In Sturgill v. American Red Cross (6th Cir., No. 24-1011, 08/21/2024), the employer fired Sturgill for not getting a COVID vaccination, finding that she was medically—but not religiously—opposed to the vaccine. Sturgill sued, alleging a failure to accommodate her religious beliefs in violation of Title VII. The trial court dismissed the case at the 12(b)(6) stage, ruling the complaint failed to show a sincere religious belief that conflicted with an employment requirement. The Sixth Circuit reversed, holding a plaintiff need not plead a prima facie case at the pleading stage, and that the complaint plausibly alleged a failure to accommodate claim. Rather, the court held that whether the plaintiff established a prima facie case is a question for the summary judgment stage following discovery.
Sixth Circuit Finds Complaint Sufficiently Alleges Failure to Accommodate Religious Beliefs
