Plaintiffs Kenneth Ringhofer, Anita Miller, Shelly Kiel, Sherry Ihde, and Kristin Rubin sued The Mayo Clinic, Mayo Clinic Health System–Southeast Minnesota Region, and Mayo Clinic, Ambulance (collectively “Mayo”) in the United States District Court for the District of Minnesota, raising claims of failure to accommodate their religious beliefs under Title VII and the Minnesota Human Rights Act (MHRA). The district court dismissed the claims, and the plaintiffs appealed to the United States Court of Appeals for the Eighth Circuit.
Factual Overview
During the Covid-19 pandemic, Mayo required all employees to receive the vaccine or, if exempted, to test weekly. The plaintiffs sought religious accommodations for the vaccination requirement, citing their Christian religious beliefs. Mayo denied the accommodations for Kiel, Ringhofer, and Miller, who refused to get the vaccine. It granted vaccination exemptions to Ihde and Rubin but required them to test for Covid-19 weekly, which they refused.
Legal Analysis
Exhaustion of Administrative Remedies: The Eighth Circuit reversed the district court’s ruling that Miller and Ihde did not exhaust their administrative remedies under Title VII. The court found that their eventual terminations were reasonably related to their EEOC charges challenging the Covid-19 vaccination policy, and therefore, they had exhausted their administrative remedies.
Failure to State a Claim: The Eighth Circuit reversed the district court’s dismissal of Kiel, Ringhofer, and Rubin’s Title VII claims for failure to plausibly plead that their religious beliefs conflicted with Mayo’s Covid-19 policies. The court found that, when read as a whole, the complaints plausibly connected the plaintiffs’ refusal to receive the vaccine or undergo testing with their religious beliefs.
MHRA Claim: The Eighth Circuit reversed the district court’s ruling that the MHRA does not provide a cause of action for failure to accommodate religious beliefs. The court predicted that, due to Minnesota’s precedent of construing the MHRA liberally and providing its citizens with greater protections than under federal law, the Minnesota Supreme Court would decide that the MHRA provides protection against failures to accommodate religious beliefs.
The Eighth Circuit reversed the district court’s judgment and remanded the case for further proceedings consistent with its opinion.
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