Plaintiff Jamie Akers sued defendant AstraZeneca Pharmaceuticals, LP in the United States District Court for the Western District of Oklahoma raising claims of religious discrimination under Title VII of the Civil Rights Act of 1964 and the Oklahoma Anti-Discrimination Act. AstraZeneca moved to dismiss Akers’ claims under Rule 12(b)(6).
Factual Overview
Akers worked for AstraZeneca for approximately 15 years, most recently in sales. In January 2022, AstraZeneca announced that all employees would need to verify COVID-19 vaccination to remain employed. Employees qualifying for a medical or religious exemption could continue weekly testing instead. Akers applied for a religious exemption, stating that as a Catholic, she objected to using medications generated using aborted fetal cells and believed the vaccine would defile the sanctity of her body. She also noted distrust of the “experimental injection” and belief in her natural immunity. AstraZeneca rejected Akers’ request, citing undue hardship, but approved a similar request from a younger employee who did not belong to Akers’ church. AstraZeneca terminated Akers without severance on April 29, 2022, due to her refusal to receive the COVID-19 vaccination. Akers filed a Charge of Discrimination with the EEOC, which was dismissed, leading to this lawsuit.
Legal Analysis
Title VII Claim: The court analyzed whether Akers sufficiently pleaded a claim under Title VII. It examined the three elements of a prima facie failure-to-accommodate claim: a bona fide religious belief conflicting with a job requirement, informing the employer of the conflict, and termination for failing to comply with the job requirement.
Bona Fide Religious Belief: The court found that Akers’ objection was sufficiently tied to “ultimate ideas about life, purpose, and death” to constitute a bona fide religious belief. It determined that even if Akers’ objection was based on both religious and secular grounds, she alleged facts permitting a plausible inference that her objection was tied to religious observance, practice, or belief.
Informing the Employer: The court found that Akers adequately alleged she informed AstraZeneca about the conflict between her religious beliefs and the vaccination requirement through her timely application for a religious accommodation.
Termination for Non-Compliance: The court determined that Akers sufficiently alleged she was fired for failing to comply with AstraZeneca’s vaccination requirement after her accommodation request was rejected.
Oklahoma Anti-Discrimination Act (OADA) Claim: The court analyzed Akers’ OADA claim in line with her Title VII claim, noting the similarities between the statutes and previous court interpretations applying Title VII analysis to OADA claims. The court concluded that Akers stated a plausible claim for relief under the OADA for the same reasons it found she stated a claim under Title VII.
The court denied AstraZeneca’s motion to dismiss Akers’ claims under both Title VII and the OADA.
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