August 13, 2025


Federal Court Revisits Employee’s Right to Religious Exemption in Vaccine Mandate Case

In a pivotal legal development, the US Second Circuit Court of Appeals has recently overturned a prior summary judgment, thereby reigniting the debate over religious accommodations in vaccine mandates. This decision stems from a lawsuit filed by former Federal Reserve Bank employees Jeanette Diaz and Lori Gardner-Alfred, who were terminated after refusing COVID-19 vaccinations based on religious beliefs.

Jeanette Diaz, who identifies as Catholic, argued against the vaccine mandate citing her objection to vaccines developed using human cell lines derived from aborted fetuses. Lori Gardner-Alfred, a member of the "Temple of the Healing Spirit," opposed the vaccine on the grounds of her faith's rejection of Western medicine. While the district court initially dismissed their claims for lack of sincerely held religious beliefs, the appellate ruling brought a nuanced perspective to Diaz's case, distinguishing it from Gardner-Alfred’s less substantiated claims.

The appellate court's decision highlighted that Diaz’s religious conviction did not need to align with mainstream Catholic doctrine, drawing an analogy to historical figures like Martin Luther, whose beliefs diverged sharply from prevailing religious norms yet remained sincere. This clarification underscores a broader judicial reluctance to question the authenticity or validity of individual religious beliefs.

Conversely, the court upheld the summary judgment against Gardner-Alfred, pointing to her inconsistent and insufficient explanations regarding her religious practices, which undermined her credibility. Additionally, both plaintiffs faced over $50,000 in sanctions for misconduct during the litigation process, including withholding important documents and violating court orders.

This case adds to a growing body of legal precedents, including notable decisions from the Seventh and Sixth Circuits, which support the stance that employees need not forfeit claims for religious accommodations merely because they also present secular objections to vaccines.

As the case is remanded back to the district court for further proceedings on Diaz's claims, the legal community and employers nationwide will closely watch the outcomes for implications on future enforcement of vaccine mandates and religious accommodations in the workplace. This ruling not only highlights the complexities involved in balancing public health with religious freedoms but also sets a significant precedent for similar cases in the future.