Zajonc v. T-Mobile US, Inc.

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) and California’s Unfair Competition Law (UCL). T-Mobile removed the case to federal court based on diversity jurisdiction. The court had previously granted T-Mobile’s motion to dismiss the original complaint for failure to state a claim. This order addresses T-Mobile’s motion to dismiss Zajonc’s first amended complaint.

FEHA Claim

The court held that Zajonc’s amended complaint still did not plausibly allege a FEHA religious-discrimination claim. To plead such a claim, a plaintiff must allege, among other things, a bona fide religious belief that conflicts with an employment requirement. Zajonc alleged only that she had bona fide religious beliefs preventing her from taking the COVID-19 vaccine and that her pastor sent a letter outlining the religious reasons for her refusal. She did not identify those reasons or attach the letter.

The court also found that Zajonc had not plausibly alleged that she was terminated because of her religious beliefs. Her allegation that T-Mobile later refused to allow accommodations, resulting in termination, was conclusory and did not state when the termination occurred. The court therefore again granted the motion to dismiss the FEHA claim.

UCL Claim

The court explained that the UCL permits only equitable remedies, such as an injunction or restitution, and that a plaintiff generally must show that money damages or another legal remedy is inadequate. Zajonc argued that she sought an injunction preventing T-Mobile from terminating employees for refusing the COVID-19 vaccine on religious grounds. The court found that she lacked Article III standing to seek forward-looking relief because she had not alleged that T-Mobile actually had such a termination policy or that, as a former employee, she faced a substantial risk of future injury.

The court also held that the UCL claim failed to state a claim even if Zajonc had adequately alleged standing. The unlawful portion depended on the alleged FEHA violation, which was inadequately pleaded. The unfair portion added no supporting facts. The fraudulent portion relied on an allegation that Zajonc’s manager stated that her accommodation request was approved and later revoked, but she did not identify the alleged common policy or allege facts showing a deceptive business practice likely to mislead the public. The court dismissed the UCL claim for lack of Article III standing and failure to state a claim.

Leave to Amend and Disposition

Although T-Mobile argued that leave to amend should be denied because Zajonc had already amended once without curing the defects, the court gave her one final opportunity to amend. The court relied on her representation at oral argument that she could plead additional supporting facts.

The court granted T-Mobile’s motion to dismiss and scheduled an initial case-management conference for October 29, 2025. The order did not state that the case was dismissed with prejudice or without prejudice.