Matos v. Discovery Communications, LLC

Background

Anddy Matos sued Discovery Communications, LLC, now known as Warner Bros. Discovery, Inc., alleging religious discrimination and retaliation under Title VII of the Civil Rights Act of 1964, New York Executive Law § 296, and the New York City Human Rights Law. Discovery moved to dismiss under Federal Rule of Civil Procedure 12(b)(6), which tests whether a complaint states a legally sufficient claim.

Matos alleged that she was a Christian and that her religious beliefs prevented her from receiving a COVID-19 vaccine. Discovery announced that all U.S. employees had to be vaccinated by January 1, 2022, or qualify for a religious or medical exemption as a condition of continued employment. Matos requested a religious exemption and permission to work remotely. Discovery denied both requests, and Matos alleged that Discovery terminated her effective January 1, 2022. She also alleged that Discovery opposed her application for unemployment benefits by stating that she had voluntarily resigned.

Materials Considered

The court considered several documents referenced in or incorporated into the amended complaint, including Discovery's vaccination announcements, Matos's exemption request, New York City guidance, and letters denying her exemption and remote-work requests. The court treated the complaint's factual allegations as true for purposes of the motion.

Vaccination Requirement

The court held that Discovery's vaccination requirement applied to all employees, including Matos, and that nothing in Discovery's earlier communications created an exception for remote employees. The court also stated that the requirement was facially neutral and generally applicable. Matos did not identify similarly situated employees who were allowed to remain unvaccinated without an exemption.

Religious-Discrimination Claim

Title VII requires an employer to reasonably accommodate an employee's religious beliefs unless the accommodation would cause an undue hardship. At the pleading stage, a plaintiff must allege a sincerely held belief that is religious in nature, that the belief conflicts with an employment requirement, that the employer was informed of the belief, and that the plaintiff was disciplined for refusing to comply.

The court accepted, for purposes of the motion, that Matos sincerely held her stated beliefs and that she alleged a conflict between those beliefs and vaccination. Matos alleged that her body was an extension of God's temple and that vaccination would tarnish or defile it. But the court found that she did not adequately allege why her objection to vaccination itself was based on religious convictions. The court distinguished a religious belief from a personal, medical, secular, or scientific objection and concluded that Matos's allegations did not plausibly connect her vaccination objection to religion. The court therefore dismissed her Title VII discrimination claim.

The court did not decide that Matos's beliefs were insincere. It stated that sincerity generally is not appropriate for resolution on a motion to dismiss and that the complaint's deficiency was the lack of sufficient allegations showing a religious basis for the objection.

Retaliation Claims

Matos alleged that Discovery retaliated against her in two ways: by terminating her after she requested a religious exemption and by opposing her unemployment-benefits application.

The court dismissed the termination-based theory because Discovery adopted the vaccination requirement before Matos requested the exemption. According to the court, her termination for failing to comply with the preexisting policy therefore did not plausibly show that the termination was caused by her protected activity.

The court also dismissed the unemployment-benefits theory because Matos did not respond to Discovery's argument that this claim should be dismissed. The court stated that the Title VII retaliation claims were dismissed without prejudice.

State and City Claims

Because the court dismissed the federal claims, it declined to exercise supplemental jurisdiction over Matos's claims under New York law and the New York City Human Rights Law. The opinion does not state a separate dismissal-with-prejudice or dismissal-without-prejudice disposition for those claims.

Disposition

The court granted Discovery's motion to dismiss. It allowed Matos 30 days to file a second amended complaint alleging additional facts supporting her Title VII discrimination and retaliation claims. The new complaint must replace, rather than supplement, the existing complaint. The court warned that claims already dismissed could be dismissed with prejudice if Matos did not meet the deadline. The Clerk was directed to terminate Discovery's pending motion.