Zajonc v. T-Mobile US, Inc.

Summary

The United States District Court for the Northern District of California grants T-Mobile’s motion to dismiss a putative class action challenging the denial of a religious exemption to the company’s COVID-19 vaccination requirement. The court dismisses the FEHA and UCL claims with leave to amend because the complaint contains insufficient factual allegations, and dismisses the wrongful-termination claim without leave to amend. The court sets a deadline for an amended complaint and continues the initial case management conference.

Holdings

1. A FEHA religious-discrimination claim must allege, among other things, that the plaintiff holds a bona fide religious belief that conflicts with an employment requirement. Plaintiff's conclusory allegations did not adequately plead such a claim, so the FEHA claim was dismissed with leave to amend.
2. Because Plaintiff's UCL unlawful-prong claim was predicated on the alleged FEHA violation, the failure of the FEHA claim required dismissal of the derivative UCL claim.
3. Plaintiff failed to state a UCL claim under the unfair prong because her allegations merely parroted statutory language and did not adequately identify a qualifying unfair business practice.
4. Plaintiff failed to state a UCL fraudulent-prong claim because she did not identify the allegedly false statements or otherwise plead facts showing that members of the public were likely to be deceived.
5. The wrongful-termination claim was dismissed without leave to amend because Plaintiff did not oppose dismissal.

Questions Presented

1. Whether the complaint adequately pleaded a FEHA religious-discrimination claim based on T-Mobile's denial of a religious exemption to its COVID-19 vaccination requirement.
2. Whether the complaint adequately pleaded claims under the unlawful, unfair, and fraudulent prongs of California's Unfair Competition Law.
3. Whether the wrongful-termination claim should be dismissed where Plaintiff did not oppose dismissal.

Disposition

other