This paper focuses on the duty of employers to make religious accommodations for employees. First it examines the First Amendment. Then it discusses major Supreme Court decisions from industry and education in the context of the 1964 Civil Rights Act and 1972 Amendment. One important case--Trans World Airlines Inc. v. Hardison--ruled in favor of the plaintiff, stating that to require TWA to bear more than a de minimis cost in order to give Hardison Saturdays off would be an undue hardship. The paper concludes, however, that many church-state issues that are yet to be resolved are or were not even seriously discussed in Hardison. For example, majority arbitrary religious mandates should be no more or less constitutionally sheltered than minority religious mandates. (Author/LD)