Browder v. City of Boston

CourtDistrict Court, D. Massachusetts
DecidedAugust 15, 2025
Docket1:24-cv-11588
StatusUnknown

This text of Browder v. City of Boston (Browder v. City of Boston) is published on Counsel Stack Legal Research, covering District Court, D. Massachusetts primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Browder v. City of Boston, (D. Mass. 2025).

Opinion

UNITED STATES DISTRICT COURT DISTRICT OF MASSACHUSETTS ____________________________________ ) MICHAEL BROWDER, ) ) Plaintiff, ) ) ) Civil Action No. 1:24-CV-11588-AK v. ) ) BISOLA OJIKUTU, ) CITY OF BOSTON, ) TAMMY PUST, ) BOSTON FIREFIGHTERS LOCAL 718 ) INTERNATIONAL ASSOCIATION OF ) FIRE FIGHTERS AFL-CIO, ) JOHN SOARES, ) ) Defendants. ) )

MEMORANDUM AND ORDER ON DEFENDANT OJIKUTU’S MOTION TO DISMISS

ANGEL KELLEY, D.J. Plaintiff Michael Browder (“Plaintiff” or “Browder”) has sued Defendant Dr. Bisola Ojikutu (“Defendant Ojikutu”), in her individual and official capacities, alleging violations of substantive and procedural due process, free exercise under the First Amendment, and equal protection under the Fourteenth Amendment pursuant to 42 U.S.C. § 1983. [Dkt. 1]. Plaintiff has also sued Tammy Pust, the City of Boston, Boston Firefighters Local 718 International Association of Fire Fighters AFL-CIO, and John Soares. Defendant Ojikutu moves to dismiss all claims against her, arguing that Browder’s claims are barred by qualified immunity, that Browder has not alleged sufficient facts to plausibly entitle him to any relief, and that Browder has not alleged any conduct of hers that caused him harm. [Dkt. 24] (“Defendant Ojikutu’s Motion to Dismiss”). Plaintiff opposes Defendant Ojikutu’s Motion, arguing that Defendant Ojikutu acted as a cabinet-level agent of the City of Boston, causing Plaintiff harm. [Dkt. 25] (“Opposition to Defendant Ojikutu’s Motion to Dismiss”). For the following reasons, Defendant Ojikutu’s Motion to Dismiss [Dkt. 24] is GRANTED. I. BACKGROUND

A. General Facts Unless otherwise noted, the facts are presented as alleged in the Complaint. [Dkt. 1]. Plaintiff is a member of the Nation of Islam (“NOI”). Plaintiff “believes that biochemical tests, vaccines, and other countermeasures against contagious disease are sinful because they seek protection from affliction in something other than God.” [Dkt. 1 at ¶ 50]. In 2007, Plaintiff joined the City of Boston Fire Department as a firefighter. For 19 months during the height of the COVID-19 pandemic, Plaintiff completed the COVID-19 Employee Mandatory Self- Monitoring Checklist. On August 12, 2021, Defendant City of Boston instituted the Vaccine Verification or Required Testing for COVID-19 policy (“Vaccine or Test Policy”).

On September 27, 2021, Plaintiff submitted a request for religious exemption from both vaccination and testing to the City of Boston Office of Human Resources (“HR”). Plaintiff alleges that he asserted his religious exemption to the policy due to his sincerely held religious beliefs. In October 2021, Defendant Tammy Pust was appointed as the Director of the City of Boston Office of Labor Relations. On October 7, 2021, Plaintiff Browder requested an update on his religious exemption request, at which point the Defendant City of Boston asked him to fill out a religious accommodation form, which Plaintiff did. Plaintiff alleges that he received no updates regarding his religious accommodation request for the following two weeks. On October 25, 2021, Plaintiff Browder received an email before the close of business from a director of HR at City of Boston Fire Department noting he is not in compliance with the Vaccine or Test Policy and informing him that if he does not come in compliance by the close of business of that day, he would be placed on unpaid administrative leave at the start of his work shift on Tuesday, October 26, 2021. On October 27, 2021, Plaintiff Browder was relieved of his duties and placed on unpaid administrative leave.

On October 28, 2021, Defendant Pust reached out to Browder to set up a meeting to discuss his pending religious accommodation request. Plaintiff requested that the communication occur in writing and Defendant Pust provided him with a “Reasonable Accommodation Interactive Dialogue Questions” form. Plaintiff filled out and returned the form on October 28, 2021. On October 29, 2021, Plaintiff was notified by one of the City of Boston’s HR directors that his religious accommodation request was denied. Specifically, the accommodation for the vaccine component of the policy was denied since the vaccine was not mandatory. The accommodation for the test component of the policy was denied on undue hardship grounds.

On December 20, 2021, Plaintiff alleges that Defendant City of Boston instituted a Mandatory Vaccine Policy based on Defendant Ojikutu’s advice. The Mandatory Vaccine Policy, however, never went into effect. On May 11, 2023, the Vaccine or Test Policy ended. On May 24, 2023, Defendant City of Boston requested that Plaintiff return to work by May 31, 2023 and noted that Plaintiff was not entitled to any backpay due to his lack of compliance with the Vaccine or Test Policy. Plaintiff Browder responded to Defendant City of Boston noting, “it is the Department and the City’s duty to address the discriminatory and retaliatory behavior that [he] ha[s] endured and to find a just resolution to this situation.” On June 28, 2023, the City of Boston Fire Department’s deputy chief of personnel ordered Plaintiff to report to him on July 12, 2023 to discuss his work status and return to duty. Plaintiff did not return to work and alleges that he had considered himself constructively discharged upon being placed on indefinite unpaid administrative leave. On September 29, 2023, the City of Boston Fire Department’s deputy chief of personnel notified Plaintiff that he was no longer employed by the City of Boston due to being on an unauthorized absence since July 12, 2023.

B. Facts Specific to Defendant Ojikutu Defendant Ojikutu became Executive Director of the Boston Public Health Commission (“BPHC”) on September 1, 2021. [Dkt. 1 at ¶ 54]. Plaintiff alleges that, “on information and belief” Defendant Ojikutu had the authority to grant or deny religious accommodation requests to the Vaccine or Test Policy and that her decisions were based on the advice of the City of Boston’s Director of Labor Relations, Defendant Pust, who interviewed employees seeking these accommodations. [Dkt. 1 at ¶ 87]. Plaintiff further alleges that Defendant Ojikutu and Defendant City of Boston denied religious accommodation requests if they were based on “conspiracy beliefs” or “medical mistrust” as defined by Defendant Ojikutu in her research

publications. [Dkt. 1 at ¶¶ 86-88]. Plaintiff brought this suit on June 19, 2024. Plaintiff brings five claims against Defendant Ojikutu: violation of substantive due process under the Fourteenth Amendment pursuant to 42 U.S.C. § 1983 (Count I), violation of Massachusetts substantive due process pursuant to Mass. Gen. Laws. ch. 12, sec. 11I (Count II), violation of free exercise under the First Amendment pursuant to 42 U.S.C. § 1983 (Count III), violation of equal protection (disparate treatment and impact based on race) under the Fourteenth Amendment pursuant to 42 U.S.C. § 1983 (Count IV), and violation of procedural due process pursuant to 42 U.S.C. § 1983 (Count IX). Plaintiff specifically argues that Defendant Ojikutu is motivated by a professional interest in combating vaccine hesitancy, medical mistrust, and certain sincerely held beliefs among Black Americans, which Defendant Ojikutu has disparaged as “conspiracy beliefs” or “conspiracy theories.” [Dkt. 1 at ¶ 245].

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Browder v. City of Boston, Counsel Stack Legal Research, https://law.counselstack.com/opinion/browder-v-city-of-boston-mad-2025.