Medical Justice
Outcome: SettledCole v. Group Health Plan, Inc.
What the court held
The Eighth Circuit reversed the dismissal of Title VII and Minnesota Human Rights Act claims brought by a physical therapist who was denied a religious exemption from her employer's COVID-19 vaccine mandate. Applying the Supreme Court's decision in Muldrow v. St. Louis, the court held that a plaintiff need plead only 'some harm respecting an identifiable term or condition of employment,' not a significant or material one, and that whether the employer's badge-lock requirement and reassignments caused that harm required further factual development.
What it means
After Muldrow, the pleading threshold for an adverse employment action is lower than the Eighth Circuit's earlier cases required. An employee no longer has to allege that the harm was significant, material, or serious.
The court also declined to weigh reasonable accommodation or undue hardship at the motion to dismiss stage, holding those questions generally belong later in the case.
This was a procedural ruling on the pleadings: the Eighth Circuit reversed the dismissal and remanded for further proceedings. It is not a final judgment, a damages award, or a settlement.