Trueblood v. Valley Cities Counseling and Consultation

Trueblood v. Valley Cities Counseling and Consultation

In the state of Washington, Dorothy Trueblood was terminated from Valley Cities Counseling and Consultation (VCCC) as a 'WISe Program parent partner’ on July 19, 2022. Trueblood, a Christian woman, was hired in 2012 and signed onto VCCC’s Staff principles, acknowledging that they would govern her work. She openly expressed her Christian faith and stated she felt her views were respected until her termination. On June 29, 2022, Trueblood requested workplace accommodations from Human Resources based on ‘religious beliefs and freedom of speech’ to not work with clients with preferred pronouns, not include pronouns in her introductions and email signatures, and to use clients' and coworkers’ names rather than their preferred pronouns.

Trueblood previously expressed to the WISe Program program manager that her religious beliefs conflicted with VCCC’s policies of using clients' and staff’s preferred pronouns. Trueblood and the manager discussed the potential harm that can be done to clients when they’re not referred to properly following inciting incidents with two non-gender-conforming clients. She was informed that Washington regulation 162-32-040 states that intentional misuse of an individual’s name, form of address, or pronouns is prohibited in places of employment and public accommodation. As a result, her accommodations were denied, and her employment was terminated.

VCCC is described as a nonprofit mental healthcare provider that offers support with anxiety, depression, substance use, gender dysphoria, and more, and operates the WISe Program to help with family mental health support. The program stated that youth clients have “complex behavioral health issues, some of which relate to sexual orientation and gender identity.” (Google Scholar) Youth Clients would have a peer or a parent partner, but VCCC stated that the youth is the client at all times, not the parent. VCCC also advised services to accommodate mental health needs with the parental and clients’ consent.

Trueblood was assigned two non-conforming gender youths in 2022. Despite the first client having preferred pronouns, Trueblood told the client’s mother her intention of using their assigned pronouns at birth, which was agreed upon by the client’s mother and a WISe team facilitator, as she was a parent partner and not a peer counselor. The second client’s parent requested that their child’s preferred pronouns be respected due to discrimination against their gender identity, and Trueblood offered to leave the client’s care team, raising her religious beliefs as the reason. Trueblood continued to engage with clients in ways that violated VCCC policies and was told that three out of five accommodations were discriminatory based on gender identity, i.e., using the correct pronouns only when people’s biology matched, but refusing to use preferred pronouns any other time.

While Trueblood claimed to have never refused cooperation with a client or co-worker due to gender identity, VCCC fired her on the basis that employees are required by state and federal laws to abide by gender identity, and refusing to use proper pronouns is discrimination. Trueblood cited that her accommodations stemmed from the freedoms of speech and exercise of religion, but since VCCC is a non-profit, amendments don’t apply in the same manner as a government institution. She denied her termination being a mutual agreement and filed a lawsuit against VCCC, accusing them of failing to accommodate her religion under Title VII, “the burden shifts to the employer to prove that it made good faith efforts to accommodate that employee's religious belief,” unless it would bring about an undue hardship on the employer, and the Washington Law Against Discrimination.

In Groff v. DeJoy, Groff requested Sundays for religious reasons, but USPS continued to schedule him. Groff was disciplined, resigned and then sued under Title VII of the Civil Rights Act of 1964. The Supreme Court unanimously ruled that the employer forcing other employees to work would not constitute an undue hardship on business, and undue hardship shouldn’t be based on employee animosity or perceived inconvenience towards religious accommodations.

In Trueblood's case, while there was an argument made that VCCC failed to give Trueblood a reasonable accommodation alternative, VCCC argues three of the five accommodations would have caused hardship as it risks violating state and federal laws on gender discrimination, stating that neither Title VII nor the WLAD can accommodate a discriminatory practice. The District Court for the Western District of Washington dismissed Trueblood’s claim with prejudice.

I agree with the court’s ruling because even though Trueblood sought the protection of the First Amendment, VCCC being a private institution means that it doesn’t apply directly. Trueblood signed off on VCCC's principles, which required staff to accommodate clients’ mental health needs and identities, which she failed to do. Finally, she put undue hardship on VCCC as discrimination based on gender identity in a place of accommodation is a liability for a place that's meant to provide mental health care tailored to individuals of all ethnicities, sexual orientations, religions and gender identities.