Anderson v. United Airlines, Inc.

CourtDistrict Court, N.D. Illinois
DecidedApril 10, 2024
Docket1:23-cv-00989
StatusUnknown

This text of Anderson v. United Airlines, Inc. (Anderson v. United Airlines, Inc.) is published on Counsel Stack Legal Research, covering District Court, N.D. Illinois primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Anderson v. United Airlines, Inc., (N.D. Ill. 2024).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION

THOMAS ANDERSON, et al., ) ) Plaintiffs, ) ) vs. ) Case No. 23 C 989 ) UNITED AIRLINES, INC., et al., ) ) Defendants. )

MEMORANDUM OPINION AND ORDER MATTHEW F. KENNELLY, District Judge: Thomas Anderson and the twenty-seven other plaintiffs in this case are pilots, flight attendants, and ground staff who work at United Airlines, Inc. The plaintiffs filed suit against United Airlines, its CEO Scott Kirby, and various other United executives and board members (collectively, United), asserting twelve claims arising out of United's COVID-19 vaccine mandate. Before the Court is the third version of the plaintiffs' complaint. For the following reasons, the Court denies the plaintiffs' motion to file an amended complaint and dismisses all of the plaintiffs' claims. Background The Court assumes familiarity with the facts of this case and its ruling on the plaintiffs' previous motion to amend. See Anderson v. United Airlines, Inc., No. 23 C 989, 2023 WL 5721594 (N.D. Ill. Sept. 5, 2023). The facts as alleged in the second proposed amended complaint are unchanged in all relevant respects. To summarize, in August 2021, United implemented a vaccine mandate that required all United employee to receive the first dose of the COVID-19 vaccine by September 27, 2021. Employees who failed to upload a copy of their vaccination record to United's employee databased by the specified date would be terminated unless they received a medical or religious exemption. United required all exemptions to be requested by August 31, 2021.

Employees granted an accommodation were placed on unpaid leave starting on October 2, 2021. The plaintiffs allege that they are current or former employees of United and that receiving the COVID-19 vaccine would violate their "sincerely held religious beliefs that their body is a temple, and that their Creator planned their existence upon their creation." Proposed Am. Compl. ¶ 106. They claim that the COVID-19 vaccines are "gene-altering experimental therapies" that lead to "a fundamental change in their genetic design that their Creator imparted within them." Id. ¶ 110. Only three of the plaintiffs allege that they applied for a religious exemption from United's vaccination requirement. See id. ¶¶ 14, 15, 17. One plaintiff alleges that he attempted to apply but

missed the deadline. Id. ¶ 33. The proposed SAC does not state whether the remaining plaintiffs applied for religious accommodations. In September 2021, United sent postcards without a privacy envelope to employees who had not yet provided proof of vaccination. The postcards stated that "[o]ur records indicate that you have not uploaded your COVID-19 vaccine information to Flying Together" and that "[u]nvaccinated employees without a reasonable

accommodation will be separated from United." Id. ¶ 154 (alterations in original). Also in September 2021, United began requiring unvaccinated employees to wear facemasks. United moved to dismiss the plaintiffs' original complaint. The Court set a schedule for briefing that motion and extended the deadline for the plaintiffs' response at their request. On the due date for their response, the plaintiffs instead filed an amended complaint. For clarity, the Court will refer to this as the first amended

complaint (FAC). Because that filing was outside the time for amendment as of course under Federal Rule of Civil Procedure 15(a)(1), the Court determined to treat the plaintiffs' FAC as a motion for leave to file an amended complaint. United filed a response opposing the motion, and the plaintiffs replied to the United's response. The Court issued a decision denying leave to amend because the proposed FAC failed to state a claim upon which relief could be granted. The Court instructed that unless the plaintiffs filed a second proposed amended complaint stating at least one viable claim over which the Court has jurisdiction, it would enter judgment in favor of United. The plaintiffs filed a second proposed amended complaint on September 26, 2023. The Court will refer to this as the second amended complaint (SAC). United opposed the

motion, arguing that "Plaintiffs' SAC changes almost nothing . . . and do[es] not resolve any of the infirmities this Court already identified or which United argued in its prior opposition to leave or in its motion to dismiss." Defs.' Resp. to Mot. to Amend at 1. The plaintiffs filed a reply to United's opposition. Discussion Federal Rule of Civil Procedure 15(a)(2) instructs courts to "freely give leave [to

amend] when justice so requires." "[D]istrict courts have broad discretion to deny leave to amend where there is undue delay, bad faith, dilatory motive, repeated failure to cure deficiencies, undue prejudice to the defendants, or where the amendment would be futile." Arreola v. Godinez, 546 F.3d 788, 796 (7th Cir. 2008). In evaluating futility, the Court applies "the legal sufficiency standard of Rule 12(b)(6) to determine whether the proposed amended complaint fails to state a claim." Kap Holdings, LLC v. Mar-Cone Appliance Parts Co., 55 F.4th 517, 529 (7th Cir. 2022) (internal quotation marks

omitted). To survive a motion to dismiss for failure to state a claim, "the plaintiff must allege 'enough facts to state a claim to relief that is plausible on its face.'" NewSpin Sports, LLC v. Arrow Elecs., Inc., 910 F.3d 293, 299 (7th Cir. 2018) (quoting Bell Atl. Corp. v. Twombly, 550 U.S. 544, 570 (2007)). At the pleading stage, the Court must "accept all well-pleaded facts in the complaint as true and draw all reasonable inferences in the plaintiff's favor." Id. A. EUA (count 1) In count one, the plaintiffs allege that United violated 21 U.S.C. § 360bbb- 3(e)(1)(A)(ii)(III) of the Federal Food, Drug, and Cosmetic Act (FDCA) by requiring its employees to receive the COVID-19 vaccine, wear facemasks, and take PCR COVID-

19 tests. The Court held that the plaintiffs could not bring a claim based on an alleged violation of the EUA provision of the FDCA because they failed to respond to United's argument that the FDCA does not create a private right of action and therefore forfeited the point. The plaintiffs' proposed SAC nevertheless contains a virtually identical EUA claim with no relevant changes. In their reply to United's response in opposition to the motion to amend, the plaintiffs attempt to rebut United's original argument that there is no private cause of action under the EUA. But this is not appropriate at this stage of the litigation. The plaintiffs forfeited this point in the first round of briefing, leading the Court to conclude that they failed to state a claim under the EUA. See Anderson, 2023 WL 5721594, at *2. "[B]y failing to respond responsively to the motion to dismiss . . . [the plaintiffs] forfeited [their] right to continue litigating [their] claim." Kirksey v. R.J. Reynolds Tobacco Co., 168 F.3d 1039, 1043 (7th Cir. 1999). The fact that the Court

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Anderson v. United Airlines, Inc., Counsel Stack Legal Research, https://law.counselstack.com/opinion/anderson-v-united-airlines-inc-ilnd-2024.