Cole v. Group Health Plan, Inc.

Background

HealthPartners instituted a policy requiring employees either to receive COVID-19 and influenza vaccinations or to use an accommodation process. Employees granted an exemption had to wear a medical-grade personal protective equipment mask while working in HealthPartners facilities, along with additional protective equipment when appropriate. Cole, a physical therapist, was not vaccinated and received a religious exemption.

Cole practices the Eckankar religion and alleged that receiving a COVID-19 vaccine would violate her religious beliefs because the ingredients of available vaccines were not fully disclosed. She claimed that exempt employees were treated differently from vaccinated employees because they could not receive an orange badge lock, had to wear masks in areas where vaccinated employees could remove them, and could be identified as unvaccinated. She also alleged that employees criticized people without the badge lock.

The complaint originally referred to claims under Title VII of the Civil Rights Act of 1964, the Americans with Disabilities Act, the Minnesota Human Rights Act, and breach of contract. In analyzing the motion, however, the court identified two causes of action: religious discrimination and failure to accommodate under Title VII, and religious discrimination under the Minnesota Human Rights Act. The opinion does not analyze the disability or contract allegations separately.

The opinion notes that Cole was employed by Park Nicollet, not Group Health Plan, Inc. Because Park Nicollet had merged with HealthPartners, the court referred to the defendant as HealthPartners.

Rule 12(b)(6) Standard

HealthPartners moved to dismiss under Rule 12(b)(6) of the Federal Rules of Civil Procedure for failure to state a claim. That motion tests whether the complaint alleges enough facts to make a legally valid claim, not whether the plaintiff will ultimately win. The court accepted well-pleaded factual allegations as true and considered whether the complaint stated a plausible claim for relief.

Title VII Claim

For a religious-accommodation claim under Title VII, the court stated that Cole had to show that she had a genuine religious belief conflicting with an employment requirement, informed HealthPartners of that belief, and was disciplined for failing to comply with the conflicting requirement. If those elements were shown, HealthPartners would have to show that it offered a reasonable accommodation or that accommodation would cause an undue hardship.

HealthPartners did not dispute, for purposes of the motion, that Cole held a sincere religious belief and had informed the company of it. The court instead focused on whether Cole identified an employment requirement that conflicted with her religion and whether she experienced an adverse employment action.

The court reasoned that HealthPartners did not require Cole to receive a COVID-19 vaccine. Instead, it gave employees the choice of vaccination or compliance with accommodation requirements. Cole did not allege that wearing a mask or using other protective equipment conflicted with her religious beliefs. The court therefore concluded that she had not alleged a religious belief conflicting with an employment requirement.

The court also held that, even assuming HealthPartners had a duty to accommodate Cole, granting her an exemption from vaccination and permitting her to wear a mask or other protective equipment was a reasonable accommodation because it eliminated the conflict between vaccination and her religious practices. The court further noted that Cole did not allege a reduction in pay, unpaid leave, or another loss of employment benefits because she was unvaccinated.

The court concluded that Cole had not alleged either a conflicting religious belief or an adverse employment action because of her religion. It therefore granted HealthPartners’ motion to dismiss her Title VII religious-discrimination and failure-to-accommodate claim.

Minnesota Human Rights Act Claim

The court stated that the analysis under the Minnesota Human Rights Act parallels the Title VII analysis. Because Cole had not established the required elements of religious discrimination under Title VII, the court reached the same conclusion on her Minnesota Human Rights Act claim and granted the motion to dismiss that claim as well.

Disposition

The court ordered that HealthPartners’ motion to dismiss was GRANTED. The opinion does not state that the claims were dismissed with or without prejudice.