Kiel v. Mayo Clinic, The

Background

Shelly Kiel, Sherry Ihde, Anita Miller, Kenneth Ringhofer, and Kristin Rubin were employed by The Mayo Clinic or related Mayo entities. Mayo adopted a policy requiring employees to receive a COVID-19 vaccination, obtain an exemption, or face termination. The plaintiffs identified as Christians and alleged that vaccination and, for some of them, weekly COVID-19 testing conflicted with sincerely held religious beliefs.

Ihde and Rubin received religious exemptions from vaccination but refused the required weekly testing. Kiel, Miller, and Ringhofer were denied religious exemptions and refused vaccination. Mayo terminated all five plaintiffs. They brought claims under Title VII of the Civil Rights Act of 1964, the Minnesota Human Rights Act, the Americans with Disabilities Act, breach-of-contract law, and promissory estoppel. In their briefing, the plaintiffs clarified that their Title VII and Minnesota claims were based on failure to accommodate religious beliefs, rather than treating Christians differently from non-Christians.

Title VII claims

Title VII requires an employee to file a timely discrimination charge with the Equal Employment Opportunity Commission or an authorized state or local agency before suing. The court held that Ihde and Miller did not exhaust their Title VII termination claims because they filed their charges before Mayo terminated them and did not update the charges afterward. The court also held that those claims were now time-barred and dismissed them with prejudice.

The court assumed that Kiel, Ringhofer, and Rubin had exhausted their Title VII religious-discrimination claims but held that their complaints did not plausibly allege a protected religious belief conflicting with Mayo’s policy. For Kiel, the court found that her objections appeared based on concerns that the vaccine was unsafe or impure and on opposition to abortion that she did not connect to particularized religious beliefs. The court also found that she did not adequately allege what religious information she provided to Mayo.

For Ringhofer, the court concluded that, considering his complaint as a whole, his opposition to vaccination appeared to rest on personal medical and safety judgments, including his research into the vaccines and statements that the vaccine contained unknown or altering substances. The court also found that his statement that vaccination was his personal choice suggested that his religion did not directly conflict with vaccination. Ringhofer likewise did not adequately allege what information he gave Mayo about his beliefs.

For Rubin, the court held that she did not identify religious teachings explaining why weekly testing would harm her body or violate her religion. Her statements that testing was unnecessary and that she would follow God’s instructions were insufficient, and the court viewed her objection as a personal medical judgment rather than a protected religious belief. The court dismissed Kiel’s, Ringhofer’s, and Rubin’s Title VII claims.

Minnesota Human Rights Act claims

The court dismissed all five plaintiffs’ Minnesota Human Rights Act claims. It held that those claims were based on failure to accommodate religious beliefs, and that the Act does not recognize failure to accommodate religious beliefs as a separate claim. The Act’s express reasonable-accommodation provision applies to disability discrimination, not religious discrimination.

Americans with Disabilities Act claims

The court dismissed Kiel’s, Miller’s, and Ringhofer’s Americans with Disabilities Act claims for failure to exhaust administrative remedies. Their agency charges did not mention disability or the Americans with Disabilities Act, and their religious- or age-discrimination allegations were not sufficiently related to the disability claims asserted in their complaints.

The court dismissed Ihde’s and Rubin’s disability claims for two additional reasons. First, it held that the weekly COVID-19 testing requirement was not an unlawful medical examination under the Act. Second, neither plaintiff adequately alleged a disability because the complaints did not show that being unvaccinated substantially limited a major life activity. Their related failure-to-accommodate claims also failed because they did not allege a disability.

Contract and promissory-estoppel claims

The plaintiffs alleged that Mayo’s equal-opportunity policy created a contract promising protection against religious discrimination. The court held that the policy was only a general statement and did not contain sufficiently definite terms or detailed procedures to constitute a unilateral employment contract. It therefore dismissed the breach-of-contract claims.

The court also dismissed the promissory-estoppel claims. Promissory estoppel is a legal doctrine that may enforce a promise when no contract exists if there was a clear promise, intended reliance, actual detrimental reliance, and enforcement is needed to prevent injustice. The court held that the policy was not a sufficiently definite promise and that the plaintiffs had not alleged facts showing detrimental reliance.

Disposition

The court granted Defendants’ motions to dismiss and dismissed all five cases with prejudice. The court did not decide Mayo’s request concerning punitive damages because it dismissed the Title VII and Americans with Disabilities Act claims. Judge John R. Tunheim ordered that judgment be entered.