Patricia Conway v. Mercy Hospital St. Louis

St. Louis, Missouri employment law lawyer represented the Plaintiff on a civil rights violation theory.



During the COVID-19 pandemic, Patricia Conway, a registered nurse, was terminated from Mercy Hospital St. Louis ("Mercy Hospital”)—a non-profit healthcare facility owned and operated by Mercy Health Ministries—after she refused to comply with the hospital's vaccination policy. The policy required all employees to receive the COVID-19 vaccine unless they obtained an approved medical or religious exemption. Mercy Hospital denied. After Conway was terminated for noncompliance with the policy, she commenced this action alleging religious discrimination under Title VII of the Civil Rights Act of 1964.



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Title VII generally prohibits employers from discriminating against employees on the basis of their religious beliefs. However, Congress created a limited exemption for "religious organizations.” See Corp. of Presiding Bishop of Church of Jesus Christ of Latter-Day Saints v. Amos, 483 U.S. 327, 329 (1987) (discussing 42 U.S.C. § 2000e-1(a)). The exemption provides:



[Title VII] shall not apply to . . . a religious corporation, association,

educational institution, or society with respect to the employment of

individuals of a particular religion to perform work connected with the

carrying on by such corporation, association, educational institution, or

society of its activities.



Because Congress did not define what makes an organization "religious,” courts look to the ordinary meaning of the term. Taniguchi v. Kan Pac. Saipan, Ltd., 566 U.S. 560, 566 (2012).

Motion for summary judgment granted.



Affirmed