MacDonald v. Oregon Health & Science University

Overview

(U.S. District Court for Oregon, July 5, 2024) The U.S. District Court for Oregon granted summary judgment to Oregon Health & Science University (OHSU), rejecting MacDonald’s prima facie Title VII claim because her religious accommodation request to remain unvaccinated would have caused undue hardship to OHSU. OHSU is the largest public hospital system in Oregon, and MacDonald worked as a registered nurse in their Children’s Hospital’s Mother and Baby unit. MacDonald was denied a religious accommodation to remain unvaccinated against COVID-19, and she was subsequently fired after she continued to decline vaccination. OHSU’s lawyers conceded that MacDonald had established a prima facie case of Title VII discrimination, but the Court granted summary judgment because OHSU demonstrated that the requested accommodation would have caused undue hardship to the hospital. OHSU established this affirmative defense with declarations from hospital administrators to describe the anticipated impact of the accommodation, and an expert report that documented the known threat of COVID-19 and the unique efficacy of vaccines. By contrast, MacDonald’s case was weakened by “redundant or inappropriate” arguments,” and by the exclusion of much of her evidence as hearsay, or due to errors in submission. In granting summary judgment, the Court notes that the Defendant’s undue hardship defense would not depend on the efficacy of the required vaccine, but on the Defendant’s “assessment of undue hardship at the time it denied Plaintiff’s exemption.” Despite conceding a prima facie Title VII violation, OHSU convinced the Court that accommodating MacDonald would have “undermined Defendant’s legitimate mission, creating a substantial increased cost and, hence, an undue hardship,” so the Court granted the OHSU’s motion for summary judgment. Read the full opinion here.

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