Federal appeals court says one supervisor's reply to a Ramadan request could be enough
A single remark about Ramadan revived a fired federal economist's discrimination case - and put supervisor accommodation responses back in HR's spotlight.
A US appeals court has given Farah Naz, a former Department of Energy economist, another shot at her religious discrimination case against the agency. On June 9, 2026, the US Court of Appeals for the District of Columbia Circuit vacated a lower court's dismissal of her Title VII discrimination claims and sent the case back for further proceedings. It upheld dismissal of her retaliation claim.
Naz, a Muslim woman of Pakistani origin, worked as an economist in the Department's Office of Energy Consumption and Efficiency Analysis from January 2017 until her firing in January 2021. She sued the Department pro se in June 2022, alleging discrimination based on race, gender, sex, religion and national origin, plus retaliation.
She traces her trouble at work to April 2018, several months after she testified in support of a colleague's EEO complaint against her then-supervisor, Kelly Perl. According to her complaint, Perl turned hostile and told her "non-native people" like her often "have difficulty writing" and asked whether she had "attended school in the United States." Naz filed her own EEO complaint against Perl in late 2018, after being placed on a 90-day performance plan.
In March 2019, Peter Gross took over as her supervisor. Naz alleged Gross knew about her EEO complaint, micromanaged her, denied her an automatic grade increase and reinstated a performance plan. She filed a second EEO complaint, this one against Gross, in October 2019. He issued her a notice of removal in August 2020, and the Department fired her in January 2021.
The whole appeal turned on one allegation - one that Naz raised in her opposition to the Department's motion to dismiss, not in the complaint itself. Naz alleged that in May or June 2019, she asked Gross to push weekly team meetings 30 minutes later during Ramadan and to allow her a flexible schedule for religious observance. According to her filing, Gross "bluntly replied to me that [the Department] is a workplace, not a religious institution, and he does not believe in Islamic religious extremism."
Chief Judge Srinivasan, writing for the panel, said the district court did not appear to factor that allegation in when it dismissed her discrimination claims. Under D.C. Circuit precedent, courts handling pro se lawsuits generally must look at more than the complaint - including facts laid out in an opposition to a motion to dismiss. The panel said the alleged remark, made little more than a year before Naz's removal notice, supports a religious discrimination claim.
The court was split. Circuit Judge Katsas agreed the retaliation claim was rightly dismissed but disagreed with vacating the discrimination dismissal. He wrote that neither Naz nor the court-appointed amicus specifically pointed to the "Islamic religious extremism" allegation in their appellate briefing, and said a district court should not be expected to dig a single allegation out of a 148-page opposition with more than 1,000 pages of exhibits.
The retaliation claim is done. The panel agreed with the district court that Naz had not adequately alleged a causal link between her protected EEO activity and the adverse actions that followed.
For HR, the takeaway is direct. A single supervisor remark - made in the context of refusing a religious accommodation request, and tied closely in time to later adverse action - can be enough to push a discrimination case past dismissal at the federal appellate level. How managers respond to accommodation requests, in real time and in writing, matters. So does training supervisors to handle religious observance requests neutrally and to document the business reason for any limit on flexibility.
The case now goes back to the district court, which will decide whether to credit the Ramadan allegation or explain why it can be set aside - for example, under court rules governing pro se filings.
