Maryrose Thill v. 3M Company

Summary

The United States District Court for the District of Minnesota granted 3M Company’s motion for summary judgment in MaryRose Thill’s action alleging religious discrimination under Title VII and the Minnesota Human Rights Act arising from 3M’s COVID-19 vaccination requirement. The court held that 3M offered a reasonable accommodation by identifying a non-customer-facing position with the same pay and job grade, which Thill declined. The complaint was dismissed with prejudice.

Holdings

1. An employer satisfies its Title VII religious-accommodation obligation when it offers a reasonably comparable position that eliminates the conflict between the employee's religious beliefs and an employment requirement and preserves the employee's terms, conditions, and privileges of employment. 3M's proposed non-customer-facing position with the same pay and job grade was a reasonable accommodation as a matter of law.
2. An employee has a duty to cooperate in achieving an accommodation and to make a good-faith attempt to satisfy her religious needs through an accommodation offered by the employer. Thill's refusal to pursue the proposed position left 3M entitled to summary judgment.
3. The court declined to separately analyze the MHRA claim because 3M treated it as derivative of the Title VII claim and Thill did not object or request individualized consideration; to the extent the claim required separate treatment, Thill forfeited that argument.
4. Any disparate-impact claim that may have been included in the complaint was abandoned because 3M framed the case as a disparate-treatment failure-to-accommodate claim and Thill did not dispute that framing.

Questions Presented

1. Whether 3M violated Title VII by failing to reasonably accommodate Thill's religious objection to COVID-19 vaccination.
2. Whether 3M's proposed transfer to a non-customer-facing position with the same pay and job grade constituted a reasonable accommodation as a matter of law.
3. Whether Thill's Minnesota Human Rights Act claim required separate analysis where the parties treated it as derivative of the Title VII claim.
4. Whether Thill preserved any disparate-impact claim allegedly included in her complaint.

Disposition

dismissed