765 F.Supp.3d 723
E.D. Tenn.2025Background
- Tanja Benton, a former employee of BlueCross BlueShield of Tennessee, Inc. (BCBST), sued her employer for failing to accommodate her religious objection to the company’s COVID-19 vaccine mandate.
- Benton claimed BCBST violated Title VII and the Tennessee Human Rights Act by not providing a reasonable accommodation for her sincere religious beliefs, which linked her opposition to the COVID-19 vaccine to her anti-abortion religious views.
- After the court denied summary judgment due to factual disputes over the sincerity of Benton's religious beliefs, the case proceeded to trial.
- The jury found in favor of Benton, awarding back pay, compensatory damages, and punitive damages—a total later reduced due to statutory caps.
- The court addressed several post-trial motions: BCBST’s renewed motion for judgment as a matter of law, a motion to amend the judgment to adhere to statutory damages caps, and Benton’s motions for attorney fees and prejudgment interest.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Benton’s objection to the vaccine was a sincerely held religious belief | Her Christian faith and anti-abortion beliefs motivated her refusal; she linked vaccine refusal to use of fetal cell lines | Her belief was not a comprehensive religious doctrine; previous vaccines were not opposed; lack of religious formalities | Court found sufficient evidence for a reasonable jury to find her beliefs sincere |
| Whether BCBST provided a reasonable accommodation | The job search period and lack of support made the accommodation unreasonable | Offered 30 days to find another position and designated her for rehire | Reasonableness is fact-specific; a jury could find BCBST's efforts insufficient under the circumstances |
| Whether accommodating Benton would have caused BCBST undue hardship | Remote work would not cause undue hardship; she was effective remotely, and clients did not demand in-person meetings | Accommodating her would cause administrative burdens, client issues, and undermine safety goals | Competing evidence; not appropriate for judgment as matter of law—jury could find for Benton |
| Entitlement to punitive damages | BCBST acted with reckless indifference by not considering individualized accommodations | BCBST’s motive was health/safety, not malice; believed statutory defense applied | Reasonable jury could find reckless indifference to rights; punitive damages allowed but subject to statutory cap |
Key Cases Cited
- Reeves v. Sanderson Plumbing Prods., Inc., 530 U.S. 133 (Rule 50 standard for judgment as a matter of law post-jury)
- Ansonia Bd. of Educ. v. Philbrook, 479 U.S. 60 (reasonableness of accommodation is case-specific and statutory inquiry ends if reasonable)
- Thomas v. Review Bd. of Ind. Emp’t Sec. Div., 450 U.S. 707 (religious belief need not be logical or consistent to merit protection)
- Kolstad v. ADA, 527 U.S. 526 (standard for award of punitive damages under Title VII)
- Groff v. DeJoy, 600 U.S. 447 (undue hardship requires substantial increased costs, not just de minimis)