Thill v. 3M Company
- Laura Provinzino
- 0:23-cv-03626
- U.S. District Court · District of Minnesota
- 17
In Maryrose Thill v. 3M Company, Judge Provinzino granted 3M's motion for summary judgment and dismissed the case with prejudice, ruling that 3M satisfied its legal duty to accommodate Thill's religious objection to COVID-19 vaccination by offering her a lateral transfer to a non-customer-facing position that she declined without adequate justification.
Employees who request religious exemptions from employer vaccination requirements and are offered alternative positions or accommodations, as well as employers navigating Title VII and state human rights law obligations in the context of workplace vaccine mandates.
What happened
In Maryrose Thill v. 3M Company, MaryRose Thill was hired by 3M in August 2021 as an Activation Marketer supporting sales to hospitals and clinics. When 3M implemented a COVID-19 vaccination requirement driven by federal regulations, Thill requested a religious exemption based on her Christian belief that her body is a temple and that the vaccines would defile it. After 3M denied her exemption request, her supervisor identified a lateral transfer to a non-customer-facing role in 3M's Separation and Purification Sciences Division, at the same salary and job grade, that would have eliminated the need for her to be vaccinated. Thill declined the offer by text message, saying the position was not a 'good fit,' and was subsequently terminated in May 2022 for not being vaccinated and having no approved exemption.
Thill sued 3M under Title VII of the Civil Rights Act of 1964 and the Minnesota Human Rights Act, arguing that 3M failed to reasonably accommodate her religious beliefs. Under Title VII, an employer must offer a reasonable accommodation to an employee whose sincere religious beliefs conflict with a job requirement. One recognized form of reasonable accommodation is a lateral transfer to a comparable position where the religious conflict no longer exists. The key legal question was whether 3M's offer of the Purification division role constituted a reasonable accommodation, regardless of whether it was guaranteed or required Thill to apply. Thill argued the position was informally offered, might not have been a true lateral move, and amounted to a forced career change — but the court found she cited no record evidence to support those claims and that her own deposition testimony acknowledged the transfer could have been lateral, consistent with her supervisor's sworn declaration confirming it was.
Judge Provinzino granted 3M's motion for summary judgment and dismissed the complaint with prejudice, holding that 3M met its legal obligation by offering Thill a reasonable accommodation that would have fully resolved her religious conflict. The court explained that Title VII requires bilateral cooperation — the employer must offer a reasonable accommodation, but the employee must also make a good-faith effort to accept it. Because Thill rejected the offered position without meaningful engagement, she failed her part of that cooperative obligation. The court noted it did not need to decide whether Thill's religious beliefs were sincerely held or whether her prima facie case was established, because the reasonable accommodation issue was dispositive. The Minnesota Human Rights Act claim was also dismissed because Thill had agreed it should be analyzed under the same framework as the Title VII claim and did not argue it separately.
The detailed version
- Maryrose Thill v. 3M Company, No. 23-cv-3626 (LMP/JFD)
- Laura M. Provinzino, United States District Judge
- Summary judgment granted in favor of Defendant 3M Company; complaint dismissed with prejudice
- February 23, 2026
Background and Facts
MaryRose Thill was hired by 3M in August 2021 as an Activation Marketer supporting sales representatives in selling healthcare products to hospitals and clinics. Although she was not initially required to visit customers in person due to the COVID-19 pandemic, her role was classified as 'customer-facing.' In October 2021, 3M announced a COVID-19 vaccination requirement pursuant to a federal mandate applicable to government contractors. Thill submitted a religious exemption request on November 2, 2021, citing her Christian belief that the body is a temple of the Holy Spirit (drawing on multiple Biblical passages) and that receiving the COVID-19 vaccine would defile her body. She also cited safety and efficacy concerns about the vaccines.
The federal contractor mandate was blocked by a court in December 2021, temporarily suspending action on Thill's request. However, in January 2022, the U.S. Centers for Medicare and Medicaid Services (CMS) issued a separate rule requiring workers at Medicare and Medicaid-certified healthcare facilities to be vaccinated. Because Thill's role was customer-facing and involved visiting healthcare facilities, 3M determined she was covered by the CMS rule. On April 18, 2022, 3M notified Thill she must be vaccinated by May 23, 2022, or obtain an approved exemption, or face termination.
On April 27, 2022, 3M formally denied Thill's religious exemption, finding it did not meet the legal standard. Her supervisor, Matt Linabery, then identified a potential lateral transfer to 3M's Separation and Purification Sciences Division, which produced membranes and filters for water purification. This role was not customer-facing and would not require vaccination. Linabery confirmed in a sworn declaration that the role would carry the same salary and job grade as Thill's current position. On May 13, 2022, Thill declined the transfer by text message, stating it was 'not a good fit.' She also did not apply for a medical exemption. 3M terminated her employment on May 25, 2022.
Claims
After receiving a right-to-sue letter from the Equal Employment Opportunity Commission (EEOC), Thill filed suit on November 27, 2023, alleging religious discrimination under Title VII of the Civil Rights Act of 1964 (42 U.S.C. § 2000e et seq.) and the Minnesota Human Rights Act (MHRA), both on a failure-to-accommodate theory.
MHRA Claim
The court noted that the MHRA may not be a carbon copy of Title VII, but because Thill agreed at oral argument that her MHRA claim should be analyzed under the same framework and did not separately brief it, she forfeited any independent analysis of the MHRA claim. The court therefore only adjudicated the Title VII claim.
Title VII Framework
To establish a prima facie case of religious discrimination based on failure to accommodate under Title VII, an employee must show: (1) a bona fide religious belief conflicting with an employment requirement; (2) the employer was informed of the belief; and (3) the employee was disciplined for failing to comply with the requirement. If established, the burden shifts to the employer to show it offered a reasonable accommodation or that accommodation would cause undue hardship.
The court declined to decide whether Thill established her prima facie case, finding that the reasonable accommodation issue was dispositive.
Reasonable Accommodation Analysis
Under Title VII, if an employer offers a reasonable accommodation, the employee cannot insist on a different arrangement, even one the employee prefers. A lateral transfer to a 'reasonably comparable position' eliminating the religious conflict constitutes a recognized form of reasonable accommodation. Courts have interpreted 'reasonably comparable' to mean a position that reasonably preserves the employee's terms, conditions, or privileges of employment — it need not perfectly replicate all prior terms.
The court found no genuine dispute that 3M's offer of the Purification division role was a reasonable accommodation: it would have eliminated Thill's need to be vaccinated, and Linabery's uncontroverted declaration confirmed the position carried the same pay and job grade. Thill's counterarguments were rejected:
- Not formally offered: Thill argued the position was not offered in a 'professional and organized manner,' but cited no record evidence or legal authority for this requirement.
- Uncertainty about lateral status: Thill's deposition showed she was merely unsure whether the transfer was lateral, which does not contradict Linabery's affirmative declaration that it was. Uncertainty alone does not create a genuine factual dispute.
- Forced career change: Thill argued this was a major career shift, but cited no record evidence beyond her text declining the role as 'not a good fit.' That a proposed accommodation is not the employee's preferred option does not make it unreasonable.
- Fact question for the jury: While reasonableness is often fact-intensive, the court distinguished Thill's cited cases because, unlike those cases, there was no dispute here that the offered position would have fully resolved her religious conflict.
- Not guaranteed: Thill argued the position was not guaranteed and she might have had to apply. Even accepting this, the court held that offering an employee the opportunity to apply for — or be assisted in finding — an internal position eliminating the religious conflict satisfies the employer's accommodation duty, citing analogous decisions from the Fifth, Seventh, Ninth, and Eleventh Circuits, as well as multiple district courts.
The court also invoked the principle of bilateral cooperation embedded in Title VII: once 3M offered a reasonable accommodation, Thill had a corresponding duty to make a good-faith effort to pursue it. Instead, she summarily dismissed the Purification division role without explanation and without exploring the option. The court held this failure was Thill's responsibility, not 3M's.
Disposition
3M's Motion for Summary Judgment (ECF No. 48) was GRANTED. The complaint (ECF No. 1) was DISMISSED WITH PREJUDICE, meaning Thill cannot refile these claims.
Reviewer note from the AI+
Read the full 17-page opinion on CourtListener, the free public archive maintained by the Free Law Project.