In Watkins v. Wesley Homes, No. 2:25-CV-00290-LK, 2026 WL 353262 (W.D. Wash. Feb. 9, 2026), the court, inter alia, granted defendant’s motion to dismiss plaintiff’s claim of religious discrimination under Title VII of the Civil Rights Act of 1964.
From the decision:
Title VII makes it “an unlawful employment practice for an employer…to discriminate against any individual…because of such individual’s…religion.” 42 U.S.C. § 2000e-2(a). For purposes of Title VII, “[t]he term ‘religion’ includes all aspects of religious observance and practice…unless an employer demonstrates that he is unable to reasonably accommodate to an employee’s…religious observance or practice without undue hardship on the conduct of the employer’s business.” Id. § 2000e(j). A plaintiff can establish a prima facie case of religious discrimination under Title VII by demonstrating that: “(1) [s]he is a member of a protected class; (2) [s]he was qualified for h[er] position; (3) [s]he experienced an adverse employment action; and (4) similarly situated individuals outside h[er] protected class were treated more favorably, or other circumstances surrounding the adverse employment action give rise to an inference of discrimination.” Fonseca v. Sysco Food Servs. of Ariz., Inc., 374 F.3d 840, 847 (9th Cir. 2004) (quoting Peterson v. Hewlett–Packard Co., 358 F.3d 599, 604 (9th Cir. 2004)).
Construed liberally, Watkins’s complaint fails to allege facts showing that she “experienced an adverse employment action[.]” Fonseca, 374 F.3d at 847. To establish that element, a plaintiff must show “some injury respecting her employment terms or conditions[.]” Muldrow v. City of St. Louis, Missouri, 601 U.S. 346, 359 (2024). Watkins makes no such claim. She avers that her supervisor “sent…an email wanting to di[s]cuss the ‘issue’ ” related to Watkins leaving work to attend a Catholic funeral and the supervisor told Watkins “that [she] was in need of ‘training[.]’ ” Dkt. No. 4 at 4. Watkins does not aver how the meeting with her supervisor and the comment that she needed training negatively affected the terms and conditions of her employment.
The court next held that plaintiff did not sufficiently allege a constructive discharge claim, reasoning that “because Watkins’s allegations are insufficient to demonstrate a hostile work environment, they are also insufficient to establish the graver claim of hostile-environment constructive discharge.” (Internal quotation marks omitted).