Aimee Sturgill v. Am. Red Cross, 114 F.4th 803

Plaintiff Aimee Sturgill, a devout Christian and nurse, objected to the American Red Cross’s COVID-19 vaccine mandate on religious grounds, requesting a religious accommodation.
The Red Cross denied her accommodation request, concluding her objection was medically, not religiously, motivated, and terminated her employment after she refused the vaccine.
Sturgill filed suit under Title VII, alleging the Red Cross failed to accommodate her sincerely held religious beliefs.
The district court dismissed her complaint under Rule 12(b)(6), holding she did not plausibly allege the prima facie elements of a religious-accommodation claim and did not assert a disparate-treatment claim.
On appeal, the Sixth Circuit reviewed whether the complaint plausibly stated a failure to accommodate claim and whether it included a disparate-treatment claim.
The court accepted as true all factual allegations in the complaint and attached documents, as required at the motion-to-dismiss stage.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of pleading for failure-to-accommodate	Sturgill’s complaint plausibly alleges a sincere religious conflict with vaccine	She failed to allege a sincere religious belief, only medical objections	Complaint plausibly alleges failure to accommodate; dismissal reversed
Requirement for prima facie case at pleading	Not required at motion-to-dismiss stage	Necessary to state a claim under Title VII	Pleading a prima facie case is not a requirement at the 12(b)(6) stage
Whether religious objection was only medical	Religious beliefs are linked to her Christian faith and practices	Objection is actually medical due to blood disorder and vaccine safety	Both religious and secular reasoning can coexist; plausibly religious
Existence of disparate-treatment claim	Complaint includes disparate-treatment based on religious beliefs	Only pleaded failure-to-accommodate; no general disparate-treatment claim	Complaint sets out only failure-to-accommodate, not disparate-treatment

Bell Atl. Corp. v. Twombly, 550 U.S. 544 (plausibility pleading standard for Rule 12(b)(6) motions)
Ashcroft v. Iqbal, 556 U.S. 662 (clarifying the plausibility standard for pleadings)
Swierkiewicz v. Sorema N.A., 534 U.S. 506 (prima facie case not a pleading requirement)
Trans World Airlines, Inc. v. Hardison, 432 U.S. 63 (employer duty to accommodate religious observance under Title VII)
Thomas v. Review Bd. of Ind. Emp. Sec. Div., 450 U.S. 707 (protection of sincerely held religious beliefs under the First Amendment)
EEOC v. Abercrombie & Fitch Stores, Inc., 575 U.S. 768 (failure-to-accommodate can fall under disparate-treatment framework)