A US federal appellate court on Monday vacated an order of summary judgment against a Federal Reserve Bank employee’s religious accommodation claim arising from the institution’s COVID-19 vaccine mandate. The suit was filed by executive assistants Jeanette Diaz and Lori Gardner-Alfred.
The US Court of Appeals for the Second Circuit issued a mixed ruling, allowing Diaz’s claim to proceed, while affirming the judgment against Gardner-Alfred’s claim. The court found genuine factual disputes regarding Diaz’s Catholic-based objections to vaccines. Significantly, the court held that her beliefs do not need to align with official Catholic doctrine, analogizing that “Martin Luther was regarded by the Catholic Church as a heretic,” but still held sincere religious beliefs.
Monday’s ruling notes that courts are not permitted to ask whether a particular religious belief is appropriate or true, but are instead tasked with determining the sincerity of the belief. The court determined that summary judgment was inappropriate because there was a genuine dispute about Diaz’s state of mind. The case now returns to the district court for trial on Diaz’s remaining claims.
The court reached the opposite conclusion for Gardner-Alfred. Her inability to provide basic details about her religious organization rendered her testimony “wholly contradictory, incomplete, and incredible.” Monday’s ruling also affirmed more than $50,000 in sanctions against both plaintiffs.
In 2022, the Federal Reserve Bank of New York (FRBNY), a federally chartered corporation that implements monetary policy and regulates banks, denied religious exemptions to the two employees who refused COVID-19 vaccinations. Diaz and Gardner-Alfred were both terminated for refusing to comply with the bank’s vaccine policy. The employees filed suit in New York state court seeking injunctive relief, but the FRBNY removed the case to federal court. Diaz, a Catholic, argued a religious objection to vaccines she believed were “created using human cell lines derived from abortion.” Gardner-Alfred claimed a 20-year membership in the “Temple of the Healing Spirit,” an organization that opposes Western medicine.
After nearly a year of discovery marked by the plaintiffs’ misconduct, including the willful withholding of relevant documents and violations of court orders, the federal district court imposed over $50,000 in sanctions against the employees. The district court found that neither plaintiff demonstrated sincerely held religious beliefs, and summary judgment was granted to the bank.
The Second Circuit joins the Seventh Circuit’s Passarella v. Aspirus and Sixth Circuit’s Sturgill v. American Red Cross 2024 rulings in holding that employees don’t inherently forfeit religious accommodation claims because they also expressed secular vaccine concerns. This emerging consensus follows a flurry of vaccine-related litigation dating back to 2021.
