Hunt v. Sunrise Operations LLC

Background

Andrew Hunt served as chief engineer for an old steamship owned and operated by Sunrise Operations LLC and The Pasha Group. Hunt alleges that he is an Orthodox Christian and that the defendants refused to accommodate his religious objection to receiving the COVID-19 vaccine, resulting in his termination.

Hunt asserted religious-discrimination claims under Title VII of the Civil Rights Act of 1964, a federal employment-discrimination law, and California’s Fair Employment and Housing Act. MEBA moved to dismiss the claims against it under Federal Rule of Civil Procedure 12(b)(6), which requires dismissal when a complaint does not state a legally sufficient claim for relief. This was MEBA’s renewed motion directed at Hunt’s Third Amended Complaint. Sunrise and Pasha had answered that complaint.

Court’s Analysis

For purposes of the motion, the court accepted the complaint’s factual allegations as true and drew reasonable inferences in Hunt’s favor. The court had previously dismissed claims against MEBA from an earlier amended complaint because the allegations did not clearly identify what each defendant allegedly did. The court had allowed Hunt to amend.

The court found that the Third Amended Complaint cured those earlier problems. It alleged that MEBA’s attorney expressed doubt about the sincerity of Hunt’s religious beliefs and took a hostile and oppositional position toward his accommodation request. It also alleged that Sunrise denied the request in a letter and at two meetings attended by MEBA, where a Sunrise representative allegedly said that accommodations would not be provided to anyone.

The complaint further alleged that MEBA and Sunrise were jointly responsible for evaluating or handling religious-accommodation requests under a written agreement between the union and employer. That agreement stated that religious-exemption requests would be handled between the union and company on a case-by-case basis.

The court held that these allegations plausibly supported a theory that MEBA acquiesced in or joined Sunrise’s alleged discriminatory conduct. The court rejected MEBA’s arguments that Hunt had not alleged that the union treated him less favorably than others because of his religion and that MEBA lacked authority to override Sunrise’s decision. The court explained that those arguments focused on a different theory of direct discrimination and that MEBA’s ultimate decision-making authority was not the issue under Hunt’s acquiescence theory.

Disposition

The court denied MEBA’s motion to dismiss the claims against it from the Third Amended Complaint. The order addressed whether Hunt’s allegations were sufficient to proceed past the pleading stage; it did not determine ultimate liability or whether the alleged discrimination occurred.