Federal Appeals Court Rules in Favor of Hospital Worker Fired for Refusing COVID Vaccine

An appeals court has reinstated a religious discrimination lawsuit lodged by hospital worker who was fired for refusing the COVID-19 vaccine.
Federal Appeals Court Rules in Favor of Hospital Worker Fired for Refusing COVID Vaccine
A health care worker prepares a COVID-19 vaccine, in a file photograph. (Michael M. Santiago/Getty Images)
Tom Ozimek
Updated:
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A Massachusetts hospital worker who was fired after unsuccessfully seeking a religious exemption from the hospital’s COVID-19 vaccine mandate has scored a win in a federal appeals court, which vacated a lower court’s dismissal of her religious discrimination lawsuit.

In a unanimous decision on Aug. 13, a three-judge panel of U.S. Court of Appeals for the First Circuit in Massachusetts rejected the U.S. District Court for the District of Massachusetts’ summary dismissal of the health worker’s case and ordered the lower court to reconsider her case.

Amanda Bazinet, who worked as an executive office manager at Beth Israel Deaconess Hospital in Milton, asserted a religious objection to getting the COVID-19 vaccine in 2021 after the hospital adopted its vaccine mandate.

In her religious accommodation request, Bazinet said it was her understanding that the currently available COVID-19 vaccines were developed using fetal cell lines that originated from aborted fetuses, arguing that taking the vaccine would make her complicit in the performance of abortions, which was against her Christian faith.

The hospital rejected her request, which led to her termination of employment. Hospital policy was that vaccine refusers would be placed on 14-day administrative leave to encourage their compliance and, failing that, the hospital would deem such employees as having “voluntarily terminated” their employment.

Bazinet sued, claiming that the hospital committed an act of religious discrimination in violation of the 1964 Civil Rights Act and a Massachusetts anti-discrimination law.

The U.S. District Court for the District of Massachusetts dismissed her religious discrimination lawsuit for failing to state a claim. It ruled that her complaint failed to allege that she maintained a sincerely held religious belief that prevented her from taking the COVID-19 vaccine. The court also held that the hospital would suffer an undue hardship by granting her request for an exemption from the vaccine mandate.

Bazinet appealed the decision to the First Circuit, which ruled in her favor.

“We vacate the district court’s order dismissing Bazinet’s religious discrimination claims and remand for further proceedings consistent with this opinion,” the judges wrote, asserting that Bazinet’s complaint sufficiently alleged that taking the vaccine would violate her religious beliefs.

The appeals court also found that the lower court erred in determining that the hospital would suffer undue hardship by excusing Bazinet from the vaccine requirement because such a finding was impossible to determine during a preliminary stage of litigation and was therefore premature.

The appeals court judges wrote in their decision that, despite the hospital’s pledge to engage in an “interactive process” to try to identify a reasonable accommodation for employees seeking COVID-19 vaccine exemptions, the hospital in fact denied Bazinet’s request “without engaging in any further process.”

When the appeals court reviewed the facts, including her request, it found that Bazinet sufficiently explained her religious objection to getting vaccinated in her accommodation request, including providing numerous quotations from religious sources that she said supported her view.

“Accepting those allegations as true for present purposes, she has sufficiently pleaded a religious belief that conflicts with receiving the COVID-19 vaccine as required by the Policy,” the appeals court judges wrote, while ordering the lower court to reconsider the case in line with their opinion.

“Whether Bazinet’s religious discrimination claims will succeed or even survive summary judgment is uncertain,” the appeals court judges wrote. “But these claims should have advanced past Rule 12(b)(6).”

Rule 12(b)(6) is a provision under the Federal Rules of Civil Procedure that allows a defendant to request the dismissal of a lawsuit if the plaintiff’s complaint fails to state a claim upon which relief can be granted.

The Epoch Times has reached out to Beth Israel Deaconess Hospital attorneys with a request for comment on the ruling.

Tom Ozimek is a senior reporter for The Epoch Times. He has a broad background in journalism, deposit insurance, marketing and communications, and adult education.
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