Two former employees of Hasbro, Inc., Jennifer DeAngelis and Natalie Tomaselli, sued the toy and game company after resigning. Both women had worked remotely during the pandemic and requested religious accommodations to be exempted from Hasbro's mandatory COVID-19 vaccination policy. They cited sincerely held religious beliefs, including objections to substances entering the body without consent and concerns that the vaccines were developed using tissue from aborted fetuses. After Hasbro denied their requests for remote work accommodations and instead issued written warnings regarding alleged mask violations at a charity event months prior, the plaintiffs resigned. They filed suit alleging religious discrimination and retaliation under Title VII. The district court dismissed the case, ruling that the plaintiffs' beliefs were not religious but merely moral, and that the employer's actions did not constitute adverse employment actions. Hasbro removed the case to federal court, where the district court granted the motion to dismiss.
The First Circuit began by addressing the threshold issue of whether the plaintiffs' beliefs qualified as religious under Title VII. Relying on its recent precedents in Bazinet and Thornton, the court held that the plaintiffs' opposition to the vaccine, rooted in beliefs about abortion and the sanctity of the body, was sufficient to plead a bona fide religious belief. The court rejected the district court's distinction between moral and religious objections, noting that a belief can have religious character even if it also has moral dimensions or is held by others for purely moral reasons. The court then turned to the retaliation and discrimination claims. For retaliation, the court applied the plausibility standard, finding that the chronological proximity of the accommodation requests to the issuance of written warnings and the removal of office access supported an inference of causation. The court emphasized that while some individual allegations might be minor, their cumulative weight painted a picture of reprisal that would deter a reasonable worker. Regarding the discrimination claim, the court analyzed whether the alleged actions constituted adverse employment actions. It found that the denial of promotions and the reassignment of DeAngelis's job to a new hire while she was on leave were substantial enough to meet the standard. On causation, the court found it plausible that the warnings were a pretext for religious animus, given the employer's delay in enforcing the mask policy and the disproportionate nature of the punishment following the disclosure of the plaintiffs' religious objections.
The case is remanded to the District Court for the District of Rhode Island for further proceedings. The decision clarifies that employers cannot dismiss religious accommodation claims based on a rigid distinction between moral and religious objections to vaccines. It also signals that a pattern of disciplinary actions, including warnings and denial of promotions, occurring shortly after an employee requests religious accommodation may be sufficient to survive a motion to dismiss, even if the individual acts might seem minor in isolation. The court left open the question of whether the specific accommodations requested were reasonable or if the employer's alternative accommodations were sufficient, as those issues will be resolved at summary judgment or trial.
Podcast (federal-narrative-summaries): Play in new window | Download