In Craven v. Shriners Hospital for Children, (D OR, Jan. 2, 2024), an Oregon federal district court dismissed a Title VII religious discrimination claim brought by a hospital maintenance technician who was fired after his claim for a religious exemption from the hospital's Covid vaccine mandate was denied. The court concluded that plaintiff had not adequately alleged that his objections to the vaccine were religious in nature. It also concluded that filing an amended complaint would be futile. The court said in part:
As Plaintiff wrote, he objected to the COVID-19 vaccine because its “ingredients include carcinogens, neurotoxins, animal viruses, animal blood, allergens, and heavy metals,” which “can cause serious harm and even death to the body.” ... This judgment—on the potential danger of the vaccine due to its physical composition—was scientific and medical, not religious. Of course, this Court does not question the sincerity of Plaintiff’s belief that his “body is a temple of the Holy Spirit.”... But Plaintiff’s beliefs about the composition of his body and that of the vaccine are independent of one another; whether Plaintiff’s body is a temple has no bearing on whether the vaccine contains carcinogens or whether, as a result of its ingredients, it “can cause serious harm.”
Therefore, Plaintiff’s allegations, even if fleshed out in a subsequent filing, would fail to state a claim of religious discrimination under Title VII.
