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Fallon v. Mercy Catholic Medical Center of Southeastern Pennsylvania

877 F.3d 487 (2017)

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Fallon v. Mercy Catholic Medical Center of Southeastern Pennsylvania

United States Court of Appeals for the Third Circuit
877 F.3d 487 (2017)

Facts

Paul Fallon (plaintiff) worked for Mercy Catholic Medical Center of Southeastern Pennsylvania (Mercy) (defendant). In 2012, Mercy started requiring employees to receive an annual flu vaccine unless they obtained a medical or religious exemption. Fallon, who did not belong to any religious organization, sought a religious exemption based on his sincerely held beliefs that the vaccine might do more harm than good. In support, he submitted a lengthy essay that explained his beliefs from a medical perspective and stated that receiving the vaccine would violate the principle that a person should not harm his own body. In 2012 and 2013, Mercy granted the requested exemption. However, in 2014, Mercy denied Fallon’s exemption request, requiring Fallon to provide a letter from a clergyperson, which Fallon could not do. When Fallon nevertheless refused to receive the flu vaccine, he was terminated. Fallon sued Mercy, arguing that his termination constituted religious discrimination violating Title VII of the Civil Rights Act of 1964 (Title VII). The district court granted Mercy’s motion to dismiss the claim, reasoning that although Fallon’s beliefs were sincere, they were not religious and were therefore not protected by Title VII. Fallon appealed.

Rule of Law

Issue

Holding and Reasoning (Roth, J.)

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