Fallon v. Mercy Catholic Medical Center of Southeastern Pennsylvania
877 F.3d 487
| 3rd Cir. | 2017Background
- Paul Fallon, employed by Mercy Catholic since 1994, refused the employer's mandatory influenza vaccination in 2014 and sought a religious exemption; Mercy Catholic required vaccines unless a medical or religious exemption was granted and asked exempt employees to wear masks.
- Fallon had previously received exemptions in 2012–2013 after submitting a lengthy personal essay; in 2014 Mercy Catholic tightened its exemption standard and requested a clergyperson's letter, which Fallon could not provide.
- Mercy Catholic denied Fallon’s 2014 religious-exemption request; Fallon was suspended and terminated on December 31, 2014, for noncompliance.
- Fallon sued under Title VII alleging religious discrimination and failure to accommodate; Mercy Catholic moved to dismiss, attaching the full 22-page essay Fallon had previously submitted.
- The District Court considered the full essay (as integral to the complaint), concluded Fallon’s beliefs were sincere but not religious under Title VII, and dismissed with prejudice as amendment would be futile.
- Fallon appealed; the Third Circuit affirmed, holding his anti-vaccine views were medical/philosophical, not religious, and that the District Court permissibly considered the attached essay and did not abuse its discretion in denying leave to amend.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Fallon’s anti-vaccination beliefs qualify as "religion" under Title VII | Fallon: his sincerely held moral/ethical convictions opposing vaccines are religious and occupy the same place as traditional religious beliefs | Mercy Catholic: beliefs are secular/medical/philosophical, not a comprehensive religious system, so not protected | Held: Not religious; beliefs are medical/philosophical and fail the Africa factors, so no Title VII protection |
| Whether the District Court could consider the full essay attached to defendant's reply on a motion to dismiss | Fallon: only the quoted portions in the complaint are proper; full essay is extrinsic and should not be considered on 12(b)(6) | Mercy Catholic: essay is integral to and explicitly relied upon by the complaint; court may consider it | Held: Court properly considered the essay as integral to the complaint |
| Whether dismissal should have been without prejudice (or plaintiff should get leave to amend) | Fallon: should be granted leave to amend; dismissal with prejudice was premature | Mercy Catholic: amendment would be futile because fundamental deficiency is non-religious nature of beliefs | Held: Denial of leave not abuse of discretion; amendment would be futile, so dismissal with prejudice appropriate |
| Standard for determining "religion" under Title VII | Fallon: cites regulation equating moral/ethical beliefs to religion if sincerely held | Mercy Catholic: standard requires the Seeger/Welsh/Africa analysis showing comprehensive, ultimate-questions focus and external signs | Held: Court applies Seeger/Welsh test and Africa factors; Fallon’s beliefs fail to meet them |
Key Cases Cited
- United States v. Seeger, 380 U.S. 163 (set standard for whether nontraditional beliefs are "religious" by asking if they occupy the same place as belief in God)
- Welsh v. United States, 398 U.S. 333 (held nontheistic beliefs can qualify as religious under Seeger standard)
- Malnak v. Yogi, 592 F.2d 197 (proposed modern definition of religion emphasizing comprehensiveness and formal signs)
- Africa v. Commonwealth of Pennsylvania, 662 F.2d 1025 (adopted Africa factors: ultimate questions, comprehensive belief system, external signs)
- Burlington Coat Factory Sec. Litig., 114 F.3d 1410 (court may consider documents integral to complaint on a motion to dismiss)
- Fowler v. UPMC Shadyside, 578 F.3d 203 (standard of review for motions to dismiss)
- Burwell v. Hobby Lobby Stores, Inc., 134 S. Ct. 2751 (courts should not question validity of religious beliefs)
- Mason v. Gen. Brown Cent. Sch. Dist., 851 F.2d 47 (anti-vaccination beliefs held to be secular/scientific, not religious)