In Yott v. North American Rockwell Corp.,28 a Seventh Day Adventist objected to joining a recently certified union that had negotiated a union security clause requiring all employees to pay union dues. Yott is the first acknowledged Title VII case to countenance attacks on union security.29 Citing religious prohibitions on either joining or paying dues to union, Yott sought an exemption from the union security clause, but made no offer to pay either an agency fee or to contribute his dues to a charity.30 The union refused the exemption, and Yott was ultimately fired according to the terms of the bargaining agreement.

A trial court dismissed Yott's subsequent lawsuit, but the appellate court held that Title VII imposed an obligation on both the employer and the union to make reasonable accommodation of Yott's religious beliefs, so long as such accommodation did not constitute an undue hardship to the employer or the union.31

Additionally, the court construed the 1972 amendments to Title VII as applicable to issues regarding union membership and the ability to avoid paying union dues.32 Although Yott ultimately lost his case, it marked the first use of Title VII by the courts to undergird the rights of employees whose religious convictions are harmed by union membership.