Dillan Roth v. Exact Sciences Corporation and Kevin Conroy

Summary

The opinion addresses defendants’ motion for summary judgment in an employment action brought under Title VII, the FMLA, and the Pennsylvania Human Relations Act. The plaintiff alleged religious discrimination and failure to accommodate arising from Exact Sciences Corporation’s COVID-19 vaccination requirement, as well as retaliation and related claims. Based on the excerpt, the court found genuine issues of material fact concerning whether the plaintiff’s objections were religious in nature and sincerely held.

Holdings

1. Roth's expressed beliefs concerning biblical bodily stewardship, the purported use of fetal-cell lines, and his Christian and Baptist faith were sufficient to create genuine disputes of material fact regarding whether his opposition to vaccination was religious in nature and sincerely held. Those issues could not be resolved on summary judgment because they required credibility determinations.
2. Exact Sciences was entitled to summary judgment because allowing Roth to remain unvaccinated in his role visiting healthcare facilities would impose an undue hardship on the company.
3. Roth failed to establish Title VII and PHRA retaliation because he did not produce evidence that Exact Sciences' stated reason for termination—failure to comply with the vaccination requirement—was a pretext for retaliation.
4. Roth failed to establish FMLA retaliation because he produced no evidence that his parental leave motivated his termination or that defendants' stated reason was pretextual.
5. Roth's FMLA interference claim failed because the FMLA does not protect an employee from termination for a reason unrelated to exercising FMLA rights, and Exact Sciences terminated Roth for failure to comply with its vaccination requirement.
6. Conroy could not be liable for aiding and abetting under the PHRA because Roth failed to establish an underlying unlawful discrimination or retaliation violation by Exact Sciences.

Questions Presented

1. Whether Roth's objections to the COVID-19 vaccination requirement constituted religious beliefs and were sincerely held for purposes of Title VII and the PHRA.
2. Whether Exact Sciences offered Roth a reasonable religious accommodation or whether allowing him to remain unvaccinated in his healthcare-facility-based role would impose an undue hardship.
3. Whether Roth established Title VII and PHRA retaliation claims based on his religious-exemption request and complaints concerning Conroy's conduct.
4. Whether Roth established an FMLA retaliation claim based on his termination while on parental leave.
5. Whether Roth established an FMLA interference claim by showing that he was denied FMLA benefits.
6. Whether Conroy could be liable for aiding and abetting under the PHRA absent an underlying unlawful discrimination or retaliation violation by Exact Sciences.

Disposition

other