Ledezma v. Optum Services, Inc.

Background

Maria Ledezma brought claims against Optum Services, Inc. under Title VII of the Civil Rights Act and California’s Fair Employment and Housing Act (FEHA). The opinion discusses her allegation that Optum required employees to be vaccinated against Covid-19 and her claim that Optum failed to accommodate her religion.

Title VII claim

The court held that Ledezma’s Title VII claim was barred by the statute of limitations. The court said she received her right-to-sue notice from the Equal Employment Opportunity Commission on March 1, 2023, but did not file the lawsuit until November 13, 2023—more than the 90-day filing period allowed by federal law. The court granted Optum’s request for judicial notice of the notice and dismissed the Title VII claim with prejudice because Ledezma did not dispute the filing delay or explain why it did not bar her claim.

FEHA claim

The court found that Ledezma’s FEHA claim was timely because she filed the lawsuit within one year after receiving a right-to-sue notice from the California Civil Rights Department. But the court held that the complaint did not explain what Ledezma’s sincerely held religious belief was or how that belief conflicted with Optum’s vaccination requirement. Without those allegations, the complaint did not state a basic claim that Optum failed to accommodate her religion under FEHA.

Result

The court granted Optum’s motion to dismiss. The Title VII claim was dismissed with prejudice. The FEHA claim was dismissed with leave to amend. Any amended complaint was due within 14 days, and any response was due 14 days after that.