Case updates this week:

September 16: In Byam v. New York City Department of Education, the United States District Court of Eastern District of New York denied the Defendant New York City’s Department of Education (“DOE”) motion for summary judgment in a Title VII case in which the DOE had denied its employee a religious accommodation to its vaccination mandate on the grounds of undue hardship.

Ultimately, the Court determined that, in this case, there were too many relevant facts in dispute regarding the nature of Plaintiff’s work responsibilities to rule as a matter of law that allowing her to work remotely would cause the DOE undue hardship. Consequently, the Court denied Defendant’s motion for summary judgment.

September 16: The United States District Court denied Defendant Boston Medical Center’s (BMC) motion for judgment on the pleadings in Munroe v. Boston Medical Center. Plaintiff, an employee of BMC, submitted a request for a religious accommodation in connection with BMC’s vaccination mandate. BMC denied the request and eventually terminated Plaintiff’s employment. Plaintiff then filed a complaint against BMC in which she argued that she was a victim of religious discrimination in violation of Title VII of the Civil Rights Act.

Plaintiff claimed to identify as a “Paganist” and that her religious leader was “Mother Nature.” Plaintiff further claimed that her religious beliefs prohibited her from being vaccinated. Defendant did concede that Plaintiff’s beliefs were sincere, but argued that they were personal, not religious beliefs. The Court stated that “to qualify as religious, beliefs need not be acceptable, logical, consistent, and comprehensive to others” and that religion “need not be practiced through a church or other organization.”

The Court concluded that Plaintiff’s claims regarding her beliefs and practices, her use of a religious label, and the expression of Mother Nature as having some qualities of divinity were sufficient to “create a plausible basis” that her beliefs were religious in nature. However, the Court noted that there was “certainly” still a question as to “how a hospital could reasonably accommodate a nurse who is involved in direct patient care, but who does not ‘participate in Western medicine,’ takes no medications . . . and who refused to be vaccinated against a highly contagious disease during a worldwide pandemic.” But because that question had not been raised in the motion, the court could not yet decide it.