713 F.Supp.3d 1231
M.D. Fla.2024Background
- Plaintiff Courtney Scafidi worked as a Senior Hospital Account Manager for B. Braun Medical, a supplier of IV therapy products, and her role required in-person sales visits to hospitals.
- Due to the COVID-19 pandemic, many hospitals and then B. Braun imposed vaccination requirements for vendors entering patient-care settings; some hospitals allowed for religious exemptions, but policies varied.
- In September 2021, B. Braun implemented a policy requiring customer-facing employees to be fully vaccinated by November 1, 2021, allowing for the possibility of exemptions.
- Scafidi, a practicing Christian, requested a religious exemption based on her conscience guided by the Holy Spirit, but her exemption was denied, and she was terminated for noncompliance with the vaccine mandate.
- Scafidi did not apply for any non-customer-facing positions (which were not available in her area) and instead sought to maintain her current role without vaccination—or have a new position created.
- The case comes on cross-motions for summary judgment after Scafidi brought claims for religious discrimination and retaliation under Title VII and the Florida Civil Rights Act (FCRA); she later abandoned her retaliation claims.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Retaliation claims (Counts II & IV) | No longer pursued; abandoned in summary judgment briefing | Argues no causation; termination was for policy noncompliance, not request | Summary judgment for defendant; claims abandoned |
| Religious Discrimination—Religious Belief | Scafidi claims sincere, religious conflict based on conscience and Holy Spirit guidance | Braun says objections are personal/scientific, not religious | Genuine dispute; fact question for jury |
| Reasonable Accommodation | Scafidi argues reasonable accommodation not offered, as positions weren’t comparable or local | Braun says it offered alternative positions not subject to mandate | Genuine dispute; fact question for jury |
| Undue Hardship | Scafidi says no specific hardship proven, no evidence of denied hospital access or cost analysis | Braun claims significant administrative burden and disruption to territories | Genuine dispute; fact question for jury |
Key Cases Cited
- Anderson v. Liberty Lobby, Inc., 477 U.S. 242 (summary judgment standard—genuine issue of material fact required)
- Celotex Corp. v. Catrett, 477 U.S. 317 (summary judgment burden)
- Wisconsin v. Yoder, 406 U.S. 205 (distinguishing religious belief from personal choice in legal accommodation context)