Civil rights Vaccination Medical student.

Byline: R.I. Lawyers Weekly Staff

Where a plaintiff alleging that he was forced to take a leave of absence from medical school because he refused to be vaccinated against COVID-19 has filed a religious discrimination complaint against a defendant that did not recognize any exemptions to its policy requiring anyone with access to Rhode Island Hospital to be vaccinated, the complaint must be dismissed because the plaintiff was not employed by the defendant, so he was not protected under Title VII, nor has he alleged any governmental action that inhibited his rights under the First Amendment.

"Jared Pierce Sanchez was a medical student at Brown University ('Brown'). He alleges that Brown, Lifespan Corporation ('Lifespan'), and Care New England Health Systems ('Care New England') discriminated against him based on his religion. Mr. Sanchez alleges he was forced to take a 2 year leave of absence from school because he refused to be vaccinated against COVID-19. ... Brown gave him an exemption based on his religious beliefs, but Lifespan's COVID-19 vaccination policy at that time required anyone with access to Rhode Island Hospital to be vaccinated and it did not recognize any exemptions. He sues Brown, Lifespan, and Care New England, claiming a violation of his rights under Titles VI and VII of the Civil Rights Act 1964 ('Title VI,' and 'Title VII'), and the First Amendment to the United States Constitution. Lifespan moves to dismiss.

"Title VII prohibits employers from discriminating against employees based on their race, color, religion, sex (including sexual orientation), or national origin.

"Mr. Sanchez is a medical student enrolled at Brown University. ... By his own account, he is a 'student trainee.' He explains that he was 'subjected to [Lifespan's] schedules, responsibilities, and obligations' and that he operated 'under the...