Hamil v. Acts Westminster

CourtDistrict Court, S.D. Alabama
DecidedFebruary 26, 2025
Docket1:22-cv-00366
StatusUnknown

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

Bluebook
Hamil v. Acts Westminster, (S.D. Ala. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF ALABAMA SOUTHERN DIVISION SLOAN HAMIL, et al., ) Plaintiffs, ) ) v. ) CIVIL ACTION No. 22-00366-KD-B ) ACTS RETIREMENT-LIFE ) COMMUNITIES INC., et al., ) Defendants. ) ORDER This action is before the Court on cross motions for summary judgment. (Docs 94 and 96). The plaintiffs are former employees Acts Retirement-Life Communities, Inc. (“Acts”), specifically they worked in the skilled nursing unit at Westminster Village in Spanish Fort, AL. Plaintiffs were terminated when they failed to receive a COVID-19 vaccination as required by their employer. Plaintiffs claim that Acts discriminated against them based on their religious belief that they should not receive the COVID-19 vaccination. Acts moves for summary judgment claiming, inter alia, it is a religious organization that is exempt from the religious discrimination claims of the plaintiffs. The Court agrees. Acts is a 501(c)(3) that provides retirement age individuals housing and care depending on their needs. Acts provides independent living, assisted living and skilled nursing units. Acts began in Fort Washington, Pennsylvania as a ministry of the Church of the Open Door. Acts’ original name was Open Door Estates. Acts now provides its services in several locations across the United States. Acts is no longer directly associated with the Church of the Open Door. However, Acts claims to continue its Christian mission. Acts bylaws include a doctrinal statement that reads: The Corporation shall subscribe to the Holy Scriptures -- both the Old and New Testaments--as its only rule of faith and practice, and adhere to the Historical Christianity and the conservative doctrines taught in the Scriptures and further expressed in the Apostles’ Creed: I believe in God the Father Almighty, Maker of heaven and earth and in Jesus Christ, His only Son, our Lord, who was conceived by the Holy Ghost, born of the Virgin Mary, suffered under Pontius Pilate, was crucified, died and was buried; He descended into hell; the third day He arose from the dead; He ascended into heaven, and sitteth on the right hand of God the Father Almighty; from thence He shall come to judge the quick and the dead. I believe in the Holy Ghost, the holy catholic church, the communion of saints, the forgiveness of sins, the resurrection of the body and life everlasting. Amen. (Doc. 98-4). The bylaws also require Acts’ Board of Directors to fully support the doctrinal statement and live their lives in accordance with the Bible.1 Acts includes a time of prayer during each board meeting. Acts Mission Statement reads: 1 Plaintiffs object to the excerpt of the bylaws as not having proper foundation. In response, Defendants attached to its Reply the excerpt from the bylaws and a declaration by Jeremy Neely, Senior Vice President of Operations and Chief Community Operations Officer, as an authenticating witness to the excerpt. Plaintiffs then moved to strike Acts’ Declaration and the substantive information, i.e. the excerpt from the bylaws. (Doc. 112). Plaintiffs claim that neither the “substantive information contained in his declaration”, nor Jeremy Neely’s name as a witness was given to them during the litigation of this case. (Id.). Federal Rule of Civil Procedure 37(c)(1) states: “If a party fails to provide information or identify a witness as required by Rule 26(a) or (e), the party is not allowed to use that information or witness to supply evidence on a motion, at a hearing, or at a trial, unless the failure was substantially justified or is harmless.” Fed. R. Civ. P. 37 (c)(1). Plaintiffs have not met their burden to show that the information or the authenticating witness was not disclosed. On September 2, 2024, Acts filed served its Second Supplemental Disclosures. (Doc. 63). In the disclosures, Acts served notice of potential future use of “witnesses needed to authenticate documents.” (Doc. 115-1 at p. 5, ¶ A. 12.). Although he is not specifically named, Jeremy Neely falls into this category as his declaration only authenticated the excerpts from Acts’ bylaws. The disclosures also included a “description by category” of documents that may be used to support its Acts’ “claims or defenses” as “[a]ny documents pertaining to Defendants’ status as religious organizations exempting them from claims of religious discrimination, including failure to accommodate, under Title VII.” (Doc. 115-1 at p. 6, ¶ B. 15.). While not specifically naming Acts’ bylaws as a part of this category, the description of the information is an adequate disclosure that Acts possessed documents to be used to support its argument for the Title VII exemption for religious organizations. Therefore, Plaintiffs’ Motion to Strike is DENIED. Acts is committed to providing security and peace of mind to seniors by being a preeminent provider of retirement-life services, responsive to individual, social, personal, health, and spiritual needs in a Christian atmosphere graced with Loving-Kindness, dignity, sensitivity, honesty, and respect without prejudice or preference. (Doc. 98-3 at p. 3). Acts also has a “Loving-Kindness Statement” that declares: The Acts Culture of Loving-Kindness is based on the extension of God’s grace, goodness, mercy, and love without prejudice to others. Acts embraces Loving- Kindness, recognizing the inherent value in others through an attitude of respect and acceptance, without favor. Acts is committed to following God’s directives to care for seniors and, in so doing, glorifying Him through intent, purpose and righteous justice. (Id.). According to Acts, the name Acts was derived from the Book of Acts, a book in the New Testament of the Bible. Specifically, Acts finds its mission in Acts 6:1-6 wherein seven men that were filled with the holy spirit and wisdom were ordained to care for widows. Acts also has a chaplain at each location that provides spiritual counseling and conducts worship services and Bible studies. All chaplains are under the leadership of the Corporate Director of Spiritual Development for Acts. The Corporate Director of Spiritual Development is required to have a Master of Divinity or a similar degree from a seminary and provides pastoral care to Acts’ employees. This action arises out of Acts’ Westminster Village (“Westminster”) in Spanish Fort, Alabama. The plaintiffs were employees in the skilled nursing unit during the COVID-19 pandemic. As was common in nursing homes, Acts had residents that were hospitalized with the virus or died from the virus. In response to the pandemic, Acts put together a Clinical Task Force. The members of this task force were Acts’ President Karen Christiansen, Chief Human Resources Officer Deidre Groenen, Vice President and Chief Medical Director Dr. Paul Reinbold, and Senior Vice President and Chief Clinical Officer Holly Schade. The Clinical Task Force met twice each day and was focused on providing the care and protection for the residents and following the guidelines set out by local and federal government authorities. Once the COVID-19 vaccine rollout began, nursing home employees and patients were among those who were first eligible to receive the vaccine. Acts sent out a letter to its employees in July 2021 stating that receiving the vaccine would be required by November 1, 2021.

Acts also provided a process for employees to request exemption. To review religious exemption requests for the vaccine, Acts formed a committee that was led by Iain Crichton, the Corporate Director of Spiritual Development. At first, the religious exemption requests were granted generously.

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Bluebook (online)
Hamil v. Acts Westminster, Counsel Stack Legal Research, https://law.counselstack.com/opinion/hamil-v-acts-westminster-alsd-2025.