696 F.Supp.3d 572
D. Minn.2023Background
- Three Seasons Hospice employees (Lee, Robsahm, Moen) were terminated after refusing Seasons’ COVID‑19 vaccine mandate despite prior positive performance reviews.
- Plaintiffs cited religious objections (vaccination would “defile” the body; objections to use of fetal‑line cell materials) and medical concerns (history of adverse vaccine reactions, autoimmune issues, cancer in remission).
- Seasons initially encouraged vaccination but on Sept. 8, 2021 adopted a mandatory vaccine policy with an explicit statement that there would be “no medical, religious or personal exemptions,” citing patient safety, anticipated CMS requirements, and a business partner.
- Plaintiffs informed Seasons of their religious beliefs and medical concerns, continued working unvaccinated under prior practices, were denied exemptions, filed EEOC charges, and sued asserting Title VII, MHRA, ADA, and (later withdrawn) contract/estoppel claims.
- On motions to dismiss, the court: denied dismissal of Title VII religious‐accommodation claims; held MHRA claims plausibly require accommodation and survive; dismissed ADA medical‑inquiry claims with prejudice; dismissed Moen’s ADA claim without prejudice for failure to exhaust; and allowed Lee’s and Robsahm’s ADA failure‑to‑accommodate claims to proceed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Title VII — duty to accommodate religion / undue hardship | Plaintiffs sought religious exemptions and allege the pre‑mandate status quo (masking, distancing) worked. | Seasons says accommodation would cause undue hardship (CMS rule, infection risk, partner requirements, reputational harm). | Denied dismissal. CMS rule permitted exemptions; undue‑hardship is fact‑intensive under Groff and cannot be resolved at pleading stage. |
| MHRA — does it impose a duty to accommodate religion? | MHRA should be interpreted like Title VII to require reasonable accommodation. | Seasons contends MHRA does not impose such a duty (no textual accommodation provision for religion). | Court predicts Minnesota Supreme Court would require religious accommodation like Title VII; MHRA claims survive. |
| ADA — medical‑inquiry prohibition ( §12112(d)(4) ) | Plaintiffs say vaccine‑status inquiries risk revealing long COVID (a disability) and thus violate the ADA’s medical‑inquiry ban. | Seasons says asking vaccination status is not a disability inquiry. | Dismissed with prejudice: vaccination status is not a disability‑related inquiry; EEOC guidance supports dismissal. |
| ADA — administrative exhaustion (Moen) | Moen argues her ADA claim is reasonably related to her EEOC charge alleging religious discrimination. | Seasons notes Moen’s EEOC charge listed only religion and did not mention medical/disability issues. | Dismissed without prejudice for Moen: EEOC charge did not give notice of disability claim; exhaustion required. |
| ADA — failure to accommodate disability | Plaintiffs allege medical exemptions were denied and reasonable accommodations (status quo measures) were feasible. | Seasons argues accommodation would impose undue hardship (safety, federal compliance, partner obligations). | Denied dismissal for Lee and Robsahm: plaintiffs plausibly pleaded disabilities/need for accommodation and employer must show undue hardship with factual record. |
Key Cases Cited
- Bell Atl. Corp. v. Twombly, 550 U.S. 544 (pleading must be plausible)
- Ashcroft v. Iqbal, 556 U.S. 662 (factual allegations accepted and reasonable inferences drawn)
- Groff v. DeJoy, 600 U.S. 447 (undue hardship requires substantial increased costs; fact‑intensive inquiry)
- Trans World Airlines, Inc. v. Hardison, 432 U.S. 63 (earlier standard treating de minimis cost as undue hardship)
- Biden v. Missouri, 142 S. Ct. 647 (CMS vaccination rule permitted medical and religious exemptions)
- U.S. Airways, Inc. v. Barnett, 535 U.S. 391 (employer must show special/case‑specific circumstances to establish undue hardship)
- Sigurdson v. Isanti Cnty., 386 N.W.2d 715 (Minnesota courts often interpret MHRA consistent with Title VII)
- Seaworth v. Pearson, 203 F.3d 1056 (8th Cir. precedent discussing undue hardship in religious‑accommodation context)