Elliott v. Shriners Hospitals for Children
5:22-cv-06236
W.D. La.Mar 11, 2025Background
- Plaintiffs Elliott and Furrow were employed in healthcare roles at Shriners Hospital in Shreveport, Louisiana.
- In September 2021, Shriners implemented a mandatory COVID-19 vaccine policy, permitting employees to request medical or religious exemptions.
- Plaintiffs sought religious exemptions, detailing faith-based objections and referencing specific religious beliefs and scripture, but their requests were denied.
- The hospital claimed that accommodating the exemptions would pose an undue hardship by threatening the health of vulnerable patients.
- Plaintiffs were terminated after their exemption requests were denied, while alleging that other employees received exemptions and were not terminated.
- Plaintiffs sued for religious discrimination (failure to accommodate, disparate treatment) under Title VII; Shriners moved to dismiss for failure to state a claim.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Adequacy of Religious Beliefs | Objections grounded in sincerely held and articulated religious beliefs | Alleged beliefs were vague/personal preferences, not bona fide religious beliefs | Plaintiffs plausibly alleged bona fide religious beliefs |
| Conflict with Employment Policy | Religious beliefs directly conflicted with vaccine mandate | Plaintiffs did not adequately allege conflict with employment requirement | Plaintiffs sufficiently alleged conflict |
| Employer Notice | Submitted written exemption requests outlining their beliefs to Shriners | Plaintiffs did not specifically inform Shriners of conflicting religious beliefs | Court found sufficient notice to Shriners |
| Undue Hardship | No facts at this stage establish granting exemption would be an undue hardship | Granting exemptions would be an undue hardship for a children’s healthcare setting | Factual questions remain; not grounds for dismissal |
| Disparate Treatment | Others granted exemptions; only Plaintiffs were terminated | Plaintiffs failed to allege protected class status or favorable treatment to others | Allegations support plausible inference of discrimination |
Key Cases Cited
- Ashcroft v. Iqbal, 556 U.S. 662 (2009) (establishing plausibility pleading standard for motions to dismiss)
- Bell Atl. Corp. v. Twombly, 550 U.S. 544 (2007) (establishing standard for plausibility in pleadings)
- Davis v. Fort Bend Cnty., 765 F.3d 480 (5th Cir. 2014) (Title VII religious accommodation burden-shifting framework)
- United States v. Seeger, 380 U.S. 163 (1965) (test for what constitutes a religious belief under federal law)
- Wisconsin v. Yoder, 406 U.S. 205 (1972) (scope of protected religious beliefs versus secular convictions)
- Raj v. La. State University, 714 F.3d 322 (5th Cir. 2013) (pleading standard for disparate treatment claims)