Sharafeldin v. State of Md. (D. Md. 2000): Prison Chaplain Sues State over Religious Harassment

A former Islamic prison chaplain sued his former employer, the State of Maryland, under Title VII, alleging that the State created a hostile work environment, subjected him to constructive discharge, and was liable for breach of contract for failing to abide by the terms of an earlier attempted settlement. The plaintiff alleged that he was harassed because of his religion for several years, including being involved in physical altercations with other non-Muslim employees, while working as an Islamic chaplain, and that this led to a hostile work environment and to his constructive discharge. The Court dismissed the contract claim, as the state has sovereign immunity under the Eleventh Amendment; but the Court denied the State’s motion for summary judgment on the other two counts, concluding that the plaintiff had established a prima facie case of discrimination.

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