DeLeon v. Futran Technology Inc.: Religious Accommodation Cannot Compel an Employer to Violate Federal Reporting Duties & Procedural Deadlines for Untimely Rule 59 Motions

1 Introduction

Darren DeLeon, acting pro se, sued Futran Technology Inc. and unnamed defendants after a job offer allegedly collapsed when DeLeon refused, on religious grounds, to provide his Social Security number (SSN) and to sign an independent-contractor agreement. He alleged a grab-bag of federal and state claims—most notably religious discrimination under Title VII. The magistrate judge recommended dismissal; the district court adopted that recommendation and later denied DeLeon’s motion for reconsideration. On appeal, the Eleventh Circuit:

Dismissed DeLeon’s challenge to the original dismissal for lack of appellate jurisdiction (untimely notice of appeal not saved by an untimely Rule 59 motion).
Affirmed the district court’s refusal to reconsider because accommodating DeLeon would have forced Futran to contravene federal law that obligates employers to collect and report SSNs, constituting undue hardship as a matter of law.

Although unpublished, the opinion cements two practical rules for litigants within the Eleventh Circuit:

A religious accommodation under Title VII fails per se when it compels an employer to violate federal statutes or regulations.
A Rule 59 motion filed after the 28-day window does not toll the 30-day period to appeal; a non-prisoner’s papers are filed when received by the clerk, not when mailed.

2 Summary of the Judgment

The Court of Appeals disposed of the case in two parts:

No Appellate Jurisdiction Over the Merits. DeLeon missed the 30-day deadline to appeal the May 9 final judgment. His Rule 59(e) motion, received on June 12 (more than 28 days after judgment), was untimely and therefore did not suspend or “toll” the appeal clock.
Denial of Reconsideration Affirmed. Reviewing for abuse of discretion, the panel held that DeLeon presented neither newly discovered evidence nor manifest error. Title VII does not require Futran to defy federal reporting law; thus, requesting an SSN was a lawful, non-discriminatory requirement, and refusing to waive it is an “undue hardship” under the Supreme Court’s Trans World Airlines, Inc. v. Hardison framework (and now Groff v. DeJoy).

3 Detailed Analysis

3.1 Precedents & Authorities Cited

Thomas v. Phoebe Putney Health Sys., Inc., 972 F.3d 1195 (11th Cir. 2020) – obligation of appellate courts to confirm jurisdiction.
28 U.S.C. § 2107 & Fed. R. App. P. 4(a) – 30-day notice-of-appeal deadline; tolling provisions.
Advanced Bodycare Solutions v. Thione Int’l, 615 F.3d 1352 (11th Cir. 2010) – untimely Rule 59 motion does not toll.
Haney v. Mizell Memorial Hosp., 744 F.2d 1467 (11th Cir. 1984) & Hatchell v. Heckler, 708 F.2d 578 (11th Cir. 1983) – “mailbox rule” limited to prisoners; filing occurs upon receipt.
Arthur v. King, 500 F.3d 1335 (11th Cir. 2007); Michael Linet, Inc. v. Village of Wellington, 408 F.3d 757 (11th Cir. 2005) – narrow grounds for Rule 59(e) relief.
TWA v. Hardison, 432 U.S. 63 (1977) & Groff v. DeJoy, 600 U.S. 447 (2023) – standard for “undue hardship” in Title VII religious accommodation.

Collectively, these authorities shaped both the procedural and substantive rulings: they required dismissal for lack of jurisdiction and supplied the legal yardstick for “undue hardship.”

3.2 The Court’s Legal Reasoning

Jurisdictional Gatekeeping. The panel meticulously applied Rule 4(a), emphasizing that the court lacks power to forgive untimely appeals. Because DeLeon mailed—but the clerk received—his Rule 59 motion after the 28-day limit, the motion did not toll, and the May 9 judgment became incontestable.
Standard of Review – Abuse of Discretion. When reviewing the denial of reconsideration, the panel adopted the deferential framework: a district court abuses its discretion only when it commits a clear error of judgment.
Title VII Analysis – Undue Hardship as a Matter of Law.
- Futran, as an employer, must collect and report employees’ SSNs under 26 U.S.C. § 6109 and IRS/SSA regulations.
- Accommodating DeLeon would force Futran to violate that statutory duty—qualifying as undue hardship under Hardison/Groff.
- Hence, the Title VII claim was legally defective; no amount of re-pleading could cure that deficiency without a change in federal tax law.
No Manifest Error / No New Evidence. DeLeon’s reconsideration motion merely re-argued the merits and attached documents available earlier. Under Eleventh Circuit precedent, that is insufficient.

3.3 Impact on Future Litigation

Even though the opinion is marked DO NOT PUBLISH, it is instructive:

Religious-Accommodation Litigation. Plaintiffs who seek exemptions from federal identification or tax laws are unlikely to succeed; courts will deem employer non-compliance an undue hardship per se.
Procedural Discipline for Pro Se Litigants. The decision reiterates that pro se status does not extend filing deadlines or relax tolling rules. Non-prisoner filings hinge on receipt, not mailing.
Strategic Counsel for Employers. Employers can rely on federal statutory mandates as a solid defense to certain accommodation requests, streamlining early dismissal strategies.
Appellate Practice. The case serves as a cautionary tale: an untimely post-judgment motion may leave a litigant jurisdictionally stranded.

4 Complex Concepts Simplified

Title VII Religious Accommodation: Federal law requires employers to reasonably accommodate an employee’s sincere religious belief, unless doing so creates an undue hardship—now interpreted by the Supreme Court to mean “substantial increased costs in relation to the conduct of the business.”
Undue Hardship: An accommodation that forces an employer to break another law is automatically an undue hardship, ending the analysis in the employer’s favor.
Rule 59(e) Motion: A request, filed within 28 days of judgment, asking the trial court to alter or amend its judgment because of new evidence or clear legal error.
Tolling: Suspending the running of a deadline. A timely Rule 59(e) motion tolls the appeal period; an untimely one does not.
Filing vs. Mailing: For non-incarcerated parties, a document is filed when the clerk’s office receives it—not when the party drops it in the mail. Prisoners get a special “mailbox rule.”

5 Conclusion

The Eleventh Circuit’s unpublished opinion in DeLeon v. Futran Technology Inc. reinforces two core principles:

Employers are not required to violate federal law to accommodate religious beliefs; such requests fail the undue-hardship test.
Procedural deadlines in the Federal Rules—particularly the timing of Rule 59 motions and notices of appeal—are jurisdictional tripwires that neither pro se status nor equitable arguments can erase.

While the ruling carries no formal precedential weight, its practical guidance is unmistakable. Litigants must mind the calendar, and religious-accommodation claims that seek to override statutory duties face an insurmountable barrier. Together, these lessons help clarify the intersection of employment discrimination law, federal reporting obligations, and appellate procedure within the Eleventh Circuit and beyond.