Fallon v. Mercy Catholic Med. Ctr. of Se. Pa. — Aug. 2016 (Summary)

RELIGIOUS DISCRIMINATION

Fallon v. Mercy Catholic Med. Ctr. of Se. Pa.
Civil Action No. 16-00834 (E.D. Pa. Aug. 9, 2016)

The United States District Court for the Eastern District of Pennsylvania granted a defendant hospital’s motion to dismiss a religious discrimination claim brought by a former employee, who was terminated due to his unwillingness to be vaccinated.

The hospital required its employees to obtain a flu vaccination or submit an exemption form to obtain a religious exemption.  The employee was granted an exemption two years in a row by providing the hospital with an essay, then was denied an exemption the third year, and was informed that he would need to provide a letter on official clergy letterhead supporting his request for an exemption.  In response, the employee submitted an essay and letter explaining that he couldn’t provide such clergy letter because he was not a member of an official religious organization and explained that his reasoning behind requesting the exemption was his conscience.

The hospital denied the exemption, and the employee brought a claim for religious discrimination under Title VII of the Civil Rights Act of 1964.  The court ruled that the employee failed to state a claim for religious discrimination, finding that: the employee’s mindset was more personal and social rather than spiritual; his beliefs regarding the vaccination consisted of a single governing idea rather than a belief system; the employee explicitly stated that he was not a member of an organized religion, and he did not belong to a religious congregation; and the employee did not claim that his reasons for refusing to be vaccinated were based on a religious belief.