齐恩尼诉梅赛德斯-奔驰美国国际公司案

Mouatasem Zienni, a Lebanese-born Arab and practicing Muslim, worked on the assembly line at Mercedes-Benz U.S. International, Inc.‘s (MBUSI) plant in Vance, Alabama, from June 20, 2022, until early January 2023. Zienni sued MBUSI, asserting claims of religious discrimination under Title VII of the Civil Rights Act of 1964 and retaliatory mistreatment. He alleged that MBUSI prevented him from praying outside scheduled break times and threatened him with demotion after he complained. On November 19, 2024, the U.S. District Court for the Northern District of Alabama granted MBUSI's motion for summary judgment. Zienni appealed, and on December 22, 2025, the Eleventh Circuit affirmed the district court's decision.

The district court granted MBUSI's motion for summary judgment on all claims, finding that Zienni failed to show that MBUSI took any adverse employment action against him. The court determined that even if a team leader's comment about transferring Zienni was an adverse action, there was no evidence the team leader knew about Zienni's EEOC charge. The Eleventh Circuit affirmed the summary judgment on December 22, 2025.

Whether Zienni established a prima facie case of religious discrimination under Title VII by demonstrating that MBUSI took an adverse employment action against him. The court also examined whether Zienni could demonstrate retaliatory mistreatment following his EEOC charge. The central issue was whether the alleged denial of a religious accommodation and statements about possible discipline constituted adverse actions.

The case highlights the ongoing tension between workplace operational requirements and religious accommodation under Title VII. It underscores the Supreme Court's Muldrow v. City of St. Louis decision, clarifying that workers must show a job action caused them “some harm”. The ruling demonstrates that speculative threats of discipline, without actual adverse consequences, are insufficient to establish religious discrimination claims. The case serves as a precedent for employers in managing religious accommodation requests in safety-sensitive industrial settings.