Fired Mayo Clinic Employees Who Refused COVID Shots Reinstated

The 8^th Circuit Court of Appeals has ruled that Mayo Clinic may have illegally fired a group of workers, who refused to get COVID-19 shots because of their religious beliefs. A three-judge panel unanimously found that the former Mayo Clinic employees demonstrated that the COVID shot requirement conflicted with their religious beliefs, reversing a decision by the U.S. District Court for Minnesota.^{1 2}

The five plaintiffs, including two nurses, a paramedic, a CT technician and a supervisor, requested religious exemptions for the COVID shot because it contained aborted fetal cells. Two of the religious exemptions were approved but the employees were required to undergo weekly COVID testing, which they refused and cited that testing violated the sanctity of their body. The Mayo Clinic’s policy required all employees to follow its COVID policy by January 2023 or be subject to termination.^{3 4}

The plaintiffs claimed that the Mayo Clinic did not accommodate their religious beliefs in violation of Title VII and the Minnesota Human Rights Act (MHRA). All of the plaintiffs asserted that the COVID policy violated the principle that their “body is a temple,” while three of the plaintiffs claimed that the shot was counter to their anti-abortion beliefs because it contained fetal cell lines.⁵

The District Court dismissed all of the plaintiffs’ claims stating that three of the plaintiffs still had remedies available to them under Title VII. The Court said the other plaintiffs did not plausibly plead that their religious beliefs were violated by the Mayo Clinic’s policies and that the MHRA does not provide relief for religious beliefs.

The EEOC Supported the Plaintiffs

The Equal Employment Opportunity Commission (EEOC) filed an amicus curie brief on behalf of the plaintiffs. The EEOC asked the Appellate Court to overturn the previous court’s “unduly narrow” definition of religion and argued that the district court…

misapplied the relevant standards under Title VII, particularly on a motion to dismiss. Although not required, Kiel and Ringhofer also alleged that their opposition to abortion arose from their religions: Kiel alleged she is a Christian, while Ringhofer alleged he is a Baptist who was raised Catholic.⁶

The Appellate Court explained the three-part test used to establish a religious discrimination case. The employee must show that they have a bona fide religious belief that is counter to an employment policy; that they told their employer of their conflicting belief; and that they faced discipline for not following the employment policy.

The lower court found that the plaintiffs did not satisfy the first two elements of this test when they argued that their “body is a temple” and they could not agree to take the injection with unknown or impure or unknown ingredients, and that their anti-abortion stance stemming from their religious beliefs did not allow them to be injected with a product made with fetal cell lines.⁷

Plaintiff’s Objections to COVID Policy Were Covered by Federal and State Protections

The panel of Appellate Judges disagreed with the district court’s assessment that the plaintiffs refusal to get the shot was not related to their religious beliefs. The Appellate Court stated that when, “the Complaint was read as a whole,” it was clear that the plaintiff’s refusal to get the shot was indeed due to their religious beliefs. Just because some of the plaintiff’s may also have personal or medical reasons for not getting the shot—in addition to their religious beliefs—does not invalidate their claim of religious discrimination and they are still protected by Title VII.

The court cited EEOC guidance:

[O]verlap between a religious and political view does not place it outside of the scope of Title VII’s religious protections, as long as the view is part of a comprehensive religious belief system.⁸

The higher court also disagreed with the District Court’s reasoning that the fact that other Christians received the shot defeats the current plaintiff’s religious claims. Under Title VII, religious beliefs need not be “acceptable, logical, consistent, or comprehensible to others.”⁹

The Appellate Court explained that federal courts have conflicting decisions as to whether the MHRA protects religious beliefs. However, since courts have found that the MHRA should be interpreted liberally and provides equal or greater protection than federal law such as Title VII, then the Minnesota Supreme Court would likely protect religious beliefs.

The case was reversed and remanded back to the District Court for a new decision.

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