McDowell v. Valley Health System

CourtDistrict Court, W.D. Virginia
DecidedMay 21, 2025
Docket5:25-cv-00002
StatusUnknown

This text of McDowell v. Valley Health System (McDowell v. Valley Health System) is published on Counsel Stack Legal Research, covering District Court, W.D. Virginia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
McDowell v. Valley Health System, (W.D. Va. 2025).

Opinion

“AT CHARLOTTESVILLE, VA May 21, 2025 IN THE UNITED STATES DISTRICT COURT ee FOR THE WESTERN DISTRICT OF VIRGINIA DEPUTY CLERK HARRISONBURG DIVISION

Douglas Bradford McDowell, ) Plaintiff, Civil Action No. 5:25-cv-00002 Valley Health System, Defendant.

MEMORANDUM OPINION Plaintiff Douglas Bradford McDowell lost his job with Defendant Valley Health System (“Valley Health’) after he failed to comply with Valley Health’s COVID-19 vaccination policy. In this lawsuit, he alleges that Valley Health violated Title VU of the Civil Rights Act of 1964 and the Virginia Human Rights Act (“VHRA”) by denying his request for a religious accommodation to the policy and discriminating against him based on his religious beliefs. This matter is before the court on Valley Health’s motion to dismiss Counts I, IH, and of McDowell’s amended complaint and strike his request for combined punitive damages under Title VII and the VHRA (Dkt. 12). Valley Health argues that McDowell’s Title VII claims are untimely and that he may not bring a failure-to-accommodate claim under the VHRA. For the reasons outlined below, the court agrees that McDowell’s Title VII claims are time-barred but concludes that a failure-to-accommodate claim is cognizable under the VHRA. Accordingly, Valley Health’s motion to dismiss will be granted in part and denied in

part. Because the court will dismiss McDowell’s Title VII claims with prejudice, Valley Health’s motion to strike is moot. I. Background

The facts in this section are taken from McDowell’s amended complaint and are accepted as true when resolving the motion to dismiss. See Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009). McDowell is a registered nurse and former employee at Winchester Medical Center, which is part of Valley Health. (Am. Compl. ¶¶ 11–12 (Dkt. 10).) In July 2021, while McDowell worked for Valley Health, the company announced that it would require all

employees to receive the COVID-19 vaccine. (Id. ¶ 13.) McDowell requested a religious accommodation to the vaccination requirement on the ground that it conflicted with his Christian faith. (Id. ¶¶ 17–22.) Valley Health denied McDowell’s request but granted religious exemptions to several other employees who he alleges are similarly situated. (Id. ¶¶ 23–30.) Valley Health then terminated McDowell’s employment on September 24, 2021, for his failure to receive the vaccine. (Id. ¶ 32.)

On November 23, 2021, McDowell filed charges of discrimination with the U.S. Equal Employment Opportunity Commission (“EEOC”) and the Virginia Office of the Attorney General Office of Civil Rights (“OCR”).1 (Id. ¶ 35.) He received a Notice of Right to Sue letter from the EEOC on September 13, 2022, and one from OCR on March 1, 2023. (Id. ¶¶ 36–37.)

1 McDowell’s amended complaint states that he filed a charge of discrimination with the EEOC and OCR on November 23, 2022. (Am. Compl. ¶ 35.) Because that date falls after the date he states he received the Notice of Right to Sue letter from the EEOC, (see id. ¶ 36), the court assumes that McDowell made a typographical error and that he actually filed the charges of discrimination on November 23, 2021. McDowell sued Valley Health in the Circuit Court of Warren County, Virginia, on December 12, 2022. (Id. ¶ 38; see Pl.’s Resp. to Def.’s Mot. for Partial Dismissal of Compl. & Mot. to Strike Request for Combined Punitive Damages at 2 (Dkt. 18).) His complaint in that

case alleged two causes of action under the VHRA: one count alleging that Valley Health failed to accommodate his religious beliefs and one count alleging disparate-treatment discrimination based on religion. (See Am. Compl. ¶ 38.) The complaint evidently did not allege any claims under Title VII. (See id.) McDowell nonsuited the action on October 7, 2024. (Id. ¶ 39.) On December 6, 2024, McDowell filed a new action against Valley Health in the Circuit Court for the City of Winchester, Virginia. (Id. ¶ 40; see Notice of Removal Ex. 1 (Dkt. 1-2)

[hereinafter “State Compl.”].) As he had in the nonsuited Warren County case, he asserted claims arising from the denial of his religious accommodation request and the termination of his employment. In addition to re-alleging both VHRA claims, he added claims alleging failure to accommodate and disparate treatment under Title VII. (State Compl. ¶¶ 33–71.) Valley Health removed the case to this court on January 13, 2025. (Dkt. 1.) It moved to dismiss McDowell’s complaint and strike his request for “combined punitive damages.”

(Dkt. 7.) McDowell then filed an amended complaint as a matter of course, which mooted the motion to dismiss. (See Dkt. 11.) McDowell’s amended complaint alleges the same four causes of action as his original complaint. He requests both compensatory damages and punitive damages “in the amount of $350,000 either from [Valley Health’s] violation [of] state law or for its violation [of] federal law or both for a total of $350,000 or $700,000.” (Am. Compl. ¶ 82.) On February 21, 2025, Valley Health moved to dismiss McDowell’s two Title VII claims (Counts I and III) and his VHRA failure-to-accommodate claim (Count II) and moved to strike his request for combined punitive damages.2 (Def.’s Mot. for Partial Dismissal of

Am. Compl. & Mot. to Strike Request for Combined Punitive Damages (Dkt. 12) [hereinafter “Mot. to Dismiss and Strike”].) II. Standard of Review A motion to dismiss under Rule 12(b)(6) tests the legal sufficiency of a complaint. Edwards v. City of Goldsboro, 178 F.3d 231, 243 (4th Cir. 1999). “To survive a motion to dismiss, a complaint must contain sufficient factual matter, accepted as true, to ‘state a claim to relief

that is plausible on its face.’” Iqbal, 556 U.S. at 678 (quoting Bell Atl. Co. v. Twombly, 550 U.S. 544, 570 (2007)). A claim satisfies the plausibility standard “when the plaintiff pleads factual content that allows the court to draw the reasonable inference that the defendant is liable for the misconduct alleged.” Id. When reviewing a Rule 12(b)(6) motion to dismiss, the court must “accept as true all well-pleaded facts in a complaint and construe them in the light most favorable to the plaintiff.” Wikimedia Found. v. Nat’l Sec. Agency, 857 F.3d 193, 208 (4th Cir.

2017). Because a Rule 12(b)(6) motion tests the sufficiency of a complaint, it generally is not a proper vehicle for raising affirmative defenses that a defendant has the burden of proving, “such as the defense that the plaintiff’s claim is time-barred.” Goodman v. Praxair, Inc., 494 F.3d 458, 464 (4th Cir. 2007) (en banc). However, the court may consider a statute-of-

2 Valley Health does not move to dismiss Count IV, which alleges disparate treatment in violation of the VHRA. limitations defense in the context of a Rule 12(b)(6) motion “if all facts necessary to the affirmative defense clearly appear on the face of the complaint.” Id. (cleaned up). III. Analysis

Valley Health argues that McDowell’s two Title VII claims (Counts I and III) are time- barred because he did not file his current lawsuit within 90 days of receiving the EEOC Notice of Right to Sue letter, as required by 42 U.S.C. § 2000e-5(f)(1). It argues that the court also should dismiss McDowell’s VHRA failure-to-accommodate claim (Count II) because, at the time of the events in this case, the VHRA did not require employers to provide reasonable accommodations for employees’ religious beliefs. Finally, Valley Health asks the court to

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McDowell v. Valley Health System, Counsel Stack Legal Research, https://law.counselstack.com/opinion/mcdowell-v-valley-health-system-vawd-2025.