Objection to Vaccine Mandate Can Prevail Under Religious Discrimination Claim

In French v. St. Charles Health Sys., Inc., the United States District Court for the District of Oregon ruled on whether a plaintiff can assert a religious discrimination claim despite also expressing a secular concern about vaccine safety in the same claim.

Seyfarth explains that the case involved four plaintiffs who sued their former employer, St. Charles Health System, Inc., for religious discrimination after their requests for religious exemptions from a COVID-19 vaccine mandate were denied.

The case arose when one plaintiff requested a religious exemption, stating that her belief that her “body is a temple of the Holy Spirit” conflicted with taking a potentially harmful vaccine. She also voiced concerns about the vaccine’s side effects due to limited testing.

St. Charles moved to dismiss under Rule 12(b)(6), arguing that the plaintiff’s objections were primarily secular and devoid of legal protection, and her religious claims were conclusory.

The court disagreed, finding that her religious claims were adequately detailed, and noted that she had explained in a letter to her employer that her beliefs were informed by her understanding of a specific passage of Scripture.

The court then ruled that secular concerns about vaccine safety did not negate her religious motivation and allowed the claim to proceed past the motion to dismiss stage.

Employers should carefully evaluate exemption requests and avoid dismissing them solely based on secular concerns. Legal counsel should assess whether a claim sufficiently invokes a specific religious belief before advising on a dismissal strategy.

Seyfarth writes that the Oregon court “joined a growing trend in workplace vaccination litigation when it ruled that a plaintiff’s allegations of religious conflict with vaccination are sufficient to survive a motion to dismiss even when religious motives are coupled with secular concerns over vaccine safety.”