Savel v. MetroHealth System, No. 23-3672 (6th Cir. 2024)
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In this case, the United States Court of Appeals for the Sixth Circuit was presented with an appeal involving an Ohio hospital's mandate for its employees to get COVID-19 vaccines. The plaintiffs, a group of current and former employees who had requested religious exemptions from the mandate, sued the hospital for religious discrimination under Title VII and Ohio Revised Code § 4112 after the hospital initially rejected all religious exemptions. The district court dismissed the case for lack of subject matter jurisdiction and failure to state a claim, leading to this appeal.
The appellate court affirmed the dismissal for the majority of plaintiffs, ruling they lacked standing to sue because they could not demonstrate sufficient injury. However, the court reversed the dismissal for two of the plaintiffs who had resigned after their religious exemption requests were denied but before the hospital changed its policy and granted all religious exemptions. The court held that these two plaintiffs had plausibly alleged that they were forced to resign, or "constructively discharged", and thus had standing to sue.
Furthermore, the court found that these two plaintiffs had sufficiently alleged that the hospital failed to provide reasonable accommodations for their religious practices and treated them differently from other employees. Consequently, they had stated plausible claims for relief under Title VII and Ohio Revised Code § 4112. The case was remanded for further proceedings concerning these two plaintiffs.
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