Multiple plaintiffs sued defendant Honeywell Federal Manufacturing & Technologies, LLC (“FM&T”) in the United States District Court for the Western District of Missouri, raising claims of religious discrimination under Title VII based on FM&T’s COVID-19 vaccination mandate and religious exemption policies. FM&T moved to dismiss plaintiffs’ second amended complaint under Rule 12(b)(6).
Factual Overview
In May 2021, FM&T implemented a company-wide COVID-19 vaccine mandate. The mandate required different colored badge holders for vaccinated and unvaccinated employees, with vaccinated employees wearing green badges. FM&T also required unvaccinated employees to wear masks, maintain social distance, and undergo weekly COVID-19 testing. Employees who failed to comply with testing requirements could be placed on unpaid leave and ultimately terminated.
FM&T allowed employees to request religious exemptions from the vaccine mandate. The plaintiffs, who held religious beliefs opposing vaccination, requested and received religious exemptions but were subject to the alternative requirements for unvaccinated employees. The plaintiffs complained to FM&T about both the vaccine mandate and the exemption conditions, alleging they constituted religious discrimination. Some plaintiffs were allegedly constructively discharged or denied promotions.
Legal Analysis
Religious Discrimination – Failure to Accommodate:
The court analyzed whether plaintiffs adequately alleged adverse employment actions under the Supreme Court’s recently relaxed standard in Muldrow v. City of St. Louis. Following Eighth Circuit precedent in Cole v. Group Health Plan, Inc., the court found that requirements like wearing different colored badges, mandatory testing, and potential unpaid leave could constitute adverse employment actions. The court rejected FM&T’s argument that these conditions resulted from vaccination status rather than religious status.
Religious Discrimination – Retaliation: The court dismissed plaintiffs’ retaliation claims due to causation issues. Because FM&T implemented its vaccine mandate and exemption conditions before plaintiffs engaged in protected activity (complaining about religious discrimination), the court found plaintiffs could not establish that their protected activity caused the alleged adverse actions.
Class Allegations: The court declined to dismiss class allegations at the pleading stage, finding that potential issues with class definition and certification requirements could be addressed during discovery and class certification proceedings.
The court denied FM&T’s motion to dismiss the religious discrimination failure-to-accommodate claim, granted the motion to dismiss the retaliation claim, and denied the motion to dismiss the class allegations.
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