Ahmann v. Washington State Department of Transportation, 2:23-cv-00140

Background

Plaintiff, Paul Ahmann, was terminated from his Equipment Technician Lead position at the Washington State Department of Transportation (WSDOT) after refusing to receive a COVID-19 vaccine, citing religious reasons.
Washington’s Governor issued a proclamation requiring most state employees to be vaccinated unless medically or religiously exempted, with specific procedures for requesting exemptions.
Ahmann submitted a religious exemption form, stating opposition to vaccines developed with aborted fetal cell lines, but did not explicitly tie this objection to a specific religious tenet or mention his religion in his submission.
WSDOT denied his exemption request for insufficient information, gave him an opportunity to respond, but he did not supplement his submission.
Ahmann did not fully comply with WSDOT’s formal exemption request process, despite WSDOT’s clear procedures communicated to employees.
The court considered cross-motions for summary judgment by both parties and a motion to exclude an expert as moot.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Prima Facie Religious Accommodation under Title VII/WLAD	Ahmann argued he had a bona fide religious belief as a Catholic opposed to abortion, making vaccination objection based on use of fetal cell lines a protected belief.	WSDOT argued that Ahmann did not sufficiently notify the agency of how his religious beliefs conflicted specifically with the COVID-19 vaccine, and cited other non-religious reasons for his refusal.	Plaintiff had a sincerely held religious belief, but failed to adequately inform WSDOT of the religious connection/conflict with vaccination.
Adequate Notice to Employer	Claimed oral notice to supervisors (and a written form) should be enough to impute knowledge of conflict to employer.	WSDOT argued only formal written submissions per their communicated process counted, and oral/written notice to supervisors was insufficient under their policy.	Notice to supervisors irrelevant given WSDOT’s formal process; plaintiff's communications did not meet notification requirements.
Sufficiency of Exemption Request Content	Argued his statement about opposition to "baby parts" and reference to evil was adequate to link objection to religion.	WSDOT argued plaintiff’s form lacked explicit reference to religious tenets or explanation of belief’s connection to the vaccine, as required by policy.	Court found plaintiff's submission did not sufficiently connect his stated belief to a religious tenet.
Imputation of Notice/Accommodation Process	Ahmann argued that under state guidance and internal policies, any notice to a supervisor should trigger employer action.	WSDOT argued their policy required employees to submit formal requests to the HR-designated address, and internal/external guidance did not override this.	WSDOT’s internally communicated process controlled; no notice was imputed from informal conversations.

Key Cases Cited

Celotex Corp. v. Catrett, 477 U.S. 317 (1986) (sets the standard for summary judgment: movant must show absence of genuine material fact)
Anderson v. Liberty Lobby, Inc., 477 U.S. 242 (1986) (defines materiality and standard for genuine disputes in summary judgment)
Scott v. Harris, 550 U.S. 372 (2007) (facts and inferences in summary judgment must be viewed in light most favorable to non-movant)
Tiano v. Dillard Dep’t Stores, 139 F.3d 679 (9th Cir. 1998) (outlines elements of religious accommodation claim under Title VII)
Burwell v. Hobby Lobby Stores, Inc., 573 U.S. 682 (2014) (courts should not second-guess sincerity or reasonableness of religious beliefs)