Jetaime Flores v. Cook County

Summary

The United States District Court for the Northern District of Illinois granted Cook County’s motion for summary judgment in Jetaime Flores’s Title VII action challenging Cook County Health’s mandatory COVID-19 vaccination policy. The court held that Flores established a sincerely held religious objection for summary-judgment purposes, but that accommodating her by allowing her to work in person while unvaccinated would impose an undue hardship. The court also rejected her disparate-treatment claim because she did not show that an allegedly comparable employee was similarly situated in all material respects.

Holdings

1. Plaintiff met her low burden at summary judgment to demonstrate she had a sincerely held religious belief that prevented her from being vaccinated, based on her written statement opposing vaccines derived from aborted fetal cell lines.
2. Allowing Plaintiff, an in-person pharmacy technician, to continue working unvaccinated would have created an undue hardship for CCH's operations, patients, and staff.
3. Plaintiff failed to establish that a similarly situated employee outside her protected class was treated more favorably, defeating her disparate treatment claim.

Questions Presented

1. Whether Defendant violated Title VII by failing to accommodate Plaintiff's religious beliefs regarding its COVID-19 vaccination policy.
2. Whether Plaintiff was subjected to disparate treatment based on her religion under Title VII.

Disposition

affirmed