also asked each of them if there was anything that could be done on his behalf so he could keep his job. None of the three officials gave him an alternative therefore Lawson felt he was forced to resign. In this case, the district court justices were divided on outcome. One of the justices felt that Lawson was not able to provide a prima facie case because he did not present any facts on the issue of constructive discharge, therefore granting summary judgment to the employer. A constructive discharge occurs when the employee is given no reasonable alternative but to terminate the employment relationship; considers an involuntary act on the part of the employee (Bennett-Alexander & Hartman, 2004). However, the Circuit Judge dissenting said Lawson did have a case. In the manual the Circuit Judge stated there were no exceptions under the Washington State Patrol policy, not leaving room for accommodations. The circuit judge goes onto say the high ranking officials did nothing to help Lawson find an alternative to resignation. Therefore, the Circuit Judge found Lawson had established a case of religious discrimination and the case went to trial (Opinion Brief, 2001).
             The Workplace Religious Freedom Act may have an impact on religious accommodation in the future employment environment. This act prohibits "arbitrary and unfair refusal to tolerate religious expression in the workplace" (Elvin, 2004). The act is to prevent employers from finding loopholes within Title VII. According to Title VII, employers are to make reasonable accommodations for religious beliefs and practices of their employees. The term accommodation can mean a minimal expense which some have determined as creating an undue hardship on their company. This has caused some employers from accommodating for an employee. This bill is currently waiting action in the Senate Committee on Health, Education, Labor and Pensions (Eckstrom, 2003).
             The U.S. Supreme Court ...