Summary
This Fifth Circuit opinion addresses a Title VII religious discrimination claim brought by a hospital employee who was placed on unpaid leave after initially requesting a religious exemption from a mandatory flu vaccination policy. The majority affirms the district court's grant of summary judgment, holding that the appellant forfeited her arguments on appeal by failing to adequately brief them or cite supporting authority. In dissent, Judge Engelhardt argues that the employer's eventual accommodation does not moot the claim for past discrimination and that the appellant adequately raised her failure-to-accommodate argument.
Topics
Practice areas
Questions Presented
- Whether the district court erred in granting summary judgment on Palms' Title VII failure‑to‑accommodate claim
- Whether Palms forfeited her arguments by failing to address the district court’s analysis and provide supporting authority
Holdings
- The district court’s summary judgment is affirmed because the appellant forfeited the argument by failing to address the district court’s analysis and to cite supporting authority.
Key quotations
“We see no reason to depart from settled practice in this case. While we deeply respect religious beliefs, including Harmon’s, “[w]e should decide like cases alike” and apply Rollins as we would in any other case.” (at 2)
Factual background
Palms worked as a radiographer at Texas Children’s Hospital for over twenty‑two years. In September 2022 the hospital instituted a mandatory flu‑shot policy. Palms sought a religious exemption, which the hospital denied because she did not explain how her beliefs had changed since she previously received the vaccine. She was placed on unpaid leave, sued, and the hospital later granted a mask‑wearing accommodation which Palms accepted.
Procedural history
The district court granted summary judgment on Palms' Title VII failure-to-accommodate claim; Palms appealed.