784 F.Supp.3d 1191
D. Minn.2025Background
- The Federal Reserve Bank of Minneapolis required COVID-19 vaccination for all employees, allowing for medical and religious exemptions.
- Rodney Maki, a law enforcement officer and practicing Catholic, requested a religious exemption based on opposition to vaccines connected to fetal cell lines derived from abortions.
- Maki was temporarily accommodated but later had his exemption revoked, and was terminated for non-compliance in January 2022.
- Maki sued the Bank under Title VII of the Civil Rights Act for religious discrimination and under the Religious Freedom Restoration Act (RFRA).
- Both parties filed cross-motions for summary judgment and sought to exclude parts of each other's expert testimony.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Title VII: Undue Hardship & Accommodation | Accommodation would not impose undue hardship; alternatives feasible | Accommodation would cause undue hardship due to job requirements, health risks | Genuine issues of fact preclude summary judgment for both sides |
| Title VII: Sincerity of Religious Belief | Religious objection is bona fide and rooted in Catholic faith | Maki's sincerity is questionable due to statements and prior conduct | Sincerity is a credibility issue for the jury; summary judgment denied |
| RFRA: Applicability to Employment Claims | Bank is not a federal agency for Title VII exclusivity, RFRA applies | Eighth Circuit bars RFRA claims where Title VII applies as exclusive remedy | RFRA claim barred by controlling precedent; summary judgment for Bank |
| Exclusion of Expert Testimony | Defendant's experts are irrelevant/unqualified; exclude all | Plaintiff's experts opine outside expertise or on legal issues; exclude portions | Cross-examinable issues remain; most expert testimony admitted; partial exclusions |
Key Cases Cited
- Groff v. DeJoy, 600 U.S. 447 (2023) (clarified the "undue hardship" standard for Title VII religious accommodation)
- Brown v. Gen. Servs. Admin., 425 U.S. 820 (1976) (Title VII is exclusive remedy for federal employee discrimination claims)
- Harrell v. Donahue, 638 F.3d 975 (8th Cir. 2011) (RFRA does not provide additional remedies for federal employment discrimination)
- Trans World Airlines, Inc. v. Hardison, 432 U.S. 63 (1977) (original, more lenient "undue hardship" standard under Title VII)
- Cooper v. Federal Reserve Bank of Richmond, 467 U.S. 867 (1984) (Federal Reserve Banks as private employers under Title VII)
- Thomas v. Review Board of Indiana Employment Security Division, 450 U.S. 707 (1981) (courts may not question validity, only sincerity, of religious beliefs)
- Anderson v. Liberty Lobby, Inc., 477 U.S. 242 (1986) (summary judgment standards)