Hampton-Davis v. Froedtert Health Inc
2:22-cv-01437
E.D. Wis.Jul 15, 2024Background
- Plaintiff, Heidi Hampton-Davis, was employed by Froedtert Health as a Gift Shop Coordinator.
- Froedtert implemented a COVID-19 vaccine mandate for all employees, permitting medical and religious exemptions.
- Hampton-Davis was initially granted a permanent medical exemption, which was later revoked due to updated CDC guidance.
- She then requested a religious exemption based on her Christian belief in the sanctity of life, citing opposition to vaccines developed using fetal cell lines.
- Froedtert denied her religious exemption due to a missed deadline for such requests, and subsequently terminated her for noncompliance with the vaccine policy.
- Hampton-Davis filed a lawsuit under Title VII, alleging religious discrimination; Froedtert moved for summary judgment.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the plaintiff's objection is religious | Holds sincere religious belief against vaccines developed with fetal cell lines | Objection is a personal medical preference, not religious | Sufficiently states a religious belief |
| Sincerity of the religious belief | Sincerity supported by immediate application after medical exemption revoked | Sincerity questioned given timing and lack of past consistency | Sincerity is a fact issue for trial |
| Motivating factor for termination | Religious belief was a basis for her termination | Terminated due to noncompliance with policy and missed exemption deadline | Unclear on this record, issue goes to trial |
| Whether accommodation would impose undue burden | No greater burden than for other employees with exemptions | Additional religious exemptions post-deadline impose undue hardship | Undue hardship not shown on this record |
Key Cases Cited
- Anderson v. Liberty Lobby, Inc., 477 U.S. 242 (summary judgment standard)
- Celotex Corp. v. Catrett, 477 U.S. 317 (party moving for summary judgment must show no genuine issue of material fact)
- Adeyeye v. Heartland Sweeteners, LLC, 721 F.3d 444 (test for what constitutes a religious belief under Title VII)
- United States v. Seeger, 380 U.S. 163 (test for sincerity and validity of religious belief)
- Groff v. DeJoy, 600 U.S. 447 (new undue hardship standard for religious accommodations under Title VII)
- EEOC v. Abercrombie & Fitch Stores, Inc., 575 U.S. 768 (employer's motive to avoid accommodation can violate Title VII)