Federal Appeals Court Revives Fed Employee’s Religious Accommodation Claim

Court Allows Catholic-Based Objection Case to Proceed
NEW YORK — A federal appellate court has revived part of a lawsuit brought by a Federal Reserve Bank of New York employee who claimed she was unlawfully fired for refusing to get a COVID-19 vaccination on religious grounds.

In a unanimous decision Monday, the 2nd U.S. Circuit Court of Appeals vacated a lower court’s summary judgment against Jeanette Diaz, allowing her claim to move forward. The court found genuine disputes over whether Diaz sincerely believed that receiving the vaccine would violate her Catholic faith, even though her views did not align with official church doctrine.

The court emphasized that judges are not permitted to decide whether a religious belief is “true” or theologically correct, but must instead assess whether the belief is sincerely held. The case now returns to U.S. District Judge Lewis Liman for trial on Diaz’s remaining claims.

Different Outcome for Second Plaintiff
The ruling was split for Diaz’s co-plaintiff, Lori Gardner-Alfred. The court upheld dismissal of her claims, citing testimony it described as “wholly contradictory, incomplete, and incredible.” Gardner-Alfred had claimed a 20-year membership in the Temple of the Healing Spirit, which she said rejects Western medicine.

The decision also upheld more than $50,000 in sanctions imposed on both women for misconduct during the case, including withholding documents and violating court orders.

Background on the Case
Diaz, of Bayonne, New Jersey, and Gardner-Alfred, of the Bronx, New York, worked as senior executive specialists at the New York Fed for 27 and 35 years, respectively. In 2022, the bank denied their requests for religious exemptions from its COVID-19 vaccine mandate. Both women were terminated in March 2022 for failing to comply with the policy.

Diaz argued that her objection was rooted in a belief that the vaccines were “created using human cell lines derived from abortion.” She also expressed non-religious skepticism, including sharing a meme suggesting the names of COVID-19 variants “Delta” and “Omicron” were an anagram for “Media Control.”

Circuit Judge Gerard Lynch wrote that a reasonable jury could conclude either that Diaz was masking a secular agenda in religious terms or that her religious objections were genuine. He also found that the lower court relied too heavily on scientific evidence showing that COVID-19 vaccines were not made with aborted fetal cells, rather than focusing on Diaz’s own beliefs.

Broader Legal Context
The Second Circuit’s decision aligns with recent rulings from the Seventh and Sixth Circuits, which held that employees do not automatically lose religious accommodation claims because they also express secular concerns about vaccines. These decisions are part of an ongoing wave of litigation tied to workplace vaccine mandates that began in 2021.