Culver v. Factory Mutual Insurance Company (FMIC aka "FM Global")

CourtDistrict Court, E.D. Texas
DecidedSeptember 26, 2024
Docket6:22-cv-00444
StatusUnknown

This text of Culver v. Factory Mutual Insurance Company (FMIC aka "FM Global") (Culver v. Factory Mutual Insurance Company (FMIC aka "FM Global")) is published on Counsel Stack Legal Research, covering District Court, E.D. Texas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Culver v. Factory Mutual Insurance Company (FMIC aka "FM Global"), (E.D. Tex. 2024).

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF TEXAS No. 6:22-cv-00444 Diane Culver et al., Plaintiffs, V. Factory Mutual Insurance Company, Defendant.

OPINION AND ORDER Plaintiffs Diane Culver, Alan Maner, Carter Whiteside, and Tyler Smith filed the present lawsuit on behalf of themselves and all others similarly situated, alleging that Factory Mutual Insur- ance Company (“FM Global”) discriminated against them and others based upon their religion in violation of Title VII of the Civil Rights Act of 1964. Doc. 1. The case was referred to United States Magistrate Judge K. Nicole Mitchell pursuant to 28 U.S.C. § 636(b)(1). Doc. 3. Defendant moved to dismiss each of plaintiffs’ claims of a hos- tile work environment for failure to exhaust administrative reme- dies. Doc. 26 at 1. Defendant also moved to dismiss all of plaintiff Tyler Smith’s claims for failure to state a claim. Jd. On May 30, 2024, the magistrate judge issued a report recommending that each of the plaintiffs’ claims for hostile work environment be dis- missed without prejudice and that plaintiff Tyler Smith’s claims for disparate treatment, failure to accommodate, retaliation, and disparate impact be dismissed without prejudice. Doc. 49 at 22. The magistrate judge recommended that Smith be granted leave to file an amended complaint that included further information regarding Smith’s religious discrimination claims. Jd. Plaintiffs submitted objections to the report, as well as a notice of supple- mental authority. Docs. 50, 51. Defendant submitted a response to the objections. Doc. 52. The court reviews objected portions

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of the magistrate judge’s report and recommendation de novo. See Fed. R. Civ. P. 72; 28 U.S.C. § 636(b)(1). I. Tyler Smith’s religious discrimination claims Plaintiffs first object to the magistrate judge’s recommenda- tion that Smith’s religious discrimination claims be dismissed without prejudice. Doc. 50 at 5. Smith states that in his exemption request, he “went into great detail about how taking the COVID- 19 vaccine would be in conflict with all four of the core virtues of his religion: Stoicism.” Doc. 1 ¶¶ 136–37. He further explains that “[i]n order to live in harmony with the Divine Reason, the follow- ers of Stoicism—an ancient tradition dating back to the Greeks— cannot violate the core teachings of the religion.” Id. ¶ 137. Smith does not allege facts regarding how taking the COVID-19 vaccine violates Stoicism’s four core virtues or what those core virtues are. In order to state a prima facie claim of religious discrimina- tion, a plaintiff must allege that: “(1) [he] held a bona fide reli- gious belief, (2) [his] belief conflicted with a requirement of [his] employment, (3) [his] employer was informed of [his] belief, and (4) [he] suffered an adverse employment action for failing to com- ply with the conflicting employment requirement.” Davis v. Fort Bend Cnty., 765 F.3d 480, 485 (5th Cir. 2014). Plaintiffs argue that Smith does not need to explain in the complaint how his beliefs conflicted with the vaccine requirement because, under Davis, he need only allege that the religious belief did conflict. Doc. 27 at 25. According to plaintiffs, requiring Smith to explain how his beliefs conflicted would constitute “a collateral attack” on the validity of those beliefs. Id. at 26. Plaintiffs further state that, even if Smith does need to allege how his beliefs con- flicted with the vaccine mandate, he has already done so. Doc. 26 at 25. Plaintiffs cite several cases, including the Eighth Circuit’s re- cent opinion in Ringhofer v. Mayo Clinic, Ambulance, 102 F.4th 894 (8th Cir. 2024), and the Sixth Circuit’s recent opinion in Lucky v. Landmark Medical of Michigan, 103 F.4th 1241 (6th Cir. 2024), to support the proposition that requiring Smith to plead facts con- necting his objection to the COVID-19 vaccine to his religion of Stoicism invites improper judicial inquiry into the sincerity of Smith’s religious beliefs. Doc. 50 at 9–10; Doc. 51 at 1–2. In Ringhofer, the plaintiffs alleged that “the vaccination re- quirements conflicted with their Christian beliefs because: (1) ac- cording to Scripture, their ‘body is a temple’ they must respect and protect, and (2) their anti-abortion beliefs, rooted in religion, prevent using a product ‘produced with or tested with fetal cell lines.’” Ringhofer, 102 F.4th at 898. The Eighth Circuit reversed the district court’s dismissal of the plaintiffs’ Title VII claims and held that the plaintiffs had adequately identified the religious views they believed to conflict with taking the COVID-19 vaccine. Id. at 901. Two of the plaintiffs in Ringhofer also alleged that their company’s COVID-19 testing requirement conflicted with their religious beliefs. Id. at 902. One plaintiff alleged that testing vio- lated her belief that “her body is a temple,” and one plaintiff al- leged that testing was “the equivalent of committing idolatry.” Id. The Eighth Circuit held that these plaintiffs plausibly pleaded that their religious beliefs conflicted with the testing requirement. Id. The court concluded that, “[b]y connecting their objection to testing to specific religious principles,” the plaintiffs satisfied their burden at the pleading stage. Id. The plaintiff in Lucky also pleaded specific facts supporting her contention that vaccination conflicted with an aspect of her religious beliefs. She pleaded that she is a non-denominational Christian who believes she “should not have any vaccination enter her body such that her body would be defiled, because her body is a temple.” Lucky, 103 F.4th at 1242. She further stated that she “seeks to make all decisions, especially those regarding vaccina- tion and other medical decisions, through prayer.” Id. Lucky pleaded that she “prayed to God specifically about the COVID-19 vaccine” and that God told her “that she would suffer spiritual harm if she received the COVID-19 vaccine.” Id. The Sixth Cir- cuit stated that the district court had no basis “for its insistence that Lucky explain how ‘her religion has a specific tenet or princi- ple that does not permit her to be vaccinated.’” Id. at 1243. Lucky’s “allegations of particular facts” (that she prayed, she re- ceived an answer, and she acted accordingly) were “almost self- evidently enough to establish, at the pleadings stage, that her re- fusal to receive the vaccine was an ‘aspect’ of her religious ob- servance or belief.” Id. Here, in comparison, Smith did not sufficiently allege a con- flict between his religious beliefs and FM Global’s vaccine man- date. He stated that receiving the vaccine “would be in conflict with all four core virtues of his religion” but did not state what those core virtues are or how the vaccine conflicts with them. Doc. 1 ¶ 137. Nor did the magistrate judge scrutinize the sincerity of Smith’s beliefs. Smith—unlike the plaintiffs in Ringhofer and Lucky—did not plead to this court facts “connecting [his] objec- tion to [vaccination] to specific religious principles.” Ringhofer, 102 F.4th at 902. That Smith must allege how his religious beliefs conflicted with an employment requirement is further illustrated by Arza- mendi v. Austin, a recently decided case from the Northern Dis- trict of Texas. No. 4:23-cv-0770-P, 2024 WL 1641962, at *3 (N.D. Tex. Apr. 16, 2024).

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Culver v. Factory Mutual Insurance Company (FMIC aka "FM Global"), Counsel Stack Legal Research, https://law.counselstack.com/opinion/culver-v-factory-mutual-insurance-company-fmic-aka-fm-global-txed-2024.