On February 7, 2012, the US Court of Appeals for the Eleventh Circuit issued an opinion in Walden v. Centers for Disease Control. One key issue in the case was whether the employer discriminated against an employee in violation of Title VII when it laid her off after she refused, because of her religious beliefs, to provide counseling to a client about a same-sex relationship.

The plaintiff, Walden, was a counselor for Computer Sciences Corporation (CSC), which administered the Employee Assistance Program (EAP) for the Centers for Disease Control and Prevention (CDC). The CDC's approval was required for all EAP counselors, and the CDC could request the immediate removal of an EAP counselor from the program.

Under the EAP guidelines and procedures, Walden was required to provide EAP services to all CDC employees, regardless of the nature of the employee's issue. However, Walden, a devout Christian, concluded that she could not provide same-sex relationship counseling to a CDC employee because it conflicted with her religious beliefs. Walden informed this CDC employee that she could not provide counseling to her because of her "personal values" and referred the client to another counselor. The CDC employee complained.

Walden's supervisor discussed the incident with her and recommended an alternative approach, but Walden refused to use that approach. CSC investigated the matter and discussed it with the CDC, which eventually asked that Walden be removed from the EAP. CSC complied with the CDC's request.

CSC laid Walden off, instead of terminating her for cause. Her layoff designation meant that:

Walden did not apply for a different position at CSC and filed suit against CSC and several other defendants alleging religious discrimination in violation of Title VII, among other claims. With respect to Walden's Title VII claim, the district court granted summary judgment in favor of CSC, holding:

Walden appealed to the Eleventh Circuit.

On February 7, 2012, the Eleventh Circuit affirmed the district court's grant of summary judgment in favor of CSC with respect to Walden's Title VII claim. The Eleventh Circuit did not decide whether Walden established a prima facie case, but held that even if she could establish a prima facie case, her claim failed because CSC reasonably accommodated her as a matter of law by:

The court explained that:

This decision clarifies that in the Eleventh Circuit:

This case is particularly noteworthy because there has been a recent increase in religious discrimination claims under Title VII, and there is not much guidance on the issues raised in this case.