Cole v. Group Health Plan, Inc.

Background

HealthPartners instituted a policy requiring employees either to receive COVID-19 and influenza vaccinations or to follow accommodation requirements. Employees who received an exemption for medical or religious reasons had to wear a medical-grade personal protective equipment mask while working in HealthPartners facilities, along with additional protective equipment when appropriate. Cole, who practices the Eckankar religion, alleged that receiving a COVID-19 vaccine would violate her religious beliefs because the ingredients were not fully disclosed. HealthPartners granted her a religious exemption.

Cole alleged that the exemption requirements treated unvaccinated employees differently. She alleged that vaccinated employees could display an orange badge lock and remove their masks in certain administrative and non-patient-care areas, while exempt employees could not. She also alleged that the badge system and mask requirement revealed her vaccination status and subjected her to criticism or ridicule.

The complaint, as described in the opinion, asserted claims involving Title VII of the Civil Rights Act of 1964, the Americans with Disabilities Act, the Minnesota Human Rights Act, and breach of contract. In its analysis, 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. HealthPartners moved to dismiss for failure to state a claim under Federal Rule of Civil Procedure 12(b)(6), which tests whether the complaint sufficiently alleges a legally plausible claim rather than deciding the case after evidence is presented.

Court’s analysis

For a Title VII religious-accommodation claim, the court stated that Cole had to allege that she held a genuine religious belief conflicting with an employment requirement, informed HealthPartners of that belief, and was disciplined for failing to follow the conflicting requirement. HealthPartners did not dispute, for purposes of the motion, that Cole’s religious belief was sincere or that she communicated it.

The court concluded that Cole had not alleged the required conflict. HealthPartners did not require Cole or other employees to receive the COVID-19 vaccine. Instead, employees could comply with the policy by following the accommodation requirements. Cole alleged that those requirements were unreasonable and humiliating, but she did not allege that wearing a mask or using additional protective equipment conflicted with her religious obligations. Because she had an option that did not require violating her religious beliefs, the court found that she had not alleged a bona fide religious belief conflicting with an employment requirement.

The court alternatively concluded that, assuming HealthPartners had a duty to accommodate Cole, it satisfied that duty by allowing her to remain unvaccinated while wearing a mask or other protective equipment. The court also noted that Cole did not allege a reduction in pay, unpaid leave, termination, or another loss of employment benefits. It therefore found that she had not alleged an adverse employment action because of her religion.

The court applied the same analysis to Cole’s Minnesota Human Rights Act claim because Minnesota courts and federal courts generally analyze the relevant religious-discrimination requirements in parallel. The court concluded that Cole had not established a prima facie case under that statute either.

Disposition

The court granted HealthPartners’ motion to dismiss Cole’s Title VII religious-discrimination and failure-to-accommodate claim and her Minnesota Human Rights Act religious-discrimination claim. The amended order stated that it was amended solely because the court had previously neglected to enter judgment; no other part of the order was altered. The court directed that judgment be entered.