Sanchez v. Rock Island County Health Department

CourtDistrict Court, C.D. Illinois
DecidedMay 12, 2025
Docket4:23-cv-04007
StatusUnknown

This text of Sanchez v. Rock Island County Health Department (Sanchez v. Rock Island County Health Department) is published on Counsel Stack Legal Research, covering District Court, C.D. Illinois primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Sanchez v. Rock Island County Health Department, (C.D. Ill. 2025).

Opinion

UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF ILLINOIS ROCK ISLAND DIVISION

ALEXANDRA SANCHEZ, DEANNA ) BRUMBAUGH, DIANA ALLEN, and ) SHERI DUHME, ) ) Plaintiffs, ) ) v. ) Case No. 4:23-cv-04007-SLD ) ROCK ISLAND COUNTY HEALTH ) DEPARTMENT and ROCK ISLAND ) COUNTY, ILLINOIS, ) ) Defendants. )

ORDER

Before the Court is a motion to bar the expert of Defendant Rock Island County Health Department (“RICHD”) filed by Plaintiffs Alexandra Sanchez, Deanna Brumbaugh, Diana Allen, and Sheri Duhme, ECF No. 37. For the following reasons, the motion is GRANTED IN PART and DENIED IN PART. BACKGROUND Plaintiffs, former employees of a local government public health agency, each filed suit against RICHD and Rock Island County, Illinois (“the County”) alleging that their previous employer, RICHD, violated Title VII of the Civil Rights Act of 1964 (“Title VII”), 42 U.S.C. §§ 2000e–2000e-17. Each case has been consolidated into this action. See Feb. 9, 2023 Text Order; Feb. 3, 2023 Order, Brumbaugh v. Rock Island Cnty. Health Dep’t, 4:23-cv-04020-SLD-JEH, ECF No. 3 (Hawley, M.J.); May 3, 2023 Order, Allen v. Rock Island Cnty. Health Dep’t, 4:23- cv-04066-SLD-JEH, ECF No. 3 (Hawley, M.J.); May 3, 2023 Order, Duhme v. Rock Island Cnty. Health Dep’t, 4:23- cv-04067-SLD-JEH, ECF No. 3 (Hawley, M.J.). The purported violations stem from their employer’s failure to accommodate their religious beliefs, first, when it denied their exemptions from a COVID-19 vaccination requirement, and later when Plaintiffs were terminated for failing to get vaccinated. See generally Am. Compl., ECF No. 27. The Court denied motions to dismiss filed by RICHD and the County, Aug. 9, 2023 Order, ECF No. 16; Sept. 20, 2024 Order, ECF No. 32, and the parties are now completing discovery.

Pursuant to Federal Rule of Civil Procedure 26, RICHD disclosed an expert witness, Dr. Ramzi Asfour. Def.’s Expert Disclosure, Mot. Bar Expert Ex. 1, ECF No. 37-1 at 1–2. Dr. Asfour was asked to “provide his opinion concerning the proper approach of a public health entity to evaluating requests from employees to be exempted from” vaccination requirements and to provide epidemiological evidence related to vaccine efficacy compared to other mitigation methods. Id. at 1. Plaintiffs filed the instant motion to bar Dr. Asfour, arguing that his opinion violates the standards of Federal Rules of Evidence 702 and 704. See generally Mot. Bar Expert; Mem. Supp. Mot. Bar Expert, ECF No. 38. RICHD opposes the motion. Resp. Mot. Bar Expert 1, ECF No. 39. DISCUSSION

I. Legal Standard Exclusion of expert testimony is governed by Federal Rule of Evidence 702 and Daubert v. Merrell Dow Pharmaceuticals, Inc., 509 U.S. 579 (1993). Rule 702 provides that a qualified witness—one with the appropriate knowledge, skill, experience, training, or education—may testify in the form of an opinion if: (a) the expert’s scientific, technical, or other specialized knowledge will help the trier of fact to understand the evidence or to determine a fact in issue;

(b) the testimony is based on sufficient facts or data;

(c) the testimony is the product of reliable principles and methods; and (d) the expert’s opinion reflects a reliable application of the principles and methods to the facts of the case.

Fed. R. Evid. 702. To determine whether an opinion is admissible, the court must consider whether (1) the witness is qualified; (2) the expert’s methodology is reliable; and (3) the testimony is relevant in that it will assist the trier of fact to understand the evidence or determine a fact in issue. Kirk v. Clark Equip. Co., 991 F.3d 865, 872 (7th Cir. 2021). The party seeking to admit the expert’s testimony must show that it satisfies these standards by a preponderance of the evidence. Gopalratnam v. Hewlett-Packard Co., 877 F.3d 771, 782 (7th Cir. 2017). II. Analysis Plaintiffs argue that the opinion of Dr. Asfour is inadmissible for various reasons—most of which invoke Rule 702. They begin by arguing that the content of the opinion falls outside the scope of Dr. Asfour’s expertise, so he is not qualified to provide the opinion. Mem. Supp. Mot. Bar Expert 2–3. Plaintiffs then contend that the opinion is riddled with legal conclusions, offends the principles of Rule 704, and abrogates the role of a jury. Id. at 6–8, 11–14. Pointing to the standards under Rule 702(d), they briefly argue that Dr. Asfour’s opinion falls short of what is required for reliability, id. at 6, and then that the opinion will not aid the trier of fact, id. at 3–4, 8–11. RICHD responds to these arguments, first explaining how the proffered expert opinion meets the standards under Rule 702, and then refuting or dismissing the remaining contentions. See generally Resp. Mot. Bar Expert. Parts of Plaintiffs’ motion relate to different

statements contained within the opinion, and some of the arguments attack the opinion in its entirety. See generally Mem. Supp. Mot. Bar Expert. Arguments related to specific statements will be addressed first. a. Whether the Statements Fall Outside of Dr. Asfour’s Expertise Plaintiffs attempt to limit the introduced statements by arguing that Dr. Asfour is not qualified to provide some of the opinion. Mem. Supp. Mot. Bar Expert 2–3. They state that Dr. Asfour is a medical doctor with an expertise in public health who “is not qualified to render . . .

opinions regarding religion or religious exemptions.” Id. The following statements are at issue: [M]ost religious exemption requests for COVID-19 vaccination should be carefully scrutinized. Many major religious organizations publicly endorsed vaccination, recognizing the collective responsibility to protect vulnerable populations. Given this widespread support, religious exemptions should generally be denied unless there is a clear and specific doctrinal basis for objection.

Report of Dr. Asfour 12, Mot. Bar Expert Ex. 2, ECF No. 37-1 at 3–15. As stated, the Federal Rules of Evidence permit an expert witness to testify “in the form of an opinion” if, as relevant here, the witness “is qualified as an expert by knowledge, skill, experience, training, or education.” Fed. R. Evid. 702. The scope of an expert’s qualification is limited to the subject area in which the expert possesses expertise. See United States v. Hall, 93 F.3d 1337, 1343 (7th Cir. 1996) (“[T]he opinion must be an expert opinion (that is, an opinion informed by the witness’s expertise) rather than simply an opinion broached by a purported expert.” (quotation marks omitted)); Gayton v. McCoy, 593 F.3d 610, 616 (7th Cir. 2010) (“Whether a witness is qualified as an expert can only be determined by comparing the area in which the witness has superior knowledge, skill, experience, or education with the subject matter of the witness’s testimony.” (quotation marks omitted)).

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Bluebook (online)
Sanchez v. Rock Island County Health Department, Counsel Stack Legal Research, https://law.counselstack.com/opinion/sanchez-v-rock-island-county-health-department-ilcd-2025.