Brenda Salinas Navarrete v. PeaceHealth

Summary

The United States District Court for the District of Oregon grants PeaceHealth’s motion for summary judgment in Brenda Salinas Navarrete’s religious discrimination and failure-to-accommodate claims under Title VII and Oregon law. The court addresses evidentiary objections and concludes that PeaceHealth was entitled to require vaccination, absent a medical or religious exception, based on the information available when its undue-hardship decision was made.

Holdings

1. Dr. Mina's testimony was excluded because portions based on scientific and medical sources unavailable to PeaceHealth in August 2021 were irrelevant, and the testimony was not supported by sufficient facts or data or a reliable methodology under Rule 702 and Daubert.
2. PeaceHealth established that accommodating Navarrete and hundreds of similarly situated unvaccinated employees with N95 respirators and regular testing instead of vaccination would impose undue hardship under Title VII and Oregon law.
3. An employer's showing that any accommodation would impose undue hardship independently defeats a Title VII failure-to-accommodate claim; the employer need not first prove that it made good-faith accommodation efforts.
4. ADA direct-threat and ADA significant-difficulty-or-expense standards did not govern Navarrete's Title VII religious-accommodation claim.
5. Navarrete could not perform the essential functions of her Environmental Services Attendant position entirely remotely.

Questions Presented

1. Whether PeaceHealth was entitled to summary judgment on Navarrete's Title VII and Oregon religious-accommodation claims because accommodating her and similarly situated unvaccinated employees onsite with N95 respirators and regular testing would impose undue hardship.
2. Whether the court should exclude Dr. Michael Mina's expert testimony under Federal Rule of Evidence 702 and Daubert because it was irrelevant to the information available to PeaceHealth in August 2021 and unreliable.
3. Whether Navarrete's arguments concerning ADA direct threat, ADA undue hardship, good-faith accommodation efforts, a continuing interactive-process duty, or discriminatory motive created a triable issue under her Title VII failure-to-accommodate claim.

Disposition

other