Brooks v. Serta Simmons Bedding, LLC
4:22-cv-01203
E.D. Mo.Apr 14, 2025Background
- Joshua Brooks worked for Serta Simmons Bedding since 2014; in 2021, Serta implemented a COVID-19 vaccine mandate following federal guidance.
- Brooks, citing Christian religious beliefs related to the vaccine's use of fetal cell lines, requested a religious exemption to work remotely without vaccination.
- Serta placed Brooks on indefinite unpaid administrative leave, posted his position, and he was ultimately replaced.
- Brooks alleged that similarly situated colleagues in other divisions were allowed to work remotely without vaccination and that his supervisor displayed animus toward Christians refusing vaccination.
- He filed charges of religious discrimination and retaliation with the Missouri Commission on Human Rights (MCHR) and the EEOC, then sued in state court under the Missouri Human Rights Act (MHRA); Serta removed the case to federal court and sought dismissal.
- The case was stayed during Serta's bankruptcy proceedings, then resumed; Serta moved to dismiss for failure to exhaust remedies and failure to state a claim.
Issues
| Issue | Brooks' Argument | Serta's Argument | Held |
|---|---|---|---|
| Exhaustion of Administrative Remedies (Count I) | His MCHR charge sufficiently notified of constructive discharge claim | Did not properly exhaust because his charge did not allege constructive discharge | Sufficiently exhausted; claim can proceed |
| Failure to Accommodate—Plausible Allegations | Stated a plausible claim: denied same accommodation as others, faced adverse action | Did not plead similarly situated comparators or sufficient facts | Sufficient to survive dismissal; claim proceeds |
| Retaliation—Protected Activity | Accommodation request and later MCHR filing were protected; Serta retaliated | Only MCHR charge, not request, is protected; no adverse action followed protected act | Request not protected activity; no retaliation shown; claim dismissed |
| Constructive Discharge Allegation | Indefinite unpaid leave and posting of position amounted to constructive discharge | No explicit resignation or discharge alleged; administrative failure | Constructive discharge plausibly alleged |
Key Cases Cited
- Ashcroft v. Iqbal, 556 U.S. 662 (pleading standard for facial plausibility of claims)
- Bell Atlantic Corp. v. Twombly, 550 U.S. 554 (pleading standard under Rule 12(b)(6))
- Jones v. TEK Industries, Inc., 319 F.3d 355 (elements of religious accommodation under federal law)
- McClure v. Career Sys. Dev. Corp., 447 F.3d 1133 (unpaid suspension as adverse employment action)