Labor & Employment Law Daily Wrap Up, DISCRIMINATION—RELIGIOUS—D. Or.: Employees’ claims of religious discrimination in COVID-19 vaccine mandate case dismissed, (Feb 7, 2025)

By Patricia K. Ruiz, J.D.

The court found the employees only gave secular objections to the vaccine, if any.

The U.S. District Court for the District of Oregon granted a motion to dismiss by an employer accused of religious discrimination. The employees alleged the employer failed to provide reasonable accommodation by declining to allow them to work without being vaccinated against COVID-19. The court determined the employees’ requests for religious accommodation did not specify how their religious beliefs prevented them from receiving the vaccine (Beeching v. PeaceHealth, No. 6:23-cv-01486-AA (D. Or. Jan. 30, 2025)).

Vaccine mandate. In accordance with an August 2021 rule by the Oregon Health Authority (OHA) requiring all Oregon health care providers and staff to be fully vaccinated against COVID-19 or comply with its process for documenting a religious or medical exemption to the vaccine, PeaceHealth imposed a vaccine mandate to its employees, including allowing employees to apply for religious or medical exemptions to the vaccine. Three employees of PeaceHealth applied for and were granted religious exemptions to the vaccine mandate and were placed on unpaid administrative leave. The employees asserted employment discrimination claims under Title VII of the Civil Rights Act of 1964 and under Oregon law, alleging PeaceHealth discriminated against them when it failed to provide reasonable accommodations by declining to allow them to work unvaccinated, with other precautions. PeaceHealth moved to dismiss.

Religious discrimination claims. PeaceHealth argued that the employees’ underlying bases for objecting to vaccination are not religious beliefs entitled to Title VII protection. Under Title VII, failure-to-accommodate claims are analyzed under a two-part burden-shifting framework. First, a plaintiff must plead a prima facie case of religious discrimination. Once a prima facie case is pleaded, the burden shifts to the employer to show it made good-faith efforts to reasonably accommodate the employee or that it could not reasonably accommodate without undue hardship. The state law claims are analyzed the same way.

Religious discrimination elements. To establish a prima facie case of religious discrimination under Title VII, a plaintiff must plead: (1) they had a bona fide religious belief, the practice of which conflicts with an employment duty; (2) they informed their employer of the belief and conflict; and (3) the employer discharged them because of the employee’s inability to fulfill the job requirement. The plaintiff’s burden in alleging how their religious beliefs conflict with employment requirements is minimal, but courts are not required to take the plaintiff’s conclusory assertions of violations of their religious beliefs at face value, and Title VII does not protect medical, economic, political or social views or personal preferences, requiring courts to distinguish between conflicts that are rooted in religious beliefs as opposed to purely secular philosophical concerns.

Vaccine exemption categories. Courts within the district have noted that vaccine religious exemption cases generally fall into three categories—those in which plaintiffs merely allege a general statement of religious conflict without identifying a conflicting belief; those in which plaintiffs allege a religious belief coupled with a secular objection; and those in which plaintiffs allege a religious belief and a general statement that acquiring the vaccine is in conflict with that belief.

The court found that the first employee’s objection falls into the first category, as she did not indicate how her religious beliefs conflict with obtaining the vaccine. For cases in the first category, courts in the district agree that a general allegation of religious conflict without identifying a conflicting belief is insufficient to survive a motion to dismiss. Thus, the court dismissed the first employee’s religious discrimination claim under Title VII and state law.

The court found the objections of the second and third employees fall into the second category of Title VII case law, a religious belief coupled with a secular objection. While the second employee alleged a religious belief that the “body is a temple of the Holy Spirit,” she objected to the vaccine because she believes it is harmful, ineffective, and lacks proper mandating authority. The third employee alleged a religious belief that her body “is a temple of the living God” but objected to the vaccine as unnecessary and possibly harmful, as she has not been determined by a doctor or a court to be a “direct threat to the health and safety of others.” Courts in the district have held that allegations of a religious belief coupled with a secular objection fail to plead a bona fide religious belief in conflict with an employment duty because the objection itself is secular. The court granted the motion to dismiss as to the second and third employees, finding they failed to state a religious discrimination claim under Title VII and state law.

Other arguments. The court rejected the employees’ arguments as to equitable estoppel, free speech, and free exercise rights and denied leave to amend their complaint.

The case is No. 6:23-cv-01486-AA.

Judge: Aiken, A.

Attorneys: Paul Robert Armstrong Janzen (Rugged Law, Inc.) for Helen Beeching. Geoffrey C. Chackel (Chackel Law, PC) for Charlotte Cramer. Matthew Singer (Schwabe, Williamson & Wyatt PC) for PeaceHealth.

Companies: PeaceHealth

Cases: ReligiousDiscrimination Discrimination Covid19 OregonNews