Cases & Developments

Order granting Defendant’s Motion to Dismiss. Plaintiff, a former medical student employed by Washington State University and completing a residency at Providence Regional Medical Center, brought discrimination claims against the University after it declined to grant him a religious exemption to its COVID-19 vaccination requirement and terminated him, even though the Center had granted the exemption. In granting the University’s Motion to Dismiss, the court held that (1) plaintiff’s allegations were conclusory because he alleged no facts as to the nature of his sincerely held religious belief or when or how he had requested the exemption from the University and (2) the University successfully asserted undue hardship because permitting plaintiff to work in a hospital without a vaccination posed an increased risk to patients of COVID-19 exposure. 

Memorandum Opinion grating Defendant’s Motion to Dismiss. Plaintiff, a former budget analyst at Princeton University who had been granted a religious exemption to the University’s COVID-19 vaccination requirement, brought discrimination and retaliation claims against the University after it denied her second request for a religious exemption to its masking, testing, and contract tracing policies and terminated her shortly thereafter. The court dismissed her religious discrimination claims for failure to identify a religious practice that prevented her from complying with the policies. It dismissed her retaliation claims, holding that because she had not alleged a sincerely held religious belief, she was unable to show that she had opposed an unlawful denial of a religious accommodation. Finally, it dismissed her Genetic Information Nondiscrimination Act (GINA) claim because she failed to show that saliva samples collected were used for any purpose other than COVID-19 testing.