ST. LOUIS – A Missouri federal judge has granted a motion to dismiss in litigation brought by a former employee of SSM Health, who alleged she was unfairly retaliated against and terminated from her role after receiving a religious exemption from taking the COVID-19 vaccination.
On June 5, U.S. District Court for the Eastern District of Missouri Judge Henry Edward Autrey granted the dismissal motion from SSM-SLUH, Inc. (doing business as “SSM Health Saint Louis University Hospital”) and SSM Health Care Corporation (doing business as “SSM Health”), ending the case brought by plaintiff Carla M. Cochran.
“On June 12, 2023, plaintiff filed this action alleging she was constructively discharged from her employment with defendants in violation of 42 U.S.C. Section 2000e, et seq. (Title VII of the Civil Rights Act of 1964). Plaintiff contends she was discriminated against based on her religious beliefs. Plaintiff asserts she was employed by SSM Health and applied for an exemption to a COVID-19 vaccination requirement in July 2021. Defendants granted the exemption shortly after plaintiff’s request. Plaintiff further alleges she was singled out and was subjected to harsh and unreasonable treatment by her supervisors, who accused her of [having] ‘no morals or values: because of her religious beliefs and exemption from vaccination,” Autrey said.
“Plaintiff acknowledges SSM-SLUH, Inc. (doing business as “SSM Health Saint Louis University Hospital”) and SSM Health Care Corporation (doing business as “SSM Health”) are Missouri not-for-profit corporations registered with the State of Missouri Secretary of State and doing business in St. Louis City, State of Missouri as SSM St. Louis University Hospital, at an office located at 1201 S. Grand Ave., St. Louis, MO 63104, where plaintiff was located for the duration of plaintiff’s employment with defendant. Defendants move to dismiss on the ground that SSM Health is a religious organization and it therefore exempt from the provisions of Title VII prohibiting religious discrimination. Plaintiff does not substantively dispute defendants’ assertion, rather, plaintiff argues the Court may not consider defendants’ exhibits which were attached to the motion to dismiss.”
Autrey explained that the Articles of Incorporation of SSMHCC and SSM-SLUH, Inc. and the Canonical Statutes of SSM Health Ministries “all set forth SSM Health’s religious purpose and mission…[and that] according to the Canonical Statutes, the purpose of SSM Health Ministries is ‘to further the healing ministry of Jesus Christ with special attention to those persons who are poor and vulnerable.”
Autrey added that “the Roman Catholic Church has also publicly declared SSMHCC, SSM Health Care St. Louis, SSM-SLUH and multiple other SSM Health ministries to be a part of the Church through their inclusion in the Official Catholic Directory… [which is] a published book, widely disseminated, publicly available and generally known.”
“Pursuant to its Canonical Statutes, SSM Health Ministries, SSMHCC and its health ministries must ‘adhere to and be guided by the Ethical and Religious Directives for Catholic Health Care Services,’ which are promulgated by the United States Conference of Catholic Bishops. The Bylaws of SSM Health Ministries further require that the members must complete an initial formation process, participate in a continuing faith formation process. In addition, the SSM Health Ministries Bylaws provide that ‘the majority of the members must be practicing Catholics in good standing with the Catholic Church and must be chosen on the basis of their knowledge, experience, availability and commitment to the Catholic healthcare ministry.’ Likewise, the board members of SSMHCC and SSM-SLUH, Inc. must understand and be willing to support the mission, philosophy and values of the Franciscan Sisters of Mary, SSM Health Ministries and SSM Health,” Autrey said.
“For all of these reasons, defendants are religious organizations, exempt from Title VII’s provisions regarding religious discrimination. Taken together, these factors readily establish SSM Health as a religious entity within the meaning of Title VII’s exemption. Title VII’s exemption shields defendant from religious discrimination claims, including claims arising from disputes over vaccination requirements. For the reasons set forth above, it is hereby ordered that defendants’ motion to dismiss, is granted.”
U.S. District Court for the Eastern District of Missouri case 4:23-cv-00762
From the St. Louis Record: Reach Courts Reporter Nicholas Malfitano at nick.malfitano@therecordinc.com