Piccolo v. Mayo Clinic

CourtDistrict Court, D. Arizona
DecidedMarch 13, 2025
Docket2:22-cv-02007
StatusUnknown

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

Bluebook
Piccolo v. Mayo Clinic, (D. Ariz. 2025).

Opinion

1 WO 2 3 4 5 6 IN THE UNITED STATES DISTRICT COURT 7 FOR THE DISTRICT OF ARIZONA

9 Nichola J Piccolo, No. CV-22-02007-PHX-DJH

10 Plaintiff, ORDER

11 v.

12 Mayo Clinic, et al.,

13 Defendants. 14 15 Defendant Mayo Clinic Arizona (“Defendant”) seeks summary judgment on all of 16 Plaintiff Nichola Piccolo’s (“Plaintiff”) claims. (Doc. 65). The matter is fully briefed. 17 (Docs. 69–70). The Court will enter summary judgment on Plaintiff’s disparate treatment 18 theory but not her failure to accommodate theory. 19 I. Background1 20 Plaintiff worked as a Registered Nurse for Defendant Mayo from August 2014 until 21 March 2022. (Doc. 65 at 2; Doc. 69 at 1). Mayo notes that Plaintiff “worked with patients 22 about to undergo, or immediately recovering from, surgical procedures, including high- 23 risk surgeries such as organ transplants.” (Doc. 65 at 2). Defendant also notes that, in July 24 2021, Piccolo injured her back at work and she was placed on extended leave and given 25 worker’s compensation. (Id.) 26 After the start of the COVID-19 pandemic, Mayo initiated a voluntary vaccine 27 participation program to help increase vaccination rates among employees; but later 28 1 The following facts are undisputed, unless stated otherwise. 1 announced a vaccine mandate in October of 2021.2 (Doc. 65 at 3). Mayo’s policy required 2 employees to become vaccinated or seek an exemption to continue their employment. (Id.) 3 The only acceptable exemptions Mayo recognized were for medical or religious reasons. 4 (Id.) Plaintiff sought a religious exemption. (Doc. 65 at 5; Doc. 69 at 4). 5 Defendant states that it “developed a multi-step process to approve, deny, or escalate 6 Accommodation Requests.” (Doc. 65 at 3). It sums up its process as follows: 7 Reviewers were instructed to assess the totality of each Accommodation Request to determine whether: (1) the individual identified a religious belief; 8 (2) the religious belief was sincerely held; and (3) the sincerely held religious 9 belief conflicted with the Policy’s vaccination requirement. Reviewers spent as much time as necessary to consider each request’s unique content. No 10 time limits, quotas, or targets applied for approval or denial. No preference 11 or bias applied for or against any particular religious faith or belief; reviewers considered only the sincerity of religious beliefs and whether they conflicted 12 with the Policy. 13 At the first step, an individual reviewer would randomly select an Accommodation Request from a shared inbox and analyze it based on the 14 factors above. Other than name, job site and employee number, the reviewer 15 did not review demographic information about the employee, such as age, race, disability or leave status. The reviewer would approve or deny the 16 Accommodation Request or, in some instances, escalate the request for 17 further consideration. If an employee’s Accommodation Request was denied, the employee could submit a Religious Accommodation 18 Reconsideration Form (“Reconsideration Request”). 19 Trained reconsideration review teams reviewed each Reconsideration 20 Request. The review team reviewed the original Accommodation Request and the notes of the reviewer as well as the Reconsideration Request. The 21 review team did not review other demographic information about the 22 employee, such as age, race, disability or leave status. The review team looked for additional, clarifying information that would justify overturning 23 the denial. 24 If the review team denied the Reconsideration Request, Mayo sent an automated notification to the employee advising of the need to become 25 vaccinated or be placed on a Final Written Warning. 26

27 2 Mayo states that it announced its vaccine mandate on October 13, 2021, in anticipation of the Biden administration’s Centers for Medicare & Medicaid Services (“CMS”) 28 Mandate for healthcare workers, which required employees to be vaccinated but allowed for exemptions for disabilities and sincerely held religious beliefs. (Doc. 65 at 1–3). QUd.) Before returning to work from her back injury, Plaintiff filed a request for a religious 2|| exemption to Defendant’s vaccine mandate on November 7, 2021. (Doc. 65-4). The Court 3 || will restate the relevant portions of this exemption request below: 4 1, What Is the sincerely held religious belief Based on my understanding of Title VII of the Civil or practice for which you are seeking Rights Act, the First Amendment to the United 5 accommodation? States Constitution, | choose ta exercise my right to religious exemption from being required to be 6 vacelnated using Covid-19 shots, My personal convictions are inspired by my study and 7 understanding of the Bible. No one should be made choose between their faith and their 8 livelihood. 9 2. Please provide any information that will | would simply like to say that I'm deeply help us ta determine that your belief is offended by the very question itselfl The fact that 10 sincerely held with the strength of some random person or group, none of which traditional religious views, For example, know me, will be tasked with deciding if I'm does this belief affect any other aspect of =| devoutly religious or not is a sad. To whoever 12 your life? may be reading this, please know that you are in ho position to judge me, my religious beliefs, or my level of devotion to those beliefs! As far as my 13 religious beliefs are concerned, | do not answer 14 to you, | answer only to Ged! 15 3. Has your religious bedief that is preventing | No you from receiving COVID-19 vaccination 16 changed over time? If yes, explain how it has change, when it changed and why. 17 4, Describe the conflict between the religious | According to Scripture my body Is created in the 18 belief or practice and receiving COVID-19 image of God (Genesis 1:27, Genesis 9:6, Genesis vaccine, Provide as much speciflelty as 5:1, 1 Corinthians 11:7, Colossians 3:10, James 19 passible and identify all areas of conflict. 3:9) and is a temple in which God's Spirit dwells. That temple is considered sacred, and we are 30 admonished to do nothing to destroy that temple {1 Corinthians 3:16-17, 1 Corinthians 6:19-20}. | 2] am religiously, morally, and ethically opposed to receiving COVID-19 vaccine. 22 5. Does your religious bellef prevent you Some But Not All Other Vaccines from receiving all vaccines or only some 23 vaccines? 24 a. Please specify (lf your religious | don't randomly just take vaccines. | believe that belief prevents you from receiving | receiving vaccines is a personal decision to seek 25 only specific vaccines, please personal guidance from the Holy Spirit (Acts 2:38- explain why, For example, if there | 39: Romans 8) and search the Scripture myself for 26 is something about the way that related truths (Ramans 15:4). If | fail to submit to some vaccines are developed or the personal convictions that the Holy Spirit and 27 manufactured that prevents you Scripture has impressed upon me, | will be fram receiving them, please sinning against Gad, 28 identify what that is.)

-3-

1 (Doc. 65-4 at 2–3).3 Plaintiff also stated that she is a Roman Catholic, a faith she has been 2 a part of since birth, and that her accommodation request is based, in part, on the use of 3 fetal cell lines.4 (Id. at 4–5). 4 Plaintiff’s request was randomly assigned to a reviewer who denied her request 5 because it contained “[i]nsufficient evidence of a sincerely held religious belief,” and 6 “indicated[d] that it is a personal decision to seek guidance.” (Doc. 65 at 5). On November 7 23, 2021, Plaintiff submitted a Reconsideration Request, which was also randomly 8 assigned to a review team. (Id. at 6). The review team reviewed Plaintiff’s original 9 Accommodation Request, the denial and the Reconsideration Request.

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Piccolo v. Mayo Clinic, Counsel Stack Legal Research, https://law.counselstack.com/opinion/piccolo-v-mayo-clinic-azd-2025.