Not just by calling your beliefs wrong. The Appeals Court revived a hospital worker’s religious discrimination claim after her employer denied her COVID-19 vaccine exemption and fired her, holding that a jury could find her beliefs religious and that the employer had not proved undue hardship. This is a published decision of the Appeals Court and is binding statewide.
Update (October 2026): In Jangl v. Secretary of the Executive Office of Health and Human Services, No. 25-P-168 (Mass. App. Ct. October 15, 2026), a published decision, the Appeals Court distinguished this case and upheld summary judgment for a state employer on undue hardship. Unlike the hospital here, that employer filed affidavits from a medical expert and agency officials, and the worker offered no evidence in response.
What happened
The employee started work as a certified surgical technologist at a hospital in the UMass Memorial system in July 2021. In September 2021 the health system announced a systemwide COVID-19 vaccination requirement. The policy allowed medical and religious exemptions, and it listed accommodations for exempt workers: N95 masks and eye protection, distanced meals, and frequent testing, or a transfer to another job if one was available. The employee asked for a religious exemption. She wrote that her body is a temple of God, that she consults the Bible and prays to God for guidance, and that her refusal was a message from her God. A system committee denied the request in a short note, saying her reasons relied on false information about the vaccine changing a person’s genes. She was fired in December 2021. A Superior Court judge granted summary judgment to the health system, ruling that her beliefs were not religious, that accommodating her would be an undue hardship, and that the system was not her employer.
What the court decided
In Jeune v. UMass Memorial Health Care System, 106 Mass. App. Ct. 95 (2025), the Appeals Court reversed on all three grounds.
The beliefs could be religious. Massachusetts law bars an employer from making a worker violate her creed or religion to keep her job, and requires reasonable accommodation of religious needs unless it would cause undue hardship. G.L. c. 151B, § 4(1A). The employee must first show a conflict with a sincerely held religious practice. Massachusetts Bay Transp. Auth. v. Massachusetts Comm’n Against Discrimination, 450 Mass. 327 (2008). Relying on several recent federal appeals court decisions, the court held that a belief that your body is God’s temple, and that you must follow guidance you receive in prayer, is a belief a jury could find religious. The employer could still argue at trial that she was not sincere. But a judge may not decide what is or is not religious doctrine.
The employer did not prove undue hardship. Once the worker shows a conflict, the burden shifts to the employer. An employer that never looked for an accommodation must conclusively show that every conceivable accommodation would be an undue hardship. Brown v. F.L. Roberts & Co., 452 Mass. 674 (2008). Speculation is not enough. Here the health system’s own policy offered accommodations to exempt workers, which strongly suggested it could accommodate without undue hardship. It offered no expert evidence that masking and testing would fail for a surgical technologist, and no evidence that no other job was open. A general concern about its reputation was not proof of concrete harm.
The parent system could be a joint employer. The health system argued it was only the parent company and that the hospital was her employer. But the system set the vaccine policy, kept her employment records, and signed the letter that fired her. Its own officer’s affidavit was contradicted by his deposition testimony. A jury could find the system was her joint employer under c. 151B.
What this means for you
If you asked your employer for a religious exemption or accommodation, this decision matters in three ways.
First, an employer cannot reject your request simply because it thinks your stated reasons are mistaken or unscientific. The question is whether your belief is religious and sincerely held, not whether the employer agrees with it.
Second, the employer carries the burden to prove undue hardship with real evidence. If it never explored accommodations, or if it gave the same accommodation to other workers, that burden is hard to meet. An employer that comes forward with expert evidence specific to your job may be in a stronger position, so the details of your role matter.
Third, you may be able to hold a parent company responsible if it set the policy, ran human resources, or made the decision to fire you, even if your paycheck came from a subsidiary.
This decision sends the case back for trial. It does not decide that the employee wins. A jury will still weigh sincerity and the other issues.
What to do now
- Put your request for a religious accommodation in writing and explain, in your own words, how the requirement conflicts with your religious beliefs or practice.
- Keep every policy, denial letter, and email, including anything showing accommodations given to other employees.
- Write down who made each decision and which company they worked for.
- Note the date of any denial or firing. A discrimination complaint with the Massachusetts Commission Against Discrimination generally must be filed within 300 days. G.L. c. 151B, § 5.
- Talk to a lawyer before you sign any separation agreement or release.
If this is your situation, call Doubleday Law at (617) 575-2006 or tell us what happened. Deadlines for discrimination and employment claims can be short.
