In a significant ruling, the Sixth Circuit Court of Appeals upheld the dismissal of Dr. Amy DiChiara's lawsuit against Summit Medical Group, Inc., and its affiliates. The court's decision, issued on July 13, 2026, confirmed that DiChiara's claims of retaliation under Title VII and the Americans with Disabilities Act (ADA) were without merit. This ruling impacts not only DiChiara but also sets a precedent for similar cases involving workplace vaccination mandates.
Dr. Amy DiChiara, a gastroenterologist, was employed by St. Elizabeth Physicians, a subsidiary of St. Elizabeth Healthcare. The dispute arose after the healthcare system implemented a COVID-19 vaccination policy on August 5, 2021, requiring all employees to be vaccinated by October 1, 2021, unless they received an exemption for medical or religious reasons. DiChiara opposed this policy, citing both scientific and religious objections, and was subsequently terminated for her actions.
The case began when DiChiara sought advice from Eric Deters, a disbarred attorney, regarding her response to the vaccination mandate. Despite not engaging Deters Law for representation, she became involved in discussions about potential litigation against her employer. DiChiara's actions included sending emails to hospital executives outlining her concerns about the vaccine and later forwarding internal emails to Deters, which ultimately led to her termination on October 4, 2021. The termination letter cited misappropriation of company property and violations of company policy as reasons for her dismissal.
After her termination, DiChiara filed a lawsuit in federal court, claiming retaliation under Title VII and the ADA, as well as various state claims. The district court granted summary judgment in favor of the defendants, stating that DiChiara's claims failed as a matter of law. DiChiara appealed the decision, leading to the recent ruling by the Sixth Circuit.
The court ruled that DiChiara did not engage in protected activity as defined under Title VII and the ADA. Judge Joan L. Larsen, writing for the panel, stated, "Because we find no protected activity, DiChiara’s prima facie case fails; so we do not reach the burden-shifting analysis." This ruling emphasized that DiChiara's actions did not constitute participation in a legal proceeding or opposition to unlawful discrimination as required for retaliation claims.
The court also noted that DiChiara's subjective belief that the vaccination policy was unlawful was not objectively reasonable. The judges highlighted that no reasonable person in her position would have believed the policy violated federal law, as it allowed for religious exemptions. Consequently, the court affirmed the lower court's decision, effectively dismissing all of DiChiara's claims.
This ruling has broader implications for healthcare workers and employers navigating vaccination mandates. It clarifies the legal protections available to employees who oppose such policies and reinforces the legal framework surrounding workplace discrimination and retaliation claims.
Moving forward, DiChiara's options for appeal are limited. The Sixth Circuit's decision is typically final unless a party seeks to have the case reviewed by the Supreme Court. There are currently no related cases pending that could impact this ruling directly.
As the legal landscape surrounding vaccination mandates continues to evolve, this case serves as a critical reference point for both employees and employers in understanding their rights and responsibilities.