Savel v. MetroHealth: Sixth Circuit Clarifies Post-Groff “Undue Hardship” and Rejects an Implied Interactive-Process Duty under Title VII

Introduction

In Frank Savel v. The MetroHealth System, No. 24-4025 (6th Cir. 2025), the United States Court of Appeals for the Sixth Circuit addressed the legality of an Ohio public hospital’s decision to deny a frontline nurse a religious exemption from its COVID-19 vaccination mandate. The case arose out of MetroHealth’s August 2021 policy requiring vaccination for all employees while providing for medical or religious exemptions.

Plaintiff-appellant Frank Savel, an intensive-care nurse, alleged religious discrimination under Title VII of the Civil Rights Act of 1964 and Ohio Revised Code § 4112 when his exemption request was refused. The district court granted summary judgment to MetroHealth. On appeal, a Sixth Circuit panel consisting of Chief Judge Sutton and Circuit Judges Clay and Bloomekatz affirmed, simultaneously resolving discovery and procedural disputes and the separate claims of a co-plaintiff, Danielle Crockett.

The decision is significant for two reasons: (1) it is one of the first published (albeit “not recommended for publication”) appellate applications of the Supreme Court’s 2023 ruling in Groff v. DeJoy, which heightened the “undue hardship” standard in religious-accommodation cases; and (2) it expressly rejects any freestanding duty on employers to engage in an “interactive process” comparable to Americans with Disabilities Act (ADA) practice when accommodating religion under Title VII.

Summary of the Judgment

Accommodation Claim: Even assuming Savel made out a prima facie case, exempting an ICU nurse from vaccination in winter 2022 would have imposed an “undue hardship” on MetroHealth—now defined after Groff as a “substantial burden” in the context of the hospital’s operations. Savel offered no evidence—only his personal disagreement—to defeat summary judgment.
Disparate-Treatment Claim: The record did not show that medical exemption requests were treated more favorably than religious ones, nor that similarly-situated employees outside the protected class received better treatment. Consequently, the fourth prong of the McDonnell Douglas prima facie test failed.
Discovery & Procedural Rulings: The district court did not abuse its discretion in denying additional time for discovery or in treating belated evidentiary objections as moot; the court emphasized Savel’s lack of diligence.
Crockett’s Claims: The companion plaintiff’s claims were properly dismissed with prejudice after she ignored the court’s order to comply with discovery obligations.

Analysis

3.1 Precedents Cited

Groff v. DeJoy, 600 U.S. 447 (2023) – Re-articulated that an employer must accommodate unless the accommodation would impose a “substantial” cost in the overall context of the business.
Tepper v. Potter, 505 F.3d 508 (6th Cir. 2007) – Sets out the burden-shifting framework for Title VII religious accommodation.
McDonnell Douglas Corp. v. Green, 411 U.S. 792 (1973) – Provides the tripartite burden-shifting structure for disparate-treatment claims lacking direct evidence.
Kizer v. St. Jude Children’s Research Hospital, 2024 WL 4816856 (6th Cir. Nov. 18, 2024) – Previously clarified that Title VII does not mandate an “interactive process.” The panel relies heavily on this emerging line.
Various procedural cases on discovery and extensions (e.g., Doe v. City of Memphis, Marie v. American Red Cross).

3.2 Legal Reasoning

a) Accommodation Claim: Under Tepper, once the prima facie burden is assumed, the employer must prove undue hardship. Applying Groff, the court found that keeping a non-vaccinated ICU nurse in a patient-facing role during a pandemic surge would impose a substantial, non-trivial risk—both to public health and to the hospital’s ability to deliver care. Evidence included nearly 1,000 staff infections during the December 2021 surge and the hospital’s mission to safeguard patients. Alternative measures (masking, testing, etc.) were deemed “far less effective.”

b) Rejection of an Interactive-Process Obligation: Savel argued MetroHealth’s failure to negotiate bespoke accommodations automatically violated Title VII. The panel, echoing Kizer, held no such requirement exists. Nonetheless, MetroHealth did offer a remote-work option and job-transfer assistance, evidencing good-faith engagement.

c) Disparate-Treatment Claim: Relying on Macy v. Hopkins County School Board of Education, the court held the “similarly-situated” comparator evidence was missing. The record showed a handful of both religious and medical exemptions were granted after individualized risk analysis; thus no inference of religious animus arose.

d) Procedural/Diligence Emphasis: The opinion underscores a litigant’s obligation to prosecute discovery proactively. Despite seven months of combined discovery windows, Savel filed no requests until after the summary-judgment motion. Under Doe v. City of Memphis, lack of diligence defeats Rule 56(d) relief.

3.3 Impact of the Judgment

Guidance on Post-Groff Standard: The Sixth Circuit supplies practical contours for what constitutes a “substantial burden” in healthcare, illustrating that patient-safety risks alone may suffice.
Clarifies No ADA-Style Interactive Process: By rejecting an implied duty, the court lightens employers’ procedural burdens in religious-accommodation contexts, limiting claims that hinge solely on dialogue failures.
Discovery Practices: The ruling signals intolerance for last-minute discovery tactics; parties must be proactive or risk forfeiture.
COVID-19 Vaccine Mandates: Employers—especially in healthcare—retain considerable discretion to enforce vaccination requirements despite religious objections when evidence of operational hardship exists.
Ohio State Law Harmonization: The court reiterates that Ohio Revised Code § 4112 mirrors Title VII, promoting uniform analysis.

Complex Concepts Simplified

Title VII Religious Accommodation: Federal law requiring employers to reasonably accommodate an employee’s sincere religious practice unless doing so would cause “undue hardship.”
Prima Facie Case: The initial, minimal showing a plaintiff must make to shift the burden of proof to the employer.
Undue Hardship (Post-Groff): A “substantial” burden on the conduct of the employer’s business—higher than the older “more than de minimis” test.
Interactive Process: An ADA concept describing cooperative dialogue to identify accommodations. The court here rules it is not a stand-alone requirement under Title VII.
McDonnell-Douglas Framework: Three-step evidentiary protocol: (1) plaintiff’s prima facie case; (2) employer’s legitimate reason; (3) plaintiff’s showing of pretext.
Summary Judgment: A procedural device allowing courts to decide a case without trial when no genuine dispute of material fact exists.
Abuse of Discretion: Standard of appellate review deferring to lower courts unless their decision was arbitrary or unreasonable.

Conclusion

Savel v. MetroHealth fortifies employer discretion in the healthcare sector under the newly articulated Groff standard, emphasizing that documented patient-safety concerns can constitute a “substantial burden.” Equally important, the Sixth Circuit closes the door on claims premised solely on an alleged failure to engage in a dialogue about accommodations, unless accompanied by evidence of feasible alternatives. Finally, the case is a cautionary tale about litigation diligence: strategic delays in discovery may prove fatal. As such, this opinion—though labeled “not recommended for publication”—will likely shape litigation strategies and employer policies throughout the Sixth Circuit and beyond.