Rachelle Jeune requested a religious exemption after she said she received a “distinctive message from my God” telling her not to get the COVID-19 vaccine.
A UMass Memorial Health surgical tech fired after she said she “prayed to God and received a message” telling her to refuse the COVID-19 vaccine has won an appeal to continue her religious discrimination lawsuit against the health care organization.
The Appeals Court sided with Rachelle Jeune, who was denied a religious exemption from UMass Memorial Health’s COVID vaccine mandate while working at HealthAlliance-Clinton Hospital in 2021. Monday’s decision overturns a lower court judge’s summary judgment dismissing Jeune’s lawsuit.
Jeune submitted her exemption request in October 2021, stating in part that receiving a COVID vaccination “would prevent me from worshipping my God.” She also leveled false accusations that COVID vaccines could genetically alter her body.
“The body is the temple of God,” Jeune wrote, adding that while she would not turn her back on modern medicine, “proceeding with Covid-19 [vaccination] would be a sin against my conscience.”
“I have been diligently praying about the covid-19 vaccine and this letter is my distinctive message from my God,” she concluded.
In rejecting Jeune’s request weeks later, the UMass Memorial religious exemption committee deemed her assertion about the vaccines’ supposed genetics-altering capabilities “patently false” and ruled that “reliance on demonstrably false information cannot be a basis for a religious accommodation.”
According to court filings, the health care system’s COVID vaccine mandate stipulated that employees granted exemptions would be required to wear personal protective equipment, socially distance, and undergo frequent testing. Employees denied exemptions would be allowed to take other jobs within their UMass Memorial entity, if available, or else face firing.
Jeune filed her religious discrimination lawsuit soon after UMass Memorial terminated her employment in December 2021. She’s seeking more than $100,000 in lost wages, attorney’s fees, and other damages, according to the Worcester Superior Court complaint.
With the Appeals Court’s decision, Jeune is now able to revive her lawsuit. The justices specifically concluded that UMass Memorial failed to demonstrate that accommodating Jeune’s request would pose an undue burden.
“In Massachusetts, an employer must accommodate an employee’s genuine religious beliefs if it can do so without creating an undue hardship,” the Appeals Court explained. “We conclude that the plaintiff’s stated beliefs that her body is a temple of God and that she prayed to God and received a message not to receive the COVID-19 vaccination were beliefs that a trier of fact could determine were religious in nature.”
The court further alleged that UMass Memorial did not seek to determine whether a reasonable accommodation was possible, offered no evidence that other jobs weren’t available for Jeune, and provided nothing to suggest its usual accommodations were out of the question due to Jeune’s role as a surgical tech.
While the lower court’s summary judgment found that Jeune “failed to articulate a sincerely held religious belief that precluded her from getting vaccinated,” the Appeals Court disagreed.
“A plaintiff, like the plaintiff here, who believes that she was created in God’s image and that her body is a temple of God and thus needs God’s approval to expose her body to foreign substances, expresses a religious belief,” the court argued. “Moreover, a plaintiff who prays to God and receives a ‘distinctive message from my God’ acts in accordance with religious beliefs when she follows those divine instructions.”
UMass Memorial declined to comment on Monday’s decision, citing the pending litigation.
“Our organization, however, is proud of the heroic efforts by our caregivers who worked tirelessly through the COVID-19 pandemic under the most trying and uncertain of times,” the health care system said in a statement, adding that its vaccine mandate was “in accordance with federal law” and intended to “provide a safe environment for all members of our community — including the immuno-compromised.”
UMass Memorial further said it reviewed religious exemption requests and approved them “when appropriate.”
“UMass Memorial is confident in the fairness with which it treated such requests and remains committed to being a welcoming and inclusive workplace for all members of our community,” the organization added.