Date: 07-03-2025

Case Style:

Frank Savel and Danielle Crockett v. the Metrohealth System

Case Number: 1:22-cv-02154

Judge: Donald C. Nugent

Court: Untied States District Court for the Northern District of Ohio

Plaintiff's Attorney: Rick Arnold and Jon Troyer

Defendant's Attorney: Katherine Mills, Rebecca Singer-Miller, natalie Stevens, and Ami Patel

Description: Cleveland, Ohio employment law lawyers represented the Plaintiff who sued on civil rights violation theories.

MetroHealth is a county-owned hospital in Cleveland, Ohio. In August 2021, it required
its entire workforce to get vaccinated against COVID-19. At the same time, MetroHealth allowed
employees to request exemptions for medical or religious reasons. MetroHealth received over 400
such exemption requests. But an intervening COVID-19 surge and shifting public health guidance
delayed its decisions. In the meantime, MetroHealth treated those awaiting decisions as compliantNo. 24-4025, Savel v. MetroHealth System small number of both religious and medical requests. It did so after individually assessing the
health and safety risks posed by each request, including the risks of exempting applicants in
patient-facing positions.

Frank Savel, an intensive-care nurse in MetroHealth’s main campus, requested a religious
exemption from the vaccine requirement. In February 2022, MetroHealth denied his request.
MetroHealth found that Savel had a sincere religious belief that conflicted with the vaccine
mandate, but that exempting him would cause the hospital an undue hardship. MetroHealth told
Savel that alternative protocols like masking were “far less effective” and placed “patients,
coworkers, and others at significant risk.” Denial Email, R. 12-2, PageID 312. Given that risk,
MetroHealth determined that remote work was the only accommodation it could offer. But Savel
had a frontline job serving COVID-19 patients and could not work remotely. So MetroHealth gave
him 45 days to get vaccinated or apply to switch to a remote position.

A month later, and shortly before the vaccination deadline, MetroHealth announced it
would grant previously denied religious exemptions. At the time, positivity rates were at a record
low, winter was over, and forecasts looked favorable. MetroHealth thus determined that the “costs
and burdens” of granting those exemptions had “changed in a material way.” Announcement, R.
12-2, PageID 434–35. But the change came late for Savel, who had already left MetroHealth for a
comparable job elsewhere.

In late 2022, Savel and 45 other employees sued MetroHealth for religious discrimination
under Title VII and its Ohio counterpart. 42 U.S.C. §§ 2000e–2(a), 2000e(j); Ohio Rev. Code
§ 4112. The district court dismissed the entire case for lack of standing and failure to state a claim.
We affirmed that ruling except as to Savel’s and Danielle Crockett’s claims. Savel v. MetroHealth
Sys.her claims without prejudice, but the district court dismissed with prejudice instead. Only Savel’s
claims remained.

As for those claims, the district court granted MetroHealth summary judgment. It held that
Savel had failed to genuinely dispute MetroHealth’s assertion of undue hardship, so his
accommodation claim failed. It also found no evidence that MetroHealth denied Savel an
exemption because of his religion, so it granted summary judgment on his disparate treatment
claim as well. This appeal followed.

Outcome: Affirmed

Plaintiff's Experts:

Defendant's Experts:

Comments: