Frank Savel v. MetroHealth Sys., 96 F.4th 932

MetroHealth, an Ohio hospital, implemented a COVID-19 vaccine mandate in August 2021, initially allowing for both medical and religious exemption requests.
The hospital granted some medical exemptions but categorically denied all religious exemption requests in February 2022, later reversing course and granting all such requests in March 2022.
Frank Savel and 45 other employees (some current, some resigned) sued MetroHealth for religious discrimination under Title VII and Ohio Revised Code § 4112, alleging failure to accommodate and disparate treatment.
The district court dismissed the claims, holding that current employees (Plaintiffs 10–46) lacked standing and that former employees (Plaintiffs 1–9) failed to state claims; only constructive discharge (forced resignation) could confer standing on resigning plaintiffs.
On appeal, the Sixth Circuit divided the plaintiffs, finding only Plaintiffs 1 and 2 plausibly alleged constructive discharge after denial of religious exemptions and before the hospital's policy change, sufficient for standing and an actionable claim under Title VII and § 4112.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Standing - Current Employees	Mental anguish and prospect of future denial is injury	No concrete or imminent injury alleged; only speculation	No standing; allegations too conclusory/speculative
Standing - Former Employees	Forced resignation = constructive discharge after denials	Resignations were voluntary; not forced by MetroHealth	Only Plaintiffs 1&2 plausibly alleged compulsion
Failure to Accommodate Claim	MetroHealth failed to provide religious accommodation	Allegations insufficient; no plausible constructive discharge	Plaintiffs 1&2 pleaded enough under Title VII
Disparate Treatment Claim	MetroHealth treated religious requests differently than medical	No plausible disparate treatment; same as above	Plaintiffs 1&2 pleaded enough under Title VII

Ashcroft v. Iqbal, 556 U.S. 662 (2009) (sets the plausibility standard for pleading)
Bell Atl. Corp. v. Twombly, 550 U.S. 544 (2007) (establishes pleading standards)
Green v. Brennan, 578 U.S. 547 (2016) (defines constructive discharge)
Trans World Airlines, Inc. v. Hardison, 432 U.S. 63 (1977) (Title VII religious accommodation standard)
Swierkiewicz v. Sorema N.A., 534 U.S. 506 (2002) (prima facie case not a pleading requirement)
Penn. State Police v. Suders, 542 U.S. 129 (2004) (clarifies constructive discharge in employment law)
Spokeo, Inc. v. Robins, 578 U.S. 330 (2016) (standing requirements)