Andrew v. Accenture Federal Services LLC, 1:25-cv-00089

Paytawn Andrew Erskine, a former employee of Accenture Federal Services LLC, was terminated after refusing to comply with a company-mandated COVID-19 vaccination policy, citing religious objections.
Erskine proceeded pro se and claimed he attempted to secure a religious accommodation from his employer, and that defendants accepted a purported "contract" outlining his terms by not objecting to it.
He brought several claims, including Title VII religious discrimination and retaliation, violations of customary international law, and various contract and equitable claims (breach, promissory estoppel, quantum meruit).
Defendants moved to dismiss all claims; Erskine moved for a preliminary injunction.
The court found that Erskine failed to exhaust his administrative remedies for Title VII claims, the international law claim was not cognizable, and the contract-based claims were implausible as there was no meeting of the minds or acceptance by silence.
The court granted the motion to dismiss with prejudice and denied the motion for preliminary injunction as moot.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Failure to accommodate under Title VII	Defendants did not engage in good-faith efforts to accommodate his religious beliefs; termination violated Title VII	Plaintiff failed to exhaust administrative remedies	Dismissed; exhaustion required and not met
Retaliation under Title VII	Termination was retaliation for seeking religious accommodation	No proper claim without exhaustion; no facts alleged	Dismissed for lack of exhaustion/time-barred
Breach of contract/implied contract	Defendants accepted terms of plaintiff's "contract" by not objecting	No contract ever formed; silence does not equal acceptance	Dismissed; no plausible contract formation
Preliminary injunction	Entitled to injunctive relief due to ongoing harm	No likelihood of success on the merits; case should be dismissed	Denied as moot and for failure on the merits

Ashcroft v. Iqbal, 556 U.S. 662 (2009) (sets out the plausibility standard for pleading in federal cases)
Bell Atl. Corp. v. Twombly, 550 U.S. 544 (2007) (explains need for plausible factual allegations in complaints)
Erickson v. Pardus, 551 U.S. 89 (2007) (civil rights complaints by pro se litigants must be liberally construed)
Winter v. Natural Resources Defense Council, 555 U.S. 7 (2008) (sets standard for granting preliminary injunctions)
Cochran v. Norkunas, 919 A.2d 700 (Md. 2007) (explains contract formation under Maryland law)
Int’l Bhd. of Teamsters v. Willis Corroon Corp. of Maryland, 802 A.2d 1050 (Md. 2002) (silence does not constitute acceptance of a contract offer)