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Unvaccinated employee awarded unemployment benefits after denial of religious exemption

In a recent decision, Massachusetts’ highest court has upheld an award of unemployment benefits to a home health aide whose employment with Fallon Community Health Plan was terminated after her request for a religious exemption from the company’s COVID-19 vaccination requirement was denied.

The case, Fallon Community Health Plan, Inc. v. Acting Director of the Department of Unemployment Assistance, centered around Fallon’s October 2021 policy mandating COVID-19 vaccination for all employees. Shanika Jefferson sought a religious exemption based on her sincerely held beliefs but was denied. As a result, her employment was terminated.

Jefferson applied for and was granted unemployment benefits by the Department of Unemployment Assistance. Fallon appealed the decision, arguing that Jefferson engaged in deliberate misconduct and willful disregard of the company’s interests by knowingly violating the vaccination policy, thus putting vulnerable patients at risk.

However, the court disagreed with Fallon’s assertions. Chief Justice Kimberly S. Budd, writing for the court, stated that Jefferson’s good faith effort to comply with the policy by applying for a religious exemption did not constitute deliberate misconduct. The court also found that while Jefferson may have violated the terms of the policy, the critical question was whether it was a “knowing” violation.

In determining whether a violation is “knowing,” the court considered mitigating circumstances. The key factor, in this case, was Jefferson’s sincere religious beliefs, which the court found did not present her with a meaningful choice regarding vaccination.

Ultimately, the Supreme Judicial Court agreed with the Department of Unemployment Assistance, concluding that Jefferson’s violation of Fallon’s policy did not result from a choice for which the legislature intended to withhold unemployment benefits.

This decision highlights the importance of considering religious accommodations and the potential impact on unemployment eligibility when implementing mandatory vaccination policies in the workplace. Employers should be aware that the denial of a religious exemption request may not automatically disqualify an employee from receiving unemployment benefits if their employment is terminated as a result.