Labor & Employment Law Daily Wrap Up, DISCRIMINATION—RELIGIOUS—W.D. Pa.: Jury to decide sincerity of fired T-Mobile employee’s religious beliefs, (Oct 7, 2025)

By Tulay Turan, J.D.

Whether secular or religious beliefs predominate in a religious accommodation request is a credibility question for a jury.

A T-Mobile salesperson, who was terminated for noncompliance with the company’s COVID-19 vaccination policy, can proceed to trial with her Title VII and state religious discrimination claims, a federal district court in Pennsylvania ruled. There were genuine issues of material fact regarding the sincerity of her religious beliefs, whether T-Mobile offered her a reasonable accommodation, and whether it would have suffered an undue hardship if it allowed her to remain in her position unvaccinated. However, the court granted T-Mobile’s motion for summary judgment on her pregnancy discrimination claim because she failed to show a nexus between her pregnancy and termination, which occurred after she returned from maternity leave (Pruitt v. T-Mobile, No. 2:23-cv-1950 (E.D. Pa. Oct. 6, 2025)).

The employee worked as a major account executive for T-Mobile and began working remotely in mid-March 2020 due to the COVID-19 pandemic. In August 2021, T-Mobile announced the implementation of a policy that would designate all badge-controlled office locations as “COVID-19 vaccinated-only office spaces” effective in late September. The employee’s position was located at one of the vaccination-only workspaces although she had been working remotely for over a year when the policy was announced.

Accommodation request. In September 2021, the employee submitted a written religious accommodation request. T-Mobile granted her an exemption from the requirement to return to in-person work at the office until January 2022. In late January 2022, T-Mobile required employees to be fully vaccinated by April 2, 2022. Those who did not comply would be placed on unpaid leave.

Pregnancy. Also in January 2022, the employee informed her manager that she was pregnant. In addition to her religious accommodation request, she submitted two medical accommodation requests, which T-Mobile denied following its determination that it could not accommodate her based on the essential function of her job and the risk of harm that her unvaccinated status posed to herself and others. She had, however, been granted a medical leave of absence through her delivery date of September 2022, and that leave was converted into 12 weeks of paid maternity leave through December 2022.

Return to work. The employee returned to work remotely from her home in December 2022. She claimed T-Mobile approved the arrangement. However, after working for a week and half, T-Mobile terminated her. The company claimed that it considered accommodations for her that did not require vaccination, but that she rejected all such accommodations. The employee claimed an HR representative testified that he did not know who, when, or how T-Mobile allegedly reached out to her about a different position and that he was under the impression that any alleged job offer was for a temporary position.

Complaint filed. Thereafter, the employee filed a complaint alleging that T-Mobile discriminated against her on the basis of religion, pregnancy, and disability under Title VII and the Pennsylvania Human Relations Act. T-Mobile filed this motion for summary judgment on all claims. The employee sought partial summary judgment on her religious discrimination claims.

Religious objection. Addressing the employee’s religious discrimination claims, the court found there was a genuine dispute of material fact as to whether she objected to the vaccination policy because of her religious beliefs. Thus, neither party was entitled to summary judgment on these claims because whether secular or religious beliefs predominate in a religious accommodation request is a credibility question for a jury to decide, the court said.

The employee submitted evidence sufficient to find that her statements regarding her religious beliefs “did not merely cloak otherwise secular and medical concerns.” She expressly stated in her accommodation request that “as a Bible-believing Born Again Christian, I believe in the sanctity of human life.” She also stated that it was “completely unacceptable for me to receive any product that uses aborted fetal cells for testing or development.” Her deposition testimony further demonstrated her religious beliefs, as she and her husband do not vaccinate their children because they “don’t want to alter their God-given immune systems.” A reasonable jury, the court said, could find that her objection to vaccination was grounded in a sincere religious belief.

However, T-Mobile adduced evidence that her secular and medical concerns could have predominately motivated her vaccination refusal. She admitted to receiving two immunizations after the age of 18 despite stating the contrary in her exemption request. T-Mobile also pointed to material facts such as her statement that she “avoids toxins as much as she can,” her concerns about cardiac issues associated with COVID-19 vaccines, and her belief that COVID-19 vaccines were rushed to market and not subject to adequate testing. These facts created a genuine dispute of material fact. Whether her noncompliance with T-Mobile’s vaccination policy credibly rested on religious grounds must be resolved by a jury, the court found.

Reasonable accommodation. Likewise, a genuine dispute existed regarding whether T-Mobile offered the employee a reasonable accommodation. The record was clear that T-Mobile offered her an alternative, fully remote position that did not require vaccination. Whether that position was temporary, the amount of its compensation, and the nature of T-Mobile’s cooperation with her were all disputed issues of material fact. Thus, the issue of whether T-Mobile offered her a reasonable accommodation must be resolved by a jury.

Undue hardship. Regarding T-Mobile’s argument that it would have suffered an undue hardship if it allowed the employee to remain in her position unvaccinated, the court found this also was an issue for a jury to resolve.

As a threshold matter, the court noted that the Supreme Court’s heightened undue hardship standard, which requires the employer’s burden to rise to an “excessive” or “unjustifiable” level as set forth in Groff, applied. The court rejected T-Mobile’s argument that the de minimis standard applied because the employee’s accommodation request predated Groff. The court explained that “[w]here the Supreme Court has applied a rule of federal law to the parties before it, the Court is required to give retroactive effect to that rule in all cases still open on direct review and as to all events, regardless of whether they predate the announcement of the rule.”

Noting that an undue hardship analysis is rooted in a “keen review of the facts,” the court found there was a genuine dispute of material fact as to whether accommodating the employee would have imposed an undue hardship on T-Mobile. The safety concerns that would have made her return to the office an excessive and unjustifiable burden demanded a credibility determination, as did T-Mobile’s argument that she could not have continued to meet with customers and fulfill her duties if she remained unvaccinated. Her argument that she could have fulfilled her responsibilities while remaining unvaccinated also required a credibility determination.

Pregnancy discrimination. Finally, the court granted T-Mobile’s motion for summary judgment on the employee’s pregnancy discrimination claim because she failed to show a nexus between her pregnancy and termination. She admitted during her deposition that she knew before informing T-Mobile of her pregnancy that she could be terminated if she refused COVID-19 vaccination, that she was treated the same as any other unvaccinated employee in a similar role, that she understood the policy applied to everyone regardless of their religion or pregnancy status, and that she was treated the same and “actually better than” non-pregnant employees who were unvaccinated.

The court found the evidence showed that T-Mobile accommodated her pregnancy. No evidence of hostile treatment existed after she revealed her pregnancy. T-Mobile granted her leave pending the birth of her child, and she received 12 subsequent weeks of paid maternity leave thereafter. T-Mobile did not terminate her employment after she informed her supervisors that she was pregnant, and she was not terminated while on leave. She was terminated when she resumed working after her leave and chose not to comply with the vaccination policy. No record evidence existed to support her claim that she was treated differently due to her pregnancy. Accordingly, the court granted T-Mobile’s motion for summary judgment on this claim.

The case is No. 2:23-cv-1950.

Judge: Stickman IV, W.

Attorneys: Andrea Shaw (Law Office of Andrew H. Shaw) for Kylie Pruitt. Andrew Maunz (Jackson Lewis) for T-Mobile USA, Inc.

Companies: T-Mobile USA, Inc.

Cases: Discrimination ReligiousDiscrimination DisabilityDiscrimination PregnancyDiscrimination Discharge Covid19 PennsylvaniaNews