A pair of employees failed to show their employer engaged in religious discrimination when it fired them for hosting a Christmas party during the COVID-19 pandemic, the 6th U.S. Circuit Court of Appeals has held (Dahlquist et. al. v. Amedisys, Inc., No. 22-5154 (6th Cir. Oct. 7, 2022)).
In December 2020, the two employees of home healthcare firm Amedisys, Inc. held an after-hours Christmas party at a private residence. Several co-workers attended the party. Twenty days after the event, Amedisys terminated the workers, finding that they had violated company directives and exhibited “poor judgment,” according to court documents, because the party risked exposing attendees to COVID-19. The company did not fire any other employees who attended the party.
The plaintiffs sued Amedisys in Tennessee state court in October 2021, alleging the company discriminated against them because they are Christian and chose to express their beliefs by hosting a religious party. Amedisys removed the suit to a federal district court, after which the plaintiffs filed an amended complaint alleging discrimination based on exercise of First Amendment rights and retalitory discharge claims, among others.
The district court granted Amedisys’ motion to dismiss the plainitffs’ complaint for failure to state claim. On appeal, the 6th Circuit upheld the ruling, noting that the plaintiffs were the only two attendees at the holiday party to be terminated despite the fact that other employees attended, which “undermines the plaintiffs’ assertion that religion was a motivating factor” in Amedisys’ decision, per the court.
The plaintiffs’ other claims were similarly dismissed, including allegations that Amedisys engaged in a retaliatory discharge in response to the exercise of protected rights and that Amedisys invaded the plaintiffs’ privacy.
