Kimberly Cloutier alleged that her employer, Costco Wholesale Corp., failed to offer her a reasonable accommodation after she alerted it to a conflict between the "no facial jewelry" provision of its dress code and her religious practice as a member of the Church of Body Modification. She argued that this failure amounted to religious discrimination in violation of Title VII. The district court granted summary judgment for Costco, concluding that Costco reasonably accommodated Cloutier by offering to reinstate her if she either covered her facial piercing with a band-aid or replaced it with a clear retainer. The 1 st Circuit affirmed, but on a different basis. It held that Costco had no duty to accommodate Cloutier because it could not do so without undue hardship.

The Church of Body Modification! She should at least get points for creativity!