Pamela Cole sued her employer Group Health Plan, Inc. d/b/a HealthPartners in the United States District Court for the District of Minnesota, raising claims of religious discrimination under Title VII and the Minnesota Human Rights Act (MHRA). The district court granted HealthPartners’ motion to dismiss for failure to state a claim, and Cole appealed to the United States Court of Appeals for the Eighth Circuit.
Factual Overview:
Pamela Cole, a physical therapist and certified wound specialist, had worked for HealthPartners and its predecessor companies for 25 years with positive job performance feedback. In August 2021, HealthPartners implemented a COVID-19 vaccine mandate for all employees, allowing for religious and medical exemptions subject to certain conditions. These conditions included wearing medical-grade masks at all times in HealthPartners facilities, wearing additional personal protective equipment as needed, and agreeing to potential reassignment.
Cole, a member of the Eckankar religion, requested a religious accommodation to continue working unvaccinated as she had during the previous year and a half of the pandemic. HealthPartners granted her exemption from the vaccine but rejected her request to be exempt from the conditions. Vaccinated employees were given orange badge locks allowing them to remove masks in certain areas, which Cole alleged publicly indicated vaccination status and subjected unvaccinated employees to criticism and embarrassment.
Cole filed a charge of discrimination with the Equal Employment Opportunity Commission, obtained a right-to-sue letter, and subsequently filed this lawsuit alleging religious discrimination under Title VII and the MHRA.
Legal Analysis:
Disparate Treatment Claim: The court analyzed Cole’s allegations in the context of a disparate treatment claim, noting that a failure to accommodate is not a freestanding cause of action under Title VII. The court outlined the four elements of a prima facie case of religious discrimination:
- Membership in a protected class due to religious beliefs
- Meeting the employer’s legitimate expectations
- Suffering an adverse employment action
- Circumstances giving rise to an inference of discrimination
The court found that Cole adequately alleged the first two elements. Regarding the third element, the court noted that after the recent Supreme Court decision in Muldrow v. St. Louis, Cole only needed to plead “some harm respecting an identifiable term or condition of employment” rather than a “significant,” “material,” or “serious” injury. The court determined that Cole’s allegations of public identification of her vaccination status, resulting criticism from coworkers, and potential reassignment required further factual development to determine if they constituted an adverse action.
On the fourth element, the court found that Cole’s allegations plausibly raised an inference of discrimination, noting that failure to reasonably accommodate religious practices and singling out religious adherents for inequitable treatment can constitute religious discrimination under Title VII.
The court concluded that dismissal of the complaint at this stage was improper and that further factual development was necessary to determine the merits of Cole’s claims.
The Eighth Circuit reversed the district court’s grant of summary judgment and remanded the case for further proceedings consistent with its opinion.
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