell, P., Gerteis, J., & Hartman, D. (2006). Atheist as “other”: Moral

boundaries and cultural membership in American society. American

Sociological Review, 71, 211-234. doi: 10.1177/000312240607100203

EEOC. (2011). Religion-based charges filed from 10/01/2000 through 9/30/2011

showing percentage filed on the basis of religion-Muslim. Retrieved

July 10, 2014 from http://www.eeoc.gov/eeoc/events/9-11-11_religion_

charges.cfm

EEOC. (2013). Enforcement and litigation statistics. Retrieved July 10, 2014

from http://www.eeoc.gov/eeoc/statistics/enforcement/index.cfm

Greenhouse, S. (2010). Muslims report rising discrimination at work. New York

Times. Retrieved from http://www.nytimes.com/2010/09/24/business/24

muslim.html?pagewanted=all&_r=0

Hollon, C. J., & Bright, T. L. (1982). National origin harassment in the work

place: Recent guideline developments from the EEOC. Employee Relations

Law Journal, 8(2), 282-293.

Hunter, C., & Smith, L. (2010). Military leadership and education and religion’s

role in the U.S. Military mission. Technical Report Number 01-10.

Jonathan, E. (2008). The influence of religious fundamentalism, right-wing

authoritarianism, and Christian orthodoxy on explicit and implicit measures

Law & Harris DISCRIMINATION IN THE MILITARY 205

of attitudes toward homosexuals. International Journal for the Psychology of

Religion, 18, 316-329. doi: 10.1080/10508610802229262

Judge, T. A., Carl, J. T., Joyce, E. B., & Gregory, K. P. (2001). The job

satisfaction-job performance relationship: A qualitative and quantitative

review. Psychological Bulletin, 127(3), 376-407.

Kelly, E. P. (2008). Accommodating religious expression in the workplace.

Employee Responsibilities and Rights Journal, 20, 45-56. doi: 10:1007/

s10672-007-9059-6

King, E. B., & Ahmand, A. S. (2010). An experimental field study of

interpersonal discrimination toward Muslim job applicants. Personal

Psychology, 63, 881-906. Doi: 10.1111/j.1744-6570.2010.01199.x

Knotts, T. L. (2003). Relation between employees’ religiosity and job

involvement. Psychological Reports, 93, 867-875. Retrieved from

http://www.amsciepub.com

Kosim, B., Mayer, E., & Keysar, A. (2001). American religious identification

survey 2001. New York: Graduate Center of the City University of New

York.

Kutcher, E. J., Bragger, J. D., Rodriguez-Srednicki, O., & Masco, J. L. (2010).

The role of religiosity in stress, job attitudes, and organizational citizenship

behavior. Journal of Business Ethics, 95, 319-337. doi: 10.1007/s10551-009-

0362-z

Laythe, B., Finkel, B., & Kirkpatrick, L. A. (2001). Predicting prejudice from

religious fundamentalism and right-wing authoritarianism: A multiple-

regression approach. Journal for the Scientific Study of Religion, 40, 1-10.

Retrieved from http://www.jstor.org/stable/1388176

Levy, A. (2013). Local airman claims religious discrimination. San Antonio

Express News. Retrieved on July 10th from https://www.

expressnews.com/news/local/article/Local-airman-claims-religious-discrimin-

ation-4748042.php

Milliman, J., Czaplewski, A. J., & Ferguson, J. (2003). Workplace spirituality

and employee work attitudes: An exploratory empirical assessment. Journal

of Organizational Change Management, 16, 426-447. doi: 10.1108/

09534810310484172

Parco, J. E. (2013). For God and country: Religious fundamentalism in the U.S.

Military. Center for Inquiry, Office of Public Policy. Retrieved on 4

November, 2015 from http://www.centerforinquiry.net/advocacy/

for_god_and_country_religious_fundamentalism_in_the_u.s._military/

Rodda, C. (2010). U.S. soldiers punished for not attending Christian concert.

Huffington Post, retrieved 7 June, 2016 from http://www.huffington

post.com/chris-rodda/us-soldiers-punished-for-_b_687051.html

Ruggs, E. N., Hebl, M. R., Law, C., Cox, C. B., Roehling, M. V., Wiener, R. L.,

& Barron, L. (2013). Gone fishing: I-O psychologists’ missed opportunities

to understand marginalized employees’ experiences with discrimination.

Industrial and Organizational Psychology: Perspectives on Science and

Practice, 6, 39-60. http://dx.doi.org/10.1111/iops.12007

Sharlet, J. (2009). Jesus killed Mohamed. Harpers Magazine. Retrieved July 12,

2014 from http://harpers.org/archive/2009/05/0082488

206 NORTH AMERICAN JOURNAL OF PSYCHOLOGY

Tanenbaum. (2013). What American workers really think about religion:

Tanenbaum’s 2013 Survey of American Workers and Religion. Retrieved

from https://www.tanenbaum.org/2013survey

Note: This research was supported in part by the Office of Naval Research

through a research fellowship with the Defense Equal Opportunity Management

Institute (DEOMI).

Disclaimer: The findings in this report are not to be construed as an official

DEOMI, U.S. military services, or Department of Defense (DoD) position unless

designated by other authorized documents.

Dr. Harris, LT, MSC, USN, is a military service member. This work was

prepared as part of her official duties. Title 17 U.S.C. § 105 provides that

“Copyright protection under this title is not available for any work of the United

States Government.” Title 17 U.S.C. § 101 defines a U.S. Government work as a

work prepared by a military service member or employee of the U.S.

Government as part of that person’s official duties.

Reproduced with permission of copyright owner. Further reproduction
prohibited without permission.

Module 1 – Background

EQUAL EMPLOYMENT OPPORTUNITY & HRM

Required Reading

Critical Thinking:

Cornell University. (2017). Critically analyzing information sources: Critical appraisal and analysis. Retrieved from 

http://olinuris.library.cornell.edu/ref/research/skill26.htm.

 This reading will help you in assessing appropriate reference material.

Cornell University. (2017). Distinguishing scholarly from non-scholarly periodicals: A checklist of criteria: Introduction & definitions. Retrieved from 

http://olinuris.library.cornell.edu/ref/research/skill20.html.

 This reading will help you in assessing appropriate reference material.

Cornell University. (2017). Evaluating Web sites: Criteria and tools. Retrieved from 

http://olinuris.library.cornell.edu/ref/research/webeval.html.

 This reading will help you in assessing appropriate reference material.

Other Assignment Topics:

Anti-Defamation League. (2012). Religious accommodation in the workplace: Your rights and obligations. Retrieved from 

https://www.adl.org/sites/default/files/documents/assets/pdf/civil-rights/religiousfreedom/religfreeres/ReligAccommodWPlace-docx .

 Review the sections on Reasonable Accommodation and Undue Hardship; to be used in the SLP assignment especially.

Brent Goff Reports. (March 2017). In Europe, no religion at work. Retrieved from 

https://www.youtube.com/watch?v=LemKVWkoeXE.

 You will view and comment on this video in the Discussion.

Gepp, R. (2017). Religious accommodation in the workplace: Guidance for Avoiding Legal Trouble. HR Daily Advisor. Retrieved from 

Religious Accommodation in the Workplace: Guidance for Avoiding Legal Trouble

HR Hero. (2017) Age discrimination in Employment Act. Retrieved from 

http://topics.hrhero.com/age-discrimination-in-employment-act-adea/.

 This is a brief overview and required for the Case Assignment.

HR Hero. (2017). Americans with Disabilities Act (ADA) and ADA Amendments Act (ADAAA). Retrieved from 

http://topics.hrhero.com/americans-with-disabilities-act-ada-and-ada-amendments-act-adaaa/.

 This is a brief overview and required for the SLP assignment.

Katz, H. C., Kochan, T. A., & Colvin, A. J. S. (2017).Employment law. An introduction to U. S. collective bargaining and labor relations. Ithaca: Cornell University Press, pg. 71-79. Retrieved from Skillsoft Books in the Trident Online Library.

U.S. Equal Employment Opportunity Commission. (n.d.) Enforcement guidance on reasonable accommodation and undue hardship under the Americans with Disabilities Act. Retrieved from 

https://www.eeoc.gov/policy/docs/accommodation.html

U.S. Equal Employment Opportunity Commission (n.d.) Title VII of the Civil Rights Act of 1964. Retrieved from 

https://www.eeoc.gov/laws/statutes/titlevii.cfm

U.S. Supreme Court. (1971). Griggs v. Duke Power Co, Retrieved from 

http://caselaw.findlaw.com/us-supreme-court/401/424.html.

 Be familiar with the major holdings of this case. This is required for the Case Assignment.

Optional Reading

Beremin, N. (2008, September 10). Adverse impact and disparate treatment [Video file]. Retrieved from 

Dorrian, P. (June 2014). EEOC, attorneys discuss trends in disparate impact litigation. HR Focus, 8-10. Retrieved from the Trident Online Library.

Employment Law Information Network (information on recent cases, laws, HRM-related topics) 

http://www.elinfonet.com/

Equal Employment Opportunity Laws (federal) website: 

http://eeoc.gov

. (See this website for the major federal EEO laws.)

Human resource management and the law. (n.d.) Retrieved from 

Lotito, M., Fitzgerald, B., & LoVerde, D. (Winter 2016). Recent developments in employment law and litigation. Tort Trial & Insurance Practice Law Journal. 51(2) 375-407. Retrieved from the Trident Online Library. This article offers an excellent overview.

Policy Guidance: Application of the Age Discrimination in Employment Act of 1967 (ADEA) and the Equal Pay Act of 1963 (EPA) to American firms overseas, their overseas subsidiaries, and foreign firms. (2003). Retrieved from 

http://www.eeoc.gov/policy/docs/extraterritorial-adea-epa.html

Pyrillis, R. (Nov., 2016) Boomer bust: Age bias appears to be the last acceptable workplace ‘ism’ as older workers struggle to stay relevant among the growing… Workforce (Media Tech Publishing, Inc.), 95 (10). Retrieved from the Trident Online Library.

Sims, R., & Sauser, W. (2015). An introduction to legal issues in human resource management. In Sauser, W. I., & Sims, R. R. Legal and regulatory issues in human resources management. Charlotte, NC: Information Age Publishing. pp. 1-26. Retrieved from EBSCO eBooks in the Trident Online Library. This chapter offers a good background on the HR function and related legal issues.

Section 12: Religious Discrimination. (n.d.). In EEOC Compliance Manual. Retrieved from 

http://www.eeoc.gov/policy/docs/religion.html

Society for Human Resource Management (2016). Visit the SHRM website (

www.shrm.org

) for some of the latest information on dynamic HRM topics, certification details, and SHRM membership information.

State Labor Laws

 website.

United States Department of Labor. (n.d.). Summary of the major laws of the Department of Labor. Retrieved from 

http://www.dol.gov/opa/aboutdol/lawsprog.htm