JEFFREY BILYEU; JESSICA BILYEU v. UT-BATTELLE, LLC. - Articles

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JEFFREY BILYEU; JESSICA BILYEU v. UT-BATTELLE, LLC.

Posted by: Azya Thornton on Sep 29, 2025

Court: 6th Circuit Court (Published Opinions)

Attorneys 1: ARGUED: Brian Field, SCHAERR | JAFFE LLP, Washington, D.C., for Appellants.

Attorneys 2: Keith D. Frazier, OGLETREE DEAKINS, NASH, SMOAK & STEWART, P.C., Nashville, Tennessee, for Appellee.

Attorneys 3: ON BRIEF: Brian J. Field, Mark R. Paoletta, SCHAERR | JAFFE LLP, Washington, D.C., Melissa B. Carrasco, CARRASCO TRUMP, Knoxville, Tennessee, for Appellants.

Attorneys 4: Keith D. Frazier, OGLETREE DEAKINS, NASH, SMOAK & STEWART, P.C., Nashville, Tennessee, David L. Schenberg, OGLETREE DEAKINS, NASH, SMOAK & STEWART, P.C., St. Louis, Missouri, for Appellee.

Judge(s): SILER, KETHLEDGE, and BUSH, Circuit Judges

Court Appealed: United States District Court for the Eastern District of Tennessee at Knoxville

JOHN K. BUSH, Circuit Judge. Jeffrey and Jessica Bilyeu objected on religious grounds to a coronavirus vaccine mandate imposed by their employer, UT-Battelle, during the pandemic. According to the Bilyeus, when an employee raised a religious objection to COVID vaccination, UT-Battelle required the employee to submit to a lengthy panel interview with UT-Battelle’s leadership regarding the employee’s beliefs. Not only that, according to the Bilyeus, UT-Battelle officials prepared a “fact sheet” that the objecting employee had to read that included the views of various religious leaders in support of taking the vaccine. Only after completing this process could a religious objector forego the vaccine and then, only by being placed on indefinite unpaid leave. This treatment and other conduct by UT-Battelle, the Bilyeus contend, violated Title VII of the Civil Rights Act of 1964 based on disparate treatment, failure to accommodate, and retaliation. The district court granted summary judgment to UT-Battelle. We AFFIRM the grant of summary judgment as to Mrs. Bilyeu because she lacks Article III standing. But we VACATE the grant of summary judgment on Mr. Bilyeu’s disparate treatment and failure-to- accommodate claims and REMAND those claims so the district court may reconsider its decision in light of intervening Supreme Court precedent. Finally, we REVERSE the grant of summary judgment on Mr. Bilyeu’s retaliation claim and REMAND it for further proceedings because Mr. Bilyeu has presented evidence that might persuade a reasonable jury to believe he suffered adverse action for seeking a religious accommodation.

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