Aronson v. Olmsted Medical Center

Background

Elizabeth Aronson, a former Olmsted Medical Center employee, alleged that she was discharged after refusing to receive a COVID-19 vaccine because of her religious beliefs. Olmsted Medical Center’s policy required employees to provide proof of vaccination, begin vaccination, or submit a declination form. The policy allowed employees to seek medical or religious exemptions, but employees with exemptions still had to complete education and undergo weekly COVID-19 testing. Aronson requested a religious exemption, which was denied, and she was discharged in November 2021.

Aronson asserted religious-discrimination and religious-accommodation claims under Title VII and the Minnesota Human Rights Act, as well as claims under the Americans with Disabilities Act. The court considered Olmsted Medical Center’s motion to dismiss the Minnesota Human Rights Act claims in Count 2 and the ADA claims in Count 3. The Title VII claim in Count 1 was not part of the motion to dismiss.

Minnesota Human Rights Act claims

The court held that Aronson had not plausibly alleged religious discrimination under the Minnesota Human Rights Act. The complaint did not allege that she was replaced by someone outside her protected class or identify facts showing that Olmsted Medical Center treated her differently because of her religion. Instead, the complaint alleged that the vaccine policy applied to all employees and that she was terminated for refusing the vaccine.

The court also held that the Minnesota Human Rights Act does not require employers to provide reasonable accommodations for religious beliefs. The court distinguished Title VII, which expressly includes a religious-accommodation requirement, from the Minnesota law, whose reasonable-accommodation provision addresses disability accommodations but does not mention religion. The court concluded that Count 2 failed to state a claim.

Americans with Disabilities Act claims

The court held that Aronson did not plausibly allege disability discrimination because the complaint contained no facts showing that she had, had a record of, or was regarded as having a physical or mental impairment that substantially limited a major life activity. The court also noted that she alleged seeking only a religious accommodation, not a disability accommodation.

The court further held that the vaccine requirement was not a prohibited medical examination or disability-related inquiry under the ADA. A vaccine does not seek information about a person’s health, and asking about vaccination status is not likely to reveal whether an employee has a disability. Aronson also did not allege that she personally underwent COVID-19 testing; the court stated that, even if she had, such testing would not amount to an unlawful medical examination on the allegations presented. The court concluded that Count 3 failed to plausibly allege disability discrimination or an ADA violation.

Punitive damages and disposition

Olmsted Medical Center separately asked the court to strike references to punitive damages. Because the Title VII claim remained and the court was considering the case at the pleading stage, it declined to strike those references at that time. The request to strike the punitive-damages reference was denied without prejudice to renewal later in the proceedings.

Judge Ann D. Montgomery ordered that Olmsted Medical Center’s motion to dismiss was granted. Counts 2 and 3 of the amended complaint were dismissed with prejudice. The opinion identifies Count 1, the Title VII claim, as the remaining claim.