Strandquist v. Washington State Department of Social and Health Services

CourtDistrict Court, W.D. Washington
DecidedAugust 26, 2025
Docket3:23-cv-05071
StatusUnknown

This text of Strandquist v. Washington State Department of Social and Health Services (Strandquist v. Washington State Department of Social and Health Services) is published on Counsel Stack Legal Research, covering District Court, W.D. Washington primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Strandquist v. Washington State Department of Social and Health Services, (W.D. Wash. 2025).

Opinion

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4 5 UNITED STATES DISTRICT COURT 6 WESTERN DISTRICT OF WASHINGTON AT TACOMA 7 RANDALL J STRANDQUIST, Case No. 3:23-cv-05071-TMC 8 Plaintiff, ORDER ON SUPPLEMENTAL MOTIONS 9 IN LIMINE v. 10 WASHINGTON STATE DEPARTMENT 11 OF SOCIAL AND HEALTH SERVICES, 12 Defendant. 13

14 Before the Court are Plaintiff Randall J. Strandquist’s and Defendant Washington State 15 Department of Social and Health Services’ (“DSHS”) motions in limine (Dkt. 226, 229). The 16 Court has considered the parties’ briefs and oral arguments. The motion is ripe for the Court’s 17 consideration. 18 I. BACKGROUND 19 This case arises from Strandquist’s termination of employment with DSHS after he 20 declined to be vaccinated against COVID-19. On February 10, 2025, the Court held a five-day 21 jury trial to address two claims that had survived the summary judgment stage—one claim under 22 Title VII of the Civil Rights Act, 42 U.S.C. 2000(e)-2(a)(1), and one claim under the Washington 23 24 1 Law Against Discrimination, RCW 49.60.180. See Dkt. 175; Dkt. 165. At the conclusion of the 2 fifth day of trial, the Court declared a mistrial due to a deadlocked jury. Dkt. 191. 3 A retrial is scheduled to begin on September 3, 2025. Dkt. 201. Both parties filed their

4 supplemental motions in limine on July 28, 2025. Dkt. 226, 229. Both parties responded to the 5 other’s motions. Dkt. 245, 247. The Court addresses each motion in turn. 6 II. LEGAL STANDARD “A motion in limine is a procedural mechanism to limit in advance testimony or evidence 7 in a particular area.” Hana Fin., Inc. v. Hana Bank, 735 F.3d 1158, 1162 n.4 (9th Cir. 2013). 8 “To exclude evidence on a motion in limine the evidence must be inadmissible on all 9 potential grounds.” Goodman v. Las Vegas Metro. Police Dep’t, 963 F. Supp. 2d 1036, 1047 (D. 10 Nev. 2013) (internal quotations omitted). “[I]f not, the evidentiary ruling is better deferred until 11 trial, to allow for questions of foundation, relevancy, and prejudice to be resolved with the 12 appropriate context.” Romero v. Washington, No. 2:20-cv-01027-TL, 2023 WL 6458871, at *1 13 (W.D. Wash. Oct. 4, 2023). 14 In ruling on motions in limine, courts do not “resolve factual disputes or weigh 15 evidence.” United States v. Meech, 487 F. Supp. 3d 946, 952 (D. Mont. 2020). The inquiry is 16 discretionary. See United States v. Layton, 767 F.2d 549, 554 (9th Cir. 1985). 17 18 III. DISCUSSION A. Strandquist’s Motions in Limine 19 1. Motions in Limine 1 and 2: Preclude DSHS from challenging that Strandquist had 20 a sincerely held religious belief or that the belief conflicted with his ability to comply with the vaccine requirement. 21 Strandquist seeks to exclude arguments challenging whether he had a sincerely held 22 religious belief that prevented him from being vaccinated. Dkt. 229 at 3–7. Strandquist argues 23 that DSHS “judicially admitted Dr. Strandquist sincerely held a religious belief . . . which 24 1 conflicted with his ability to comply with the Vaccine Requirement” and alternatively, “issue 2 preclusion precludes Defendant[] from challenging Dr. Strandquist’s sincerity . . . because [it] 3 took final agency action when granting his application for a religious exemption[.]” Id. at 3, 4.

4 DSHS has agreed it will not challenge Strandquist’s prima facie case. See Dkt. 245 at 1. 5 The motions are thus DENIED as moot. 6 2. Motion in Limine 3: Preclude DSHS from challenging that Strandquist notified DSHS about his sincerely held religious belief and how it conflicted with his 7 ability to comply with the vaccine requirement. 8 Strandquist moves to exclude arguments challenging whether he notified DSHS about his 9 sincerely held religious belief and how it conflicted with his ability to receive the COVID-19 10 vaccine. Dkt. 229 at 7–8. Strandquist argues that during the first trial, he moved for judgment as 11 a matter of law that “he had established he notified Defendants about his religion and the conflict 12 it created with his ability to comply with the Vaccine Requirement[.]” Id. at 8. Since the Court 13 granted his motion, Strandquist contends that DSHS is precluded from raising this issue at the 14 retrial. Id. 15 Again, DSHS has agreed it will not challenge Strandquist’s prima facie case. See 16 Dkt. 245 at 1. Accordingly, the motion is DENIED as moot. 17 3. Motion in Limine 4: Preclude DSHS from challenging that Strandquist was threatened with or subjected to an adverse employment action. 18 Strandquist seeks to exclude arguments challenging whether he was threatened with or 19 subjected to an adverse employment action. Dkt. 229 at 8–9. Since the Court granted his motion 20 for judgment as a matter of law “that Defendant[] had threatened him with or subjected him to an 21 adverse employment action . . . when [it] discharged him from his continued public employment 22 for failing to comply with the Vaccine Requirement,” Strandquist argues that DSHS is precluded 23 from raising this issue. Id. at 8. 24 1 Given that DSHS has agreed it will not challenge Strandquist’s prima facie case, see 2 Dkt. 245 at 1, the motion is DENIED as moot. 3 4. Motion in Limine 5: Preclude DSHS from arguing that Strandquist was offered a reasonable accommodation. 4 Strandquist moves to exclude any argument that the offer of reassignment to a 5 Management Analyst 5 position was a reasonable accommodation. Dkt. 229 at 9–11. Strandquist 6 argues that a reasonable accommodation “must preserve an employee’s employment status 7 (compensation, terms, conditions, or privileges of employment).” Id. at 11. But because the 8 reassignment “would have paid [Strandquist] approximately $50,000 less per year and that 9 would have detrimentally affected the defined benefits he would receive,” DSHS should not be 10 permitted to argue it was a reasonable accommodation. Id. 11 This motion is a partial summary judgment motion disguised as a motion in limine. This 12 Court strictly enforces the dispositive motion deadline and will not entertain untimely dispositive 13 motions at the motion in limine stage. As the Court discussed with counsel at the pretrial 14 conference, any party may raise a timely Rule 50 motion if they believe the evidence at trial 15 entitles them to judgment as a matter of law on a claim or part of a claim. This motion is 16 DENIED. 17 5. Motion in Limine 6: Preclude DSHS from arguing that accommodating 18 Strandquist in his current position or maintaining his employment status would constitute an undue burden. 19 Strandquist asks the Court to exclude any argument that accommodating him in his 20 current position would have resulted in an undue burden on DSHS. Dkt. 229 at 12–15. This 21 motion is again another partial summary judgment motion and is not proper use of motions in 22 limine. This motion is DENIED. 23 24 1 6. Motion in Limine 7: Preclude DHS from arguing that Strandquist breached his duty to use ordinary care to mitigate his backpay damages because he had the 2 ability to become re-employed earlier. 3 Strandquist seeks to exclude any argument that he failed to mitigate damages because he 4 did not seek reemployment earlier or did not seek a higher-paying position even after obtaining 5 reemployment. Dkt. 229 at 15.

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Related

United States v. Laurence John Layton
767 F.2d 549 (Ninth Circuit, 1985)
United States v. Kory Ray Smith
389 F.3d 944 (Ninth Circuit, 2004)
Hana Financial, Inc. v. Hana Bank
735 F.3d 1158 (Ninth Circuit, 2013)
Goodman v. Las Vegas Metropolitan Police Department
963 F. Supp. 2d 1036 (D. Nevada, 2013)

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