A state court has in fact found that it was religious harassment for an employer to put religious articles in its employee newsletter and Christian-themed verses on its paychecks. 26 The EEOC likewise found that a claim that an employer "permitted the daily broadcast of prayers over the public address system" over the span of a year was "sufficient to allege the existence of a hostile working environment predicated on religious discrimination." 27 A recent article by two employment lawyers gives "repeated, unwanted `preaching´ episodes [by a fundamentalist Christian employee] that offend coworkers and adversely affect their working conditions" as a "bright-line example[]" of actionable harassment; an employer in such a situation would be "well advised to take swift remedial action." 28 If polite religious proselytizing can be harassment, then of course harsher criticism of religion would be, too.

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