For The Love Of G-D, Don't Say You Love Me

by Cozen O'Connor

We have come to this in our workplaces, in the lyrics of Annie Lennox: “No more ‘I love you’s.” Please enjoy today’s guest post from one of your employees:

I have difficulty getting close to people. I have trouble expressing my true feelings. Some might even call me a closed book. When the right relationship starts to develop, I look the other way. I run. I know you know how I feel about you, but my feelings stay in my own heart and mind. I’m so happy the EEOC has confirmed that I don’t have to tell my co-workers that I love them, whether in person or on any of my social media pages.

I don’t know a lot about all this legal mumbo jumbo, and social media and employment law stuff. I can get that from this awesome blog. But it seems that the government has confirmed that I can be a ranting madman in the workplace, but can’t be required to express my love for anyone. Thus, for example, the NLRB has said that my job may be protected if I call my own boss an “as*hole,” or a “scumbag”, or “fu*king mother fu*ker.” But in this new case I found in New York federal court, called EEOC v. United Health Programs of America, Inc. and Cost Containment Group, Inc., I cannot be forced to say “I love you.”

Now, I won’t get too excited, because the lawsuit just started. It is only a complaint filed by the EEOC, and no decision or rulings have been made yet. In that case, the EEOC believes that the defendants discriminated against 3 individuals (and, presumably, the rest of the workforce) based on religion. Not the employee’s religion, but the company’s “Harnessing Happiness” belief system, also commonly referred to as “Onionhead” religious practices, according to the complaint. That system, in addition to having various spiritual and environmental elements, required employees to say “I love you” to management and colleagues. Stop right there. It’s one thing for my co-workers and I to run around calling our bosses stupid fu*king morons, but expressing thanks and saying “I love you” has absolutely no place in my workplace!!

The allegedly aggrieved individuals in that case did not want to participate in the company’s practices. As the EEOC alleged in the complaint:

“Defendants failed to accommodate [plaintiffs] and other aggrieved individuals’ own religious beliefs or lack thereof. Defendants compelled employees to take part in Onionhead-related religious activities on a routine basis to maintain their employment with Defendants. [Plaintiffs] and other aggrieved individuals made known their opposition to Onionhead related religious practices to Defendants and faced termination for this reason.”

Thank you NLRB, and EEOC. Now please let me go back to work in anger.

Employer Take Away: What should you as an employer take away from this development?   

Thanks to your employee for an enlightening guest blog post.  As a company, I think there are 3 primary takeaways from this new lawsuit:

            1. Religion, religious expression, and religious accommodation in the workplace continue to be hot-button, emotion-provoking issues that mirror the larger debate over the place that religion has in our country. The EEOC is, and will likely continue to be, focused on religious discrimination and accommodation, so your company better focus on the legal obligations under federal, state, and local law regarding what you can and cannot do in the area of religion in the workplace.

            2. Social media makes it easy for individuals to find others and engage in collective expression with others who share similarly-held sincere religious beliefs. Do not simply dismiss outright religious expression, and expressed need for religious accommodation, but rather analyze your particular situation to determine what you need to do, if anything, in response.

            3. As Annie Lennox also sang, “put a little love in your heart.”  Just not in your policies.


DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

© Cozen O'Connor | Attorney Advertising

Written by:

Cozen O'Connor

Cozen O'Connor on:

Readers' Choice 2017
Reporters on Deadline

"My best business intelligence, in one easy email…"

Your first step to building a free, personalized, morning email brief covering pertinent authors and topics on JD Supra:
Sign up using*

Already signed up? Log in here

*By using the service, you signify your acceptance of JD Supra's Privacy Policy.
Custom Email Digest
Privacy Policy (Updated: October 8, 2015):

JD Supra provides users with access to its legal industry publishing services (the "Service") through its website (the "Website") as well as through other sources. Our policies with regard to data collection and use of personal information of users of the Service, regardless of the manner in which users access the Service, and visitors to the Website are set forth in this statement ("Policy"). By using the Service, you signify your acceptance of this Policy.

Information Collection and Use by JD Supra

JD Supra collects users' names, companies, titles, e-mail address and industry. JD Supra also tracks the pages that users visit, logs IP addresses and aggregates non-personally identifiable user data and browser type. This data is gathered using cookies and other technologies.

The information and data collected is used to authenticate users and to send notifications relating to the Service, including email alerts to which users have subscribed; to manage the Service and Website, to improve the Service and to customize the user's experience. This information is also provided to the authors of the content to give them insight into their readership and help them to improve their content, so that it is most useful for our users.

JD Supra does not sell, rent or otherwise provide your details to third parties, other than to the authors of the content on JD Supra.

If you prefer not to enable cookies, you may change your browser settings to disable cookies; however, please note that rejecting cookies while visiting the Website may result in certain parts of the Website not operating correctly or as efficiently as if cookies were allowed.

Email Choice/Opt-out

Users who opt in to receive emails may choose to no longer receive e-mail updates and newsletters by selecting the "opt-out of future email" option in the email they receive from JD Supra or in their JD Supra account management screen.


JD Supra takes reasonable precautions to insure that user information is kept private. We restrict access to user information to those individuals who reasonably need access to perform their job functions, such as our third party email service, customer service personnel and technical staff. However, please note that no method of transmitting or storing data is completely secure and we cannot guarantee the security of user information. Unauthorized entry or use, hardware or software failure, and other factors may compromise the security of user information at any time.

If you have reason to believe that your interaction with us is no longer secure, you must immediately notify us of the problem by contacting us at In the unlikely event that we believe that the security of your user information in our possession or control may have been compromised, we may seek to notify you of that development and, if so, will endeavor to do so as promptly as practicable under the circumstances.

Sharing and Disclosure of Information JD Supra Collects

Except as otherwise described in this privacy statement, JD Supra will not disclose personal information to any third party unless we believe that disclosure is necessary to: (1) comply with applicable laws; (2) respond to governmental inquiries or requests; (3) comply with valid legal process; (4) protect the rights, privacy, safety or property of JD Supra, users of the Service, Website visitors or the public; (5) permit us to pursue available remedies or limit the damages that we may sustain; and (6) enforce our Terms & Conditions of Use.

In the event there is a change in the corporate structure of JD Supra such as, but not limited to, merger, consolidation, sale, liquidation or transfer of substantial assets, JD Supra may, in its sole discretion, transfer, sell or assign information collected on and through the Service to one or more affiliated or unaffiliated third parties.

Links to Other Websites

This Website and the Service may contain links to other websites. The operator of such other websites may collect information about you, including through cookies or other technologies. If you are using the Service through the Website and link to another site, you will leave the Website and this Policy will not apply to your use of and activity on those other sites. We encourage you to read the legal notices posted on those sites, including their privacy policies. We shall have no responsibility or liability for your visitation to, and the data collection and use practices of, such other sites. This Policy applies solely to the information collected in connection with your use of this Website and does not apply to any practices conducted offline or in connection with any other websites.

Changes in Our Privacy Policy

We reserve the right to change this Policy at any time. Please refer to the date at the top of this page to determine when this Policy was last revised. Any changes to our privacy policy will become effective upon posting of the revised policy on the Website. By continuing to use the Service or Website following such changes, you will be deemed to have agreed to such changes. If you do not agree with the terms of this Policy, as it may be amended from time to time, in whole or part, please do not continue using the Service or the Website.

Contacting JD Supra

If you have any questions about this privacy statement, the practices of this site, your dealings with this Web site, or if you would like to change any of the information you have provided to us, please contact us at:

- hide
*With LinkedIn, you don't need to create a separate login to manage your free JD Supra account, and we can make suggestions based on your needs and interests. We will not post anything on LinkedIn in your name. Or, sign up using your email address.