The 1st U.S. Circuit Court of Appeals has revived a religious discrimination lawsuit against Beth Israel Deaconess Hospital, overturning a lower court’s dismissal.

The case involves Amanda Bazinet, a former executive office manager who was fired after refusing the COVID-19 vaccine on religious grounds.

Bazinet claimed that the vaccines were developed using fetal cell lines originating from aborted fetuses, a practice she believed would make her complicit in an action contrary to her Christian faith. She requested an accommodation under which she would test frequently and wear a mask instead.

The hospital denied Bazinet’s request, apparently without engaging in an interactive process. Instead, it allegedly told her that her proposal to wear masks and take periodic COVID tests was inadequate and that allowing her to work without the vaccine would cause the hospital undue hardship.

When Bazinet continued to refuse the vaccine, the employer deemed her “voluntarily terminated.” Bazinet ultimately filed suit in U.S. District Court, alleging that the hospital committed religious discrimination in violation of Title VII of the Civil Rights Act. A U.S. District Court judge dismissed that claim, ruling that Bazinet had failed to allege a sincerely held religious belief.

In August 2024, the 1st Circuit reversed. The appeals court’s decision, written by Judge Seth R. Aframe, emphasized that the sincerity of Bazinet’s beliefs should be considered, regardless of their factual accuracy or how widely they are shared.

“Bazinet … grounded her objection to taking the vaccine in a religious belief connecting the COVID-19 vaccine to opposition to abortion,” Judge Aframe wrote for the panel. “Whether few or many share that religious view is irrelevant. For similar reasons, it is also irrelevant at this stage of the litigation that the Hospital tells us that Bazinet is mistaken in believing that the COVID-19 vaccines were developed from fetal tissue obtained from aborted fetuses. That the Hospital disputes Bazinet’s factual foundation for her belief about the development of the vaccines does not change the religious character of the belief.”

Additional issues

Notably, the court rejected the hospital’s argument that Bazinet’s exemption request appeared to stem from “cookie-cutter, anti-vaccine forms” available online. Instead, it determined that Bazinet had adequately tied her faith to her objection by citing religious sources and explaining her position. Further, the panel rejected the hospital’s argument that Kiel v. Mayo Clinic Health Sys. Southeast Minnesota, a 2023 federal District Court decision from Minnesota, supported its position that Bazinet had not in fact pleaded a sincerely held religious belief given that many Christians opposed to abortion had taken the vaccine.

“After the Hospital filed its brief in this Court, the Eighth Circuit … properly rejected Kiel’s rationale because the fact that many Christians have elected to receive the vaccine does not undermine a particular employee’s religious beliefs on the subject,” Aframe said. “The law does not require that a religious practice or belief at issue be ‘acceptable, logical, consistent, or comprehensible to others.’”

The appellate decision also took issue with the lower court’s conclusion regarding undue hardship. The appeals court found that more factual development was necessary before determining whether accommodating Bazinet’s request would pose an undue hardship for the hospital.