SSN Policy Manual

Some Examples

This section provides three case examples against using a social security number: two wins, one loss.

EEOC v. Information Systems Consulting

Plaintiffs Response to Defendant's Motion to Dismiss IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF TEXAS DALLAS DIVISION

EQUAL EMPLOYMENT OPPORTUNITY

) ) ) )

COMMISSION,

CIVIL ACTION

Plaintiff,

V.

) NO.CA3-92-0169-T 1

INFORMATION SYSTEMS CONSULTING ) A DIVISION OF DIVERSIFIED HUMAN 1 RESOURCES GROUP, 1 Defendant. 1

PLAINTIFF'S RESPONSE TO DEFENDENT'S MOTION TO DISMISS The Plaintiff, Equal Employment Opportunity Commission (hereinafter the "Commission" or "EEOC"), files this response to Defendant's Motion to Dismiss and Brief filed in support thereof. The EEOC alleged in its Complaint that defendant's failure to accommodate Bruce Hanson's religious beliefs violated Title VII of the Civil Rights Act of 1964. In its motion, the defendant contends that the Commission's complaint should be dismissed because the Commission failed to allege specific and detailed facts concerning Mr. Hanson's bona fide religious belief that prohibits him from obtaining a social security number. Further, the defendant contends that the Internal Revenue Service requires that an employee obtain a social security number and therefore Mr. Hanson's religious belief does not conflict with an employment requirement of the defendant. Finally, the defendant asserts that it could not accommodate Mr. Hanson's belief because it would be subject to penalties under the Internal Revenue Code and the Immigration Reform and Control Act of 1986.