Benton v. BlueCross BlueShield of Tennessee, Inc.

CourtDistrict Court, E.D. Tennessee
DecidedJanuary 31, 2025
Docket1:22-cv-00118
StatusUnknown

This text of Benton v. BlueCross BlueShield of Tennessee, Inc. (Benton v. BlueCross BlueShield of Tennessee, Inc.) is published on Counsel Stack Legal Research, covering District Court, E.D. Tennessee primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Benton v. BlueCross BlueShield of Tennessee, Inc., (E.D. Tenn. 2025).

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF TENNESSEE AT CHATTANOOGA

TANJA BENTON, ) ) Plaintiff, ) Case No. 1:22-cv-118 ) v. ) Judge Atchley ) BLUECROSS BLUESHIELD OF ) Magistrate Judge Dumitru TENNESSEE, INC., ) ) Defendant. )

MEMORANDUM OPINION AND ORDER

Before the Court are Plaintiff Tanja Benton’s Motion for Interim Statutory Attorney Fees and Prejudgment Interest [Doc. 100], Defendant BlueCross BlueShield of Tennessee, Inc.’s (“BCBST”) Renewed Motion for Judgment as a Matter of Law [Doc. 104], and BCBST’s Motion to Alter or Amend the Judgment [Doc. 105]. For the following reasons, Benton’s Motion [Doc. 100] is GRANTED, BCBST’s Renewed Motion for Judgment as a Matter of Law [Doc. 104] is DENIED, and BCBST’s Motion to Alter or Amend the Judgment [Doc. 105] is GRANTED. I. BACKGROUND Tanja Benton filed this action against her former employer, BCBST, on May 16, 2022, alleging that BCBST failed to accommodate her religious objection to the company’s COVID-19 vaccine mandate. [Doc. 1]. She brought two failure to accommodate claims, one under Title VII and the other under the Tennessee Human Rights Act. [Id.]. BCBST, unsurprisingly, denied Benton’s allegations. [Doc. 10]. Later, Benton moved for summary judgment. [Doc. 40]. The Court denied this motion after finding there was a genuine dispute as to whether Benton’s objection to the COVID-19 vaccine mandate was based on a sincerely held religious belief. [Doc. 69]. With summary judgment denied, the case proceeded to trial. At trial, BCBST moved for judgment as a matter of law, which the Court took under advisement. [See Docs. 85–86; Doc. 97 at 315–25; Doc. 98 at 2]. The trial proceeded, and the jury ultimately found in Benton’s favor. [Doc. 94]. Specifically, the jury found: (1) that Benton had proven by a preponderance of the evidence that her refusal to receive the COVID-19 vaccine was based upon a sincerely held religious belief; (2) that BCBST had not proven by a preponderance

of the evidence that it offered Benton a reasonable accommodation; and (3) that BCBST had not proven by a preponderance of the evidence that it could not reasonably accommodate Benton’s religious beliefs without undue hardship. [Id.]. Based on these findings, the jury awarded Benton $177,240.00 in back pay damages and $10,000.00 in compensatory damages. [Id.]. The jury, by separate verdict, further found that Benton had proven by a preponderance of that evidence that she was entitled to punitive damages and awarded her an additional $500,000.00. [Id.]. In the months that followed, the parties filed the three motions currently pending before the Court. [See Docs. 100, 104–05]. Of these motions, the Court will first examine BCBST’s Renewed Motion for Judgment as a Matter of Law [Doc. 104] as its resolution impacts the analysis

of the other two II. BCBST’S RENEWED MOTION FOR JUDGMENT AS A MATTER OF LAW BCBST asserts that it is entitled to judgment as a matter of law for three reasons. First, BCBST asserts that Benton’s objection to the COVID-19 vaccine was not based on a sincerely held religious belief and therefore lacks protection under Title VII. [Doc. 104 at 1]. Second, BCBST asserts that the unrebutted proof shows that it offered Benton reasonable accommodations but that she failed to put forth the good faith effort needed to make them workable. [Id.]. Third and finally, BCBST asserts that the unrebutted proof it would have incurred substantial increased costs if it provided Benton her requested accommodation. In addition, BCBST also asserts that even if it is not entitled to judgment as a matter of law regarding liability, it is nevertheless entitled to judgment as a matter of law regarding the availability of punitive damages because Benton could not establish that BCBST acted maliciously or with reckless disregard to her rights. [Id. at 2]. For the following reasons, BCBST’s Motion [Doc. 104] is DENIED.

A. Standard of Review Rule 50(b) of the Federal Rules of Civil Procedure provides that “[i]f the court does not grant a motion for judgment as a matter of law made under Rule 50(a),” then “the movant may file a renewed motion for judgment as a matter of law” no later than 28 days after the entry of judgment or, “if the motion addresses a jury issue not decided by a verdict, no later than 28 days after the jury was discharged[.]” “A court should render judgment as a matter of law when ‘a party has been fully heard on an issue and there is no legally sufficient evidentiary basis for a reasonable jury to find for that party on that issue.’” Reeves v. Sanderson Plumbing Prods., Inc., 530 U.S. 133, 149, 120 S. Ct. 2097, 147 L. Ed. 2d 105 (2000) (quoting FED. R. CIV. P. 50(a)(1)). In determining

whether this standard has been met a court “may not weigh the evidence, question the credibility of witnesses, or substitute [its] own judgment for that of the jury.” Smith v. Rock-Tenn Servs., 813 F.3d 298, 306 (6th Cir. 2016). “Instead, a renewed motion pursuant to Rule 50(b) may only be granted when, ‘viewing the evidence in a light most favorable to the non-moving party [and] giving that party the benefit of all reasonable inferences, there is no genuine issue of material fact for the jury, and reasonable minds could come to but one conclusion in favor of the moving party.’” Schlosser v. VRHabilis, LLC, 113 F.4th 674, 683 (6th Cir. 2024) (alteration in original) (quoting Balsley v. LFP, Inc., 691 F.3d 747, 757 (6th Cir. 2012)). Succeeding on such a motion requires a party to overcome “the substantial deference owed a jury verdict.” Id. (internal quotation marks omitted). B. Analysis1 1. A reasonable jury could find BCBST liable for religious discrimination.

a. A reasonable jury could find that Benton’s opposition to BCBST’s COVID-19 vaccine mandate was based on her sincerely held religious beliefs.

BCBST asserts that it is entitled to judgment as a matter of law because “[Benton] did not offer any testimony from which a jury could reasonably conclude that her objection to vaccination against COVID-19 was a legally protected religious belief.” [Doc. 104 at 3]. It asserts that her vaccine opposition is emblematic of an “isolated teaching” as opposed to a “comprehensive belief system” that receives legal protection. [See id. at 3–5]. In response, Benton asserts that she provided ample evidence that her COVID-19 vaccine opposition stems from her sincerely held religious beliefs, specifically her beliefs surrounding abortion and the sanctity of human life. [Doc. 107 at 2–6]. The Court finds that Benton has the better argument. To establish a prima facie case of religious discrimination—such as Benton’s failure to accommodate claim—a plaintiff employee must establish: (1) that she holds a sincere belief that conflicts with an employment requirement; (2) that she informed her employer of the conflict; and (3) that the employer took an adverse employment action against her because of her failure to comply with the conflicting employment requirement. Sturgill v. Am. Red Cross, 114 F.4th 803, 809 (6th Cir. 2024). In this case, the parties only disputed the first element of Benton’s prima facie case, and it is this element that BCBST challenges through its assertion that Benton failed to introduce any evidence from which the jury could reasonably conclude that her opposition

1 The Court’s analysis of BCBST’s Motion does not distinguish between Benton’s federal and state failure to accommodate claims as both claims are analyzed identically. Cox v. Little Clinic of Tenn., LLC, 858 F.

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Benton v. BlueCross BlueShield of Tennessee, Inc., Counsel Stack Legal Research, https://law.counselstack.com/opinion/benton-v-bluecross-blueshield-of-tennessee-inc-tned-2025.