Zajonc v. T-Mobile US, Inc.
- Jacquelyn Corley
- 3:25-cv-02860
- U.S. District Court · Northern District of California
- 4
In Zajonc v. T-Mobile, Judge Corley granted T-Mobile’s motion on FEHA and UCL claims and dismissed the wrongful-termination claim without leave to amend.
Paula Zajonc and T-Mobile US, Inc.; the ruling also affected the proposed class claims because the FEHA and UCL allegations were dismissed with leave to amend.
What happened
In Zajonc v. T-Mobile US, Inc., Paula Zajonc challenged T-Mobile’s denial of her request for a religious exemption from its COVID-19 vaccination requirement. She brought claims under California’s Fair Employment and Housing Act, the Unfair Competition Law, and a public-policy wrongful-termination theory.
The court found that Zajonc did not provide enough facts about her religious belief, the exemption she requested, or T-Mobile’s denial to support the discrimination claim. It also found that her Unfair Competition Law allegations merely repeated legal conclusions and did not adequately identify the unlawful, unfair, or allegedly fraudulent conduct.
Judge Corley granted T-Mobile’s motion to dismiss the Fair Employment and Housing Act and Unfair Competition Law claims with leave to amend. The court dismissed the wrongful-termination claim without leave to amend and set June 26, 2025, as the deadline for an amended complaint.
The detailed version
- Zajonc v. T-Mobile US, Inc. · No. 3:25-cv-02860
- Jacquelyn Corley
- June 2, 2025
Background
Paula Zajonc filed a proposed class action in Alameda County Superior Court challenging T-Mobile’s denial of a religious exemption from its COVID-19 vaccine requirement. She asserted claims under California’s Fair Employment and Housing Act (FEHA), California’s Unfair Competition Law (UCL), and for wrongful termination in violation of public policy. T-Mobile removed the case to federal court based on diversity jurisdiction and moved to dismiss for failure to state a claim.
Court’s analysis
The court held that Zajonc’s FEHA religious-discrimination claim was inadequately pleaded. A plaintiff bringing this type of claim must allege, among other things, a genuine religious belief that conflicts with an employment requirement. Zajonc alleged that she applied for a religious COVID-19 exemption, that T-Mobile denied it under a policy applying to class members, and that her religious beliefs prevented her from taking the vaccine. The court found that she did not allege supporting facts about her religious belief, the exemption she requested, or T-Mobile’s denial. The FEHA claim therefore failed to state a claim.
The court also rejected each basis for Zajonc’s UCL claim. Her unlawful-practices theory depended on the alleged FEHA violation, so it failed because the FEHA claim failed. Her unfair-practices allegations were conclusory and did not adequately explain why the conduct was unfair under the governing standard. Her fraudulent-practices allegations asserted that T-Mobile falsely indicated it would provide exemptions but did not identify the allegedly false statements. The court concluded that both the FEHA and UCL claims required more factual detail than a recitation of statutory language.
The opinion states that Zajonc did not oppose dismissal of the wrongful-termination claim or the request to strike certain language in that claim.
Ruling
Judge Corley vacated the scheduled hearing and granted T-Mobile’s motion to dismiss with leave to amend as to the FEHA and UCL claims. The court dismissed Zajonc’s wrongful-termination claim without leave to amend. The amended complaint was due June 26, 2025, and Zajonc could not add claims or parties without further court permission. The court also continued the initial case-management conference to July 30, 2025.
Read the full 4-page opinion on CourtListener, the free public archive maintained by the Free Law Project.