US Circuit Court rules that termination of unvaccinated worker is not a violation of Title VII

January 28, 2025

On January 17, 2025, the 1st US Circuit Court of Appeals ruled that the termination of an employee for refusal to be vaccinated for the COVID-19, was not a violation of Title VII of the Civil Rights Act of 1964.


The Plaintiff alleged that the Defendant’s failure to grant a religious exemption in relation to the COVID-19 vaccine was a violation of Title VII and would not have imposed any undue hardship on the employer. The Court found that there was undisputed evidence that the Defendant relied on objective medical evidence, including public health guidance from the federal government and Commonwealth of Massachusetts when it set its vaccine policy. There was no medical evidence to contradict the Defendant’s conclusion that vaccinated individuals are less likely to infect others. Thus, the court rejected the no-undue-hardship argument of the plaintiff.  


While the 1st Circuit denied Plaintiff’s religious accommodation claims in this case, the 1st Circuit specifically noted that this was a narrow ruling only in relation to the fact that the Defendant had relied on objective medical evidence in making its decision. Other religious accommodation claims in relation to the COVID-19 vaccine, therefore, might not be subject to dismissal given other factors. As such, it is prudent to contact counsel should a claim or allegation of religious accommodation in relation to the COVID-19 vaccine arise.


If your business has any questions on this topic or any other matters, please do not hesitate to contact the attorneys at The Royal Law Firm at 413-586-2288.

December 5, 2025
Our attorneys successfully obtained summary judgment in favor of the Defendant from the Massachusetts Appeals Court in a Wage Act and contract dispute. The Complainant alleged entitlement to a substantial variable compensation award following resignation. We demonstrated that the compensation plan made such awards discretionary and contingent on continued employment at the time of payout. The Appeals Court agreed, finding that the award did not constitute wages under the Wage Act and that the Defendant acted lawfully in denying payment. All claims were dismissed in their entirety.
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