Bement v. United Airlines, Inc.

CourtDistrict Court, N.D. Illinois
DecidedMarch 3, 2025
Docket1:24-cv-09201
StatusUnknown

This text of Bement v. United Airlines, Inc. (Bement 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
Bement v. United Airlines, Inc., (N.D. Ill. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION NATHAN BEMENT, ) ) Plaintiff, ) ) vs. ) Case No. 24 C 09201 ) UNITED AIRLINES, INC., ) ) Defendant. ) MEMORANDUM OPINION AND ORDER MATTHEW F. KENNELLY, District Judge: On September 23, 2021, plaintiff Nathan Bement submitted a religious accommodation request to his employer United Airlines, Inc. (United), the defendant in this case, requesting an exemption from the company's COVID-19 vaccine mandate. United denied Bement's claim, finding that his request was untimely. Eventually, United terminated Bement's employment because he failed to comply with the company's vaccine policy by the deadline United had set. Bement now sues United under Title VII of the Civil Rights Act of 1964 and the Florida Civil Rights Act (FCRA), alleging that the airline discriminated and retaliated against him on the basis of religion. United has moved to dismiss the complaint under Federal Rule of Civil Procedure 12(b)(6) for failure to state a claim. For the reasons stated below, the Court grants the motion to dismiss but gives Bement leave to amend. Background The Court summarizes the allegations in Bement's complaint as follows. Bement began working at United in January 1989. At the time of his termination in 2021, he worked as a sheet metal line technician. During his employment, Bement was regarded as being in good standing, and he received positive reviews. On August 6, 2021, United notified employees of its COVID-19 vaccination policy.

The policy established that: All U.S.-based employees are required to be vaccinated within five weeks after the FDA has announced it has fully approved a COVID-19 vaccine or five weeks after Sept. 20, 2021, whichever comes first. The latest potential deadline for meeting this requirement is Oct. 25, 2021. Employees are required to either (1) provide proof that they have received the full course of a designated COVID-19 vaccine or, (2) obtain an approved exemption as a reasonable accommodation.

Compl., Ex. A. On August 23, 2021, United sent employees an updated policy that imposed September 27, 2021 as the new deadline to comply with the vaccination policy. Id., Ex. B. Bement states that United never notified him of the deadline to submit an accommodation request. He concedes that a deadline was posted for front-line employees to submit exemption requests. Bement says, however, that he confirmed with his union representative that he was not considered a front-line employee. Bement submitted his religious accommodation exemption request in writing to United on September 23, 2021, four days before the final deadline for compliance with the vaccination policy. United denied the request the following day, providing a brief explanation that the request was untimely. On November 15, 2021, United held a fact-finding meeting to address Bement's case and determined that he had failed to comply with the COVID-19 vaccination mandate. United sent a mass email to employees on November 23, 2021 stating that Florida Statute 381.00317, which was adopted on November 18, 2021 and prohibited employers from mandating the COVID-19 vaccination without providing certain exemptions, did not apply to United because United was subject to federal Executive Order 14042 (Ensuring Adequate COVID Safety Protocols for Federal Contractors).

Bement still submitted to United, on November 25, 2021, a Florida Department of Health Religious Exemption From COVID-19 Vaccination Form. On December 1, 2021, United again denied Bement's request, stating, as before, that it was untimely and that the "request is being closed and no further action would be taken." After receiving this denial, Bement immediately filed an administrative complaint with the State of Florida, contending that United had violated Section 381.00317 of the Florida Statues, Private Employer Vaccine Mandate Program. On December 7, 2021, United formally terminated Bement. On May 4, 2023, Bement's case before the Florida Department of Legal Affairs concluded with the Department's acceptance of a settlement agreement requiring

United to pay a $15,000 fine. Bement now sues United, alleging religious discrimination in violation of Title VII and the FCRA due to a failure to accommodate (counts 1 and 3), as well as retaliation in violation of Title VII and the FCRA (counts 2 and 4). For the reasons explained below, the Court grants United's motion to dismiss all four claims. Discussion To survive a motion to dismiss, a 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 plaintiff may not rely on labels and conclusory allegations; he or she must plead "particularized factual content." Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009); Doe v.

Columbia Coll. Chi., 933 F.3d 849, 854 (7th Cir. 2019). The FCRA was modeled after Title VII, and thus "decisions construing Title VII apply to the analysis of FCRA claims." Johnson v. Miami-Dade County, 948 F.3d 1318, 1325 (11th Cir. 2020) (internal citation omitted). The Court therefore discusses the claims together. A. Failure to accommodate claims (counts 1 and 3) Bement argues that United failed to accommodate his religion by denying his request for a religious exemption from United's COVID-19 vaccination mandate. Under Title VII, employers are prohibited from discriminating against employees based on their religion, along with other protected characteristics. See 42 U.S.C. § 2000e–2(a). A

plaintiff asserting a claim for failure to accommodate "must prove three things: (1) 'the observance or practice conflicting with an employment requirement is religious in nature;' (2) the employee 'called the religious observance or practice to [the] employer's attention;' and (3) 'the religious observance or practice was the basis for [the employee's] discharge or other discriminatory treatment.'" Adeyeye v. Heartland Sweeteners, LLC, 721 F.3d 444, 449 (7th Cir. 2013). In attempting to satisfy this standard, Bement alleges that he holds "sincere religious beliefs that preclude him from receiving the COVID-19 vaccinations." Compl. ¶ 35. He contends that despite expressing these beliefs, United failed to engage in an interactive process with him to develop a reasonable accommodation to the vaccination mandate. The Court agrees with United that Bement has failed to adequately plead an observance or practice based on his religion that conflicts with United's COVID-19 vaccination policy. The Seventh Circuit has repeatedly emphasized that employees

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Bement v. United Airlines, Inc., Counsel Stack Legal Research, https://law.counselstack.com/opinion/bement-v-united-airlines-inc-ilnd-2025.