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 Paula Zajonc’s First Amended Complaint. The court holds that the complaint does not plausibly allege a bona fide religious belief conflicting with T-Mobile’s COVID-19 vaccination requirement or termination based on religious beliefs. The court also dismisses the California Unfair Competition Law claim for lack of Article III standing and failure to state a claim, while granting one final opportunity to amend.

Holdings

1. The First Amended Complaint failed to state a FEHA religious-discrimination claim because it alleged only the conclusory assertion that Plaintiff had bona fide religious beliefs preventing vaccination, without facts plausibly describing those beliefs or their conflict with the vaccination requirement. It also failed to plausibly allege that Plaintiff was terminated because of her religious beliefs.
2. Plaintiff lacked Article III standing to seek prospective injunctive relief because she did not allege that T-Mobile had a policy of terminating employees who refused COVID-19 vaccination or that, as a former employee, she faced a substantial risk of future injury.
3. Plaintiff could not pursue UCL equitable relief for the same alleged harm because her FEHA claim sought damages and therefore supplied an adequate remedy at law. Her suggestion that she sought restitution did not establish equitable jurisdiction.
4. The UCL claim failed under each asserted prong. The unlawful theory depended on the deficient FEHA claim; the unfair theory added no supporting facts; and the fraudulent theory did not plausibly allege a business practice likely to deceive the public.
5. The court granted Plaintiff one final opportunity to amend because she represented at oral argument that she could plead additional facts supporting her claims.

Questions Presented

1. Whether the First Amended Complaint plausibly alleged a religious-discrimination claim under the California Fair Employment and Housing Act.
2. Whether the First Amended Complaint plausibly alleged a California Unfair Competition Law claim under the unlawful, unfair, or fraudulent prongs.
3. Whether Plaintiff had Article III standing to seek prospective injunctive relief under the Unfair Competition Law.
4. Whether Plaintiff should receive leave to amend after previously amending her complaint.

Disposition

dismissed