Charlotte Cramer v. PeaceHealth

CourtDistrict Court, D. Oregon
DecidedApril 10, 2026
Docket6:24-cv-01609
StatusUnknown

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

Bluebook
Charlotte Cramer v. PeaceHealth, (D. Or. 2026).

Opinion

IN THE UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF OREGON

EUGENE DIVISION

CHARLOTTE CRAMER, Civ. No. 6:24-cv-01609-AA

Plaintiff, OPINION & ORDER

vs.

PEACEHEALTH,

Defendant.

_______________________________________

AIKEN, District Judge: Plaintiff Charlotte Cramer brings five religious discrimination claims against her former employer, Defendant PeaceHealth, under Title VII of the Civil Rights Act of 1964, 42 U.S.C. § 2000e et seq., and under ORS 659A.030. See Compl., ECF No. 1. Before the Court is Defendant’s motion to dismiss four of Plaintiff’s Title VII and ORS 659A.030 religious discrimination claims. For the reasons stated below, Defendant’s Partial Motion to Dismiss, ECF No.7, is GRANTED. Four of Plaintiff’s Title VII and ORS 659A.030 claims are DISMISSED with leave to amend within 30 days consistent with the following Opinion. BACKGROUND In February 2020, the global COVID-19 pandemic hit Oregon and the United States. In August 2021, the FDA approved the first COVID-19 vaccine. On August 5, 2021, the Oregon Health Authority (“OHA”) issued a rule requiring all Oregon healthcare providers and staff to be fully vaccinated against COVID-19 (the “OHA Vaccine Mandate”) by September 30, 2021, subject to medical or religious exemption as provided under existing federal law. Former OAR 333-019-1010 (Aug. 5, 2021).

“On August 3, 2021, [Defendant] adoption of a formal policy that required all of its Healthcare Workers...to be ‘Fully Vaccinated’ with a COVID-19 vaccine by August 31, 2021 or face discipline up to and including termination[.]” Compl. ¶ 18. At that time, Plaintiff was employed by Defendant as a registered nurse. Id. ¶ 6. In August 2021, Plaintiff asked for a religious exemption to the vaccine because her “sincere Christian religious beliefs” prohibited her from receiving the vaccine, which

would “damage and violate the purity of her bodily temple” and make her “complicit in the grave evil of abortion.” Id. ¶¶ 7,8. In August 2021, Defendant granted Plaintiff a religious exemption to the vaccine mandate and placed her on unpaid administrative leave. Id. ¶ 9. Plaintiff remained on unpaid administrative leave from “September 1, 2021, through at least April 2023.” Id. ¶ 9. LEGAL STANDARD A motion to dismiss under Federal Rules of Civil Procedure 12(b)(6) tests the

sufficiency of the claims. Navarro v. Block, 250 F.3d 729, 732 (9th Cir. 2001). When evaluating the sufficiency of a complaint’s allegations, a court must accept a plaintiff’s allegations of fact as true and construe them in the light most favorable to the plaintiff. Wilson v. Hewlett-Packard Co., 668 F.3d 1136, 1140 (9th Cir. 2012). But a plaintiff’s “[f]actual allegations must be enough to raise a right to relief above the speculative level[.]” Bell Atl. Corp. v. Twombly, 550 U.S. 544, 545 (2007). “[A] plaintiff’s obligation to provide the grounds of his entitlement to relief requires more than labels and conclusions, and a formulaic recitation” of the action’s elements. Id. at 555 (internal quotation marks and citation omitted).

To survive a motion to dismiss, a pleading must allege “sufficient factual matter, accepted as true, to ‘state a claim to relief that is plausible on its face.’” Ashcroft v. Iqbal, 556 U.S. 662, 663 (2009) (quoting Twombly, 550 U.S. at 570). “A claim has facial plausibility when the plaintiff pleads factual content that allows the court to draw the reasonable inference that the defendant is liable for the misconduct alleged. The plausibility standard . . . asks for more than a sheer possibility that a

defendant has acted unlawfully.” Id. at 678. DISCUSSION Plaintiff brings five religious discrimination employment claims under Title VII and ORS 659A.030: (1) failure to accommodate; (2) disparate treatment; (3) disparate impact; (4) hostile work environment; and (5) retaliation. Compl. ¶¶ 51– 97. “A claim for religious discrimination under Title VII can be asserted under several different theories, including disparate treatment and failure to accommodate.”

Peterson v. Hewlett-Packard Co., 358 F.3d 599, 603 (9th Cir. 2004). Plaintiff’s state-law claims under ORS 659A.030 are analyzed together with her Title VII claims. Pullom v. U.S. Bakery, 477 F. Supp. 2d 1093, 1100 (D. Or. 2007) (“Because ORS 659A.030 is modeled after Title VII, plaintiff's state law discrimination claim can be analyzed together with [their] federal discrimination claim.” (citing Heller v. EBB Auto Co., 8 F.3d 1433, 1437 n.2 (9th Cir. 1993); Winnett v. City of Portland, 118 Or. App. 437 (1993)). I. The Claims

Plaintiff first alleges a failure-to-accommodate claim. Compl. ¶ 8. Defendant “does not move to dismiss that claim.” Def. Mot., ECF No. 7., at 1. Defendant moves to dismiss with prejudice the claims for disparate treatment, disparate impact, hostile work environment, and retaliation. Id. A. Disparate Impact

Plaintiff alleges that “[she] is a member of a protected class on the basis of her devout and sincerely held religious beliefs in the tenets of Christianity.” Compl. ¶ 64. Plaintiff alleges that “similarly situated individuals outside Plaintiff’s protected class were treated more favorably than Plaintiff.” Id. ¶ 67. Under Title VII, it is unlawful for an employer “to discharge any individual . . . because of such individual's . . . religion[.]” 42 U.S.C. § 2000e-2(a)(1). Title VII bars an “employment practice that causes a disparate impact on the

basis of . . . religion” unless the employer shows that “the challenged practice is job- related . . . and consistent with business necessity.” Title VII 42 U.S.C. § 2000e- 2(k)(1)(A)(i). A disparate impact claim challenges “employment practices that are facially neutral in their treatment of different groups but that in fact fall more harshly on one group than another and cannot be justified by business necessity.” Stout v. Potter, 276 F.3d 1118, 1121 (9th Cir. 2002). To plead a prima facie case of

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Charlotte Cramer v. PeaceHealth, Counsel Stack Legal Research, https://law.counselstack.com/opinion/charlotte-cramer-v-peacehealth-ord-2026.