In the case before the United States District Court, Eastern District of Missouri, plaintiff Heidi Jacobs sued defendant Mercy Health, alleging religious discrimination under Title VII of the Civil Rights Act and disability discrimination under the Americans with Disabilities Act Amendments Act (ADA). The court granted the defendant’s motion for summary judgment on both claims.
Statement of Undisputed Facts
Heidi Jacobs applied for a “V Acute Nurse” position at Mercy Health’s Virtual Care Center, contingent on compliance with Mercy Health’s vaccination policies, which, during the COVID-19 pandemic, required employees to receive COVID-19 and influenza vaccines. Jacobs sought religious and medical exemptions for both vaccines, claiming her non-denominational Christian faith trusts in God-given immunity over vaccinations and citing a suspected diagnosis of Guillain-Barré Syndrome (GBS) from a past influenza vaccine reaction. Mercy Health denied her religious exemption requests, stating Jacobs had not identified any religious belief violated by receiving the vaccine. Despite her medical exemption request for the influenza vaccine being granted due to her alleged history of GBS, her exemption request for the COVID-19 vaccine was denied because GBS is not recognized by the CDC as a contraindication for receiving the COVID-19 vaccine. Consequently, Mercy Health rescinded Jacobs’s employment offer for failing to meet the vaccination policy, leading to her lawsuit.
Legal Analysis
Title VII Religious Discrimination Claim: The court found that Mercy Health, as a religious organization, is exempt from claims of religious discrimination under Title VII. Despite Jacobs’s argument that her beliefs are religious, the court determined that the exemption applies broadly and does not require the employer to justify its employment decisions based on religious doctrine. The court further concluded that Jacobs’s claims of religious discrimination fail as a matter of law because the religious organization exemption shields Mercy Health from such claims.
ADA Disability Discrimination Claim: Under the ADA, an individual must demonstrate a disability that substantially limits one or more major life activities. Jacobs argued that her suspected GBS, an episodic condition potentially exacerbated by vaccines, constituted a disability. Even so, the court found Jacobs failed to establish she has a disability under the ADA, noting her condition did not impair any major life activities, she never received a formal diagnosis of GBS, and her symptoms from a past vaccine reaction were temporary and resolved without medical intervention. The court also found the requested accommodation of a vaccine exemption was not reasonable because the CDC does not recognize GBS as a contraindication for the COVID-19 vaccine. Therefore, Jacobs’s ADA discrimination claim also fails as a matter of law. In conclusion, the court granted Mercy Health’s motion for summary judgment on both the Title VII religious discrimination and ADA disability discrimination claims
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