Casciano v. Life Secure Insurance Company

CourtDistrict Court, E.D. Michigan
DecidedJanuary 22, 2025
Docket2:23-cv-11149
StatusUnknown

This text of Casciano v. Life Secure Insurance Company (Casciano v. Life Secure Insurance Company) is published on Counsel Stack Legal Research, covering District Court, E.D. Michigan primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Casciano v. Life Secure Insurance Company, (E.D. Mich. 2025).

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF MICHIGAN SOUTHERN DIVISION

CHRIS CASCIANO,

Plaintiff,

v. Case No. 23-11149 Hon. Jonathan J.C. Grey LIFESECURE INSURANCE CO.,

Defendant. ___________________________________/

OPINION AND ORDER DENYING DEFENDANT’S MOTION FOR JUDGMENT ON THE PLEADINGS (ECF No. 17) and GRANTING PLAINTIFF’S MOTION FOR LEAVE TO FILE AMENDED COMPLAINT (ECF No. 19)

On May 16, 2023, Plaintiff Chris Casciano filed the instant complaint against his former employer, LifeSecure Insurance Company (“LifeSecure”), alleging two violations of his civil rights under Title VII, 42 U.S.C. § 2000e et seq., and one violation of the Elliott-Larsen Civil Rights Act (“ELCRA”), Mich. Comp. Laws § 37.2101 et seq. In summary, Casciano alleges that LifeSecure unlawfully discriminated against his religion by failing to grant him a religious exemption from a COVID-19 vaccination requirement and then terminating his employment for not getting the vaccine. This matter is before the Court on LifeSecure’s motion for judgment

on the pleadings (ECF No. 17) and Chris Casciano’s motion for leave to file an amended complaint (ECF No. 19.) The motions are fully briefed. The Court finds that the parties have adequately briefed the motions and

therefore considers them without oral argument. E.D. Mich. LR 7.1(f). I. BACKGROUND Casciano was employed as a manager by LifeSecure until his

termination on January 5, 2022. After his termination, Casciano filed an Equal Employment Opportunity Commission (“EEOC”) Charge of Discrimination alleging religious discrimination and retaliation on

February 25, 2022, and received his right to sue letter on February 17, 2022. (ECF No. 1, PageID.3.) On November 1, 2021, LifeSecure enacted a mandatory COVID-19

vaccination policy for all employees and contractors. In his original complaint, Casciano provides limited detail about his religious belief and merely alleges he has a sincerely held religious belief as he “seeks to

make all decisions, especially those regarding vaccination and other medical decisions, through prayer” and his sincerely held religious belief conflicted with the vaccination policy. (ECF No. 1, PageID.6.) Casciano submitted a religious exemption request for the COVID-

19 vaccine to LifeSecure. After an interview, LifeSecure denied Casciano’s exemption request. Casciano alleges that LifeSecure did not engage in an interactive process which might have allowed for

accommodation of his belief. Casciano further alleges that he was treated “differently than similarly situated employees with different religious beliefs who were allowed to continue working despite not being

vaccinated.” (ECF No. 1, PageID.14.) In his proposed amended complaint, Casciano provides additional detail about his religious belief, including that he is a nondenominational

Christian who “derives his morals and conscience from Jesus Christ and the Bible.” (ECF No. 19-1, PageID.305.) He further alleges he believes that “God created man in His perfect image with an immune system built

to protect from illness and harm” and he “must not alter God’s design for the human body, including his natural God-given immune system, which conflicts with Defendant’s employment requirement to vaccinate from

COVID-19.” (Id.) In terms of the disparate treatment claims, Casciano states that “[i]n discovery, Plaintiff will be able to investigate which types of religious beliefs Defendant found to be acceptable and which types of

religious beliefs Defendant discriminated against, thereby establishing evidence probative of discriminatory intent.” (ECF No. 19-1, PageID.317– 318.)

II. LEGAL STANDARD A Rule 12(c) motion for judgment on the pleadings is subject to the same standard of review as a motion to dismiss for failure to state a claim

upon which relief can be granted under Federal Rule of Civil Procedure 12(b)(6). Hindel v. Husted, 875 F.3d 344, 346 (6th Cir. 2017) (citing Barany-Snyder v. Weiner, 539 F.3d 327, 332 (6th Cir. 2008)). The Court

may grant a motion to dismiss under Rule 12(b)(6) if the complaint fails to allege facts sufficient to “state a claim to relief that is plausible on its face.” Bell Atl. Corp. v. Twombly, 550 U.S. 544, 570 (2007). When

assessing a motion to dismiss under Rule 12(b)(6), the Court must give plaintiff the benefit of the doubt and must accept all the complaint's factual allegations as true. Keys v. Humana, Inc., 684 F.3d 605, 608 (6th

Cir. 2012). In deciding whether to dismiss a case, a court will generally rely only on the facts or claims stated in the complaint. Rondigo, L.L.C. v. Twp. of Richmond, 641 F.3d 673, 680 (6th Cir. 2011) (citations omitted).

However, the Court may consider exhibits attached to the complaint, public records, and motion to dismiss attachments without converting the motion into one for summary judgment so long as the outside

documents are referred to in the complaint and are central to the claims. Id. III. ANALYSIS

The Sixth Circuit has “long differentiated between ‘failure to accommodate’ and ‘disparate treatment’ claims.” Sturgill v. Am. Red Cross, 114 F.4th 803, 811 (6th Cir. 2024) (citations omitted). A failure-to-

accommodate claim is a type of disparate-treatment claim. Id. (citing EEOC v. Abercrombie & Fitch Stores, Inc., 575 U.S. 768, 774–775 (2015)); Savel v. MetroHealth Sys., 96 F.4th 932, 943 n.4 (6th Cir. 2024) (citing

Abercrombie & Fitch). Thus, a disparate-treatment claim that is independent from an accommodation claim must be separately pled. Id. A. Failure to Accommodate

In the context of a Title VII religious discrimination case, a “plaintiff does not have to allege specific facts establishing a prima facie case of discrimination in their complaint.” Savel, 96 F.4th at 943. “If a reasonable court can draw the necessary inference [of discrimination]

from the factual material stated in the complaint, the plausibility standard has been satisfied.” Id. (quoting Keys v. Humana, Inc., 684 F.3d 605, 610 (6th Cir. 2012)).

“The heart of the failure-to-accommodate claim is that an employer discharges (or otherwise discriminates against) an employee for failing a job-related requirement instead of abiding by its ‘statutory obligation to

make reasonable accommodation for the religious observances’ of its employees.” Id. at 943–944 (6th Cir. 2024) (quoting Trans World Airlines, Inc. v. Hardison, 432 U.S. 63, 75 (1977)).

Courts must be cautious in reviewing pleadings involving allegations of religious belief as the “Supreme Court has warned, [r]epeatedly and in many different contexts, that courts must not

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Related

Trans World Airlines, Inc. v. Hardison
432 U.S. 63 (Supreme Court, 1977)
Bell Atlantic Corp. v. Twombly
550 U.S. 544 (Supreme Court, 2007)
Younis v. Pinnacle Airlines, Inc.
610 F.3d 359 (Sixth Circuit, 2010)
Rondigo, L.L.C. v. Township of Richmond
641 F.3d 673 (Sixth Circuit, 2011)
Lloyd v. Crawford, III v. Jack A. Roane
53 F.3d 750 (Sixth Circuit, 1995)
Kathryn Keys v. Humana, Inc.
684 F.3d 605 (Sixth Circuit, 2012)
Barany-Snyder v. Weiner
539 F.3d 327 (Sixth Circuit, 2008)
Shelbi Hindel v. Jon Husted
875 F.3d 344 (Sixth Circuit, 2017)
Frank Savel v. MetroHealth Sys.
96 F.4th 932 (Sixth Circuit, 2024)
Najean Lucky v. Landmark Med. of Mich., P.C.
103 F.4th 1241 (Sixth Circuit, 2024)
Aimee Sturgill v. Am. Red Cross
114 F.4th 803 (Sixth Circuit, 2024)

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