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US Circuit Court rules that termination of unvaccinated worker is not a violation of Title VII

January 28, 2025

On January 17, 2025, the 1st US Circuit Court of Appeals ruled that the termination of an employee for refusal to be vaccinated for the COVID-19, was not a violation of Title VII of the Civil Rights Act of 1964.


The Plaintiff alleged that the Defendant’s failure to grant a religious exemption in relation to the COVID-19 vaccine was a violation of Title VII and would not have imposed any undue hardship on the employer. The Court found that there was undisputed evidence that the Defendant relied on objective medical evidence, including public health guidance from the federal government and Commonwealth of Massachusetts when it set its vaccine policy. There was no medical evidence to contradict the Defendant’s conclusion that vaccinated individuals are less likely to infect others. Thus, the court rejected the no-undue-hardship argument of the plaintiff.  


While the 1st Circuit denied Plaintiff’s religious accommodation claims in this case, the 1st Circuit specifically noted that this was a narrow ruling only in relation to the fact that the Defendant had relied on objective medical evidence in making its decision. Other religious accommodation claims in relation to the COVID-19 vaccine, therefore, might not be subject to dismissal given other factors. As such, it is prudent to contact counsel should a claim or allegation of religious accommodation in relation to the COVID-19 vaccine arise.


If your business has any questions on this topic or any other matters, please do not hesitate to contact the attorneys at The Royal Law Firm at 413-586-2288.

April 10, 2025
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April 9, 2025
The United States District Court for the Northern District of New York issued an order granting summary judgment in favor of the Defendant, a school district, in a claim brought pursuant to the Americans with Disabilities Act (ADA). The Court agreed that the Plaintiff, a teacher, did not qualify for accommodation under the ADA because she could perform her job fully without the accommodation. It was agreed upon that her job functions could be performed but under “great duress and harm.” The Plaintiff appealed this decision to the United States Court of Appeals for the Second Circuit. The Court disagreed with the USDC NY decision, stating that “an employee may qualify for a reasonable accommodation even if she can perform the essential functions of her job without the accommodation.” For Employers This ruling reminds us that the crux of the ADA is if the accommodation is reasonable, aimed at mitigating disability related limitations, and does not place an undue burden on the employer, the employer is expected to fulfill that accommodation. Every request for accommodation should be looked at on a case-by-case basis. A broad metric should not be how a business decides if it should allow any requests for ADA accommodation(s). The attorneys at The Royal Law Firm are dedicated to helping employers navigate ADA accommodations and interpretations in their day-to-day practice and handbooks. If your business has any questions on this topic or any other matters, please do not hesitate to contact the attorneys at The Royal Law Firm at 413-586-2288.
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