Sanchez Jr. v. City Of Chicago

CourtDistrict Court, N.D. Illinois
DecidedApril 7, 2025
Docket1:24-cv-01322
StatusUnknown

This text of Sanchez Jr. v. City Of Chicago (Sanchez Jr. v. City Of Chicago) is published on Counsel Stack Legal Research, covering District Court, N.D. Illinois primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Sanchez Jr. v. City Of Chicago, (N.D. Ill. 2025).

Opinion

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION

JULIO SANCHEZ JR., ) ) Plaintiff, ) ) No. 24 C 1322 v. ) ) Judge Sara L. Ellis THE CITY OF CHICAGO, ) ) Defendant. )

OPINION AND ORDER In August 2021, the City of Chicago (the “City”) imposed a vaccine mandate for all of its employees. Plaintiff Julio Sanchez Jr., a firefighter for the City, objected to receiving the COVID-19 vaccine on religious grounds and sought a religious exemption. While one of his exemption requests remained pending, however, he received the COVID-19 vaccine and continued his work uninterrupted. He then filed this lawsuit against the City, contending that the City failed to accommodate him and retaliated against him in violation of Title VII; violated the First Amendment, the Due Process Clause of the Fourteenth Amendment, and the Illinois Health Care Right of Conscience Act; and intentionally or negligently inflicted emotional distress. The City has moved to dismiss Sanchez’s claims for lack of subject matter jurisdiction and failure to state a claim pursuant to Federal Rules of Civil Procedure 12(b)(1) and (b)(6). Because Sanchez voluntarily chose to comply with the vaccine mandate despite having a pending exemption request, he did not suffer an injury in fact and so the Court must dismiss Sanchez’s amended complaint for lack of standing. BACKGROUND1 Sanchez has worked for the City as a firefighter/EMT for over fifteen years. As a Christian, he maintains sincerely held religious beliefs, including that he should not receive the COVID-19 vaccine.

In August 2021, the City adopted a COVID-19 vaccination policy that required all employees to receive the COVID-19 vaccine or else the City would place the non-complying employees on non-pay status. The policy provided for medical and religious exemptions. On October 10, 2021, Sanchez contacted the City’s human resources department (“HR”) with questions about the policy, expressing his concerns regarding the COVID-19 vaccine. His email included seventeen questions, but HR only responded to one. On November 23, 2021, Sanchez submitted an exemption request, citing to the Illinois Health Care Right of Conscience Act and requesting an exemption from the COVID-19 vaccine requirement based on his religious beliefs. HR responded by email on December 3, 2021, asking for more information, including Sanchez’s reason for seeking a religious exemption, the duration

of Sanchez’s religious practices, and whether his beliefs also gave rise to objections to other vaccines and medications. HR additionally requested that Sanchez complete a fetal cell form. On December 15, 2021, HR denied Sanchez’s initial exemption request, indicating that he did not provide the requested information. Sanchez then submitted the additional information, except for the fetal cell form, to HR on December 19, 2021, along with a second exemption request. Sanchez followed up on this request several times, and he ultimately received notice of

1 The Court takes the facts in this section from the amended complaint and presumes they are true for the purpose of resolving this motion. See Virnich v. Vorwald, 664 F.3d 206, 212 (7th Cir. 2011); Local 15, Int’l Bhd. of Elec. Workers, AFL-CIO v. Exelon Corp., 495 F.3d 779, 782 (7th Cir. 2007). The Court also considers the additional materials submitted by the parties when considering the motion to dismiss pursuant to Rule 12(b)(1). See Apex Digit., Inc. v. Sears, Roebuck & Co., 572 F.3d 440, 443–44 (7th Cir. 2009). a denial on December 28, 2021. That denial indicated that those employees who did not meet the vaccination requirement within six weeks of the denial of their exemption request may face non-disciplinary, non-pay status. Sanchez then submitted a third exemption request on January 3, 2022, which he treated as

a new request. He did not receive an acknowledgment of the request from HR. Given the uncertainty over the status of his exemption request and the deadline to comply with the vaccination policy, Sanchez decided to receive the first dose of the COVID-19 vaccine on January 5, 2022. That same day, he filed a union grievance regarding the vaccination, and he sought out assistance from the EEOC the following day. He also reached out to HR, the EEOC, the Chicago Fire Department’s chain of command, and the City’s Office of the Inspector General about his objections to receiving the vaccine. He did not receive substantive responses from these departments. Therefore, on February 10, 2022, Sanchez received the second dose of the COVID-19 vaccine. Sanchez never received a decision from HR on his third exemption request. LEGAL STANDARD

A motion to dismiss under Rule 12(b)(1) challenges the Court’s subject matter jurisdiction. Fed. R. Civ. P. 12(b)(1). The standard of review for a Rule 12(b)(1) motion to dismiss depends on whether the defendant raises a facial or factual challenge. Silha v. ACT, Inc., 807 F.3d 169, 173 (7th Cir. 2015). If a defendant challenges the sufficiency of the allegations regarding subject matter jurisdiction—a facial challenge—the Court “must accept all well- pleaded factual allegations as true and draw all reasonable inferences” in the plaintiff’s favor. Id. “[W]hen evaluating a facial challenge to subject matter jurisdiction,” the Court employs the Twombly–Iqbal “plausibility” standard, “which is the same standard used to evaluate facial challenges to claims under Rule 12(b)(6).” Id. at 174. If, however, the defendant contests the truth of the jurisdictional allegations—a factual challenge—the Court may look beyond the pleadings and view any competent proof submitted by the parties to determine if the plaintiff has established subject matter jurisdiction by a preponderance of the evidence. See id. at 173; Apex, 572 F.3d at 444–45; Meridian Sec. Ins. Co. v. Sadowski, 441 F.3d 536, 543 (7th Cir. 2006).

A motion to dismiss under Rule 12(b)(6) challenges the sufficiency of the complaint, not its merits. Fed. R. Civ. P. 12(b)(6); Gibson v. City of Chicago, 910 F.2d 1510, 1520 (7th Cir. 1990). In considering a Rule 12(b)(6) motion, the Court accepts as true all well-pleaded facts in the plaintiff’s complaint and draws all reasonable inferences from those facts in the plaintiff’s favor. Kubiak v. City of Chicago, 810 F.3d 476, 480–81 (7th Cir. 2016). To survive a Rule 12(b)(6) motion, the complaint must assert a facially plausible claim and provide fair notice to the defendant of the claim’s basis. Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009); Bell Atl. Corp. v. Twombly, 550 U.S. 544, 555 (2007); Adams v. City of Indianapolis, 742 F.3d 720, 728–29 (7th Cir. 2014).

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Sanchez Jr. v. City Of Chicago, Counsel Stack Legal Research, https://law.counselstack.com/opinion/sanchez-jr-v-city-of-chicago-ilnd-2025.