Religious-belief allegations revive Title VII claims over vaccine mandate

The 4th U.S. Circuit Court of Appeals revived part of a lawsuit brought by two former remote employees who alleged they were unlawfully fired after refusing to comply with a COVID-19 vaccination mandate. The plaintiffs sought religious exemptions, but the defendant denied those requests and terminated their employment. A U.S. District Court dismissed all claims, finding the plaintiffs failed to plausibly allege that their refusals were rooted in protected religious beliefs.

On appeal, the 4th Circuit said its recent guidance in Barnett v. Inova Health Care Services governs the pleading standard in vaccine-mandate cases. There, the court explained that a plaintiff need only plausibly allege that a refusal to be vaccinated stems from an aspect of religious practice or faith. Applying that framework, the court held the plaintiffs met the standard.

One plaintiff alleged she opposed vaccines derived from aborted fetal cell lines because of her Christian upbringing. The second asserted that complying with the mandate would betray her conscience and faith, citing Catholic teaching. At the pleading stage, the court said, these allegations sufficiently connect their beliefs to the refusal to be vaccinated and plausibly establish that those beliefs are essential components of their respective faith traditions.

The 4th Circuit emphasized that this ruling does not confer a blanket right to religious exemptions: employers may still deny accommodations that impose an undue hardship, and employees will ultimately have to prove the sincerity of their beliefs. But the district court erred in dismissing the claims before any factual development.

The court, however, affirmed dismissal of the plaintiffs’ ADA claims, holding that asking employees about vaccination status is not a disability-related inquiry.

The 11-page opinion is Finn v. Humane Society of the United States, Lawyers Weekly No. 001-184-25.