The Minnesota Court of Appeals issued four important decisions on June 12, 2023—one precedential and three nonprecedential—which provide valuable guidance to employers and employees regarding religious belief exemption denials and unemployment benefits.
In its precedential case, Tina Goede v. Astra Zeneca Pharmaceuticals, LP, the Court upheld a decision from an unemployment law judge (ULJ) determining that an employee’s refusal to follow company policy constituted disqualifying employment misconduct. There, the employee (Goede) was an account sales manager at Astra Zeneca. Goede’s position required her to meet with customers in-person, some of which included large health care systems that required COVID-19 vaccinations as a prerequisite to entering their facilities. Astra Zeneca had a policy requiring employees to obtain a COVID-19 vaccine, but that policy allowed for religious and medical exemptions. Goede requested a religious exemption but was ultimately denied. She was thereafter terminated for failing to comply with the company’s COVID-19 vaccination policy. Subsequently, Goede applied for unemployment benefits; the Minnesota Department of Employment and Economic Development (DEED), after reviewing her application, issued a determination of ineligibility. Goede then appealed the DEED decision to the ULJ. Following the hearing, the ULJ decided that Goede was properly denied unemployment benefits. According to the ULJ, “Goede does not have a sincerely held religious belief that prevents her from receiving a COVID-19 vaccine.” The ULJ explained that “Goede’s concern is about some vaccines, and that she is declining to take them because she does not trust them, not because of a religious belief.”
Goede thereafter appealed the ULJ’s decision to the Minnesota Court of Appeals. The Court, in finding that the ULJ did not err in its determination that Goede’s refusal amounted to misconduct, focused largely on the testimony and evidence presented at the ULJ hearing. The Court concluded that there was substantial evidence in the record to support the ULJ’s credibility findings including Goede’s testimony that the vaccine “killed more people than it saved”, “doesn’t work”, and that COVID-19 was “just the flu” therefore she does not need the vaccine. Ultimately, the Court upheld that the ULJ properly found Goede’s reasons for refusing the vaccination were purely secular—her lack of trust in the safety and efficacy of the vaccine.
The Court similarly found, in Ahmed Daniel, v. Honeywell International, Inc., that an employee’s refusal to comply with his employer’s reasonable COVID-19 policy amounted to misconduct and was not based on his religious belief. There, the employee (Daniel) was provided a COVID-19 vaccination exemption from Honeywell that was conditioned on weekly COVID testing. Daniel failed to adhere to this condition and was thereafter terminated. When he was denied unemployment benefits, Daniel appealed to the ULJ and testified that his religion is “the bible” and that he believes his “body is the temple of God.” However, Daniel also testified that he believes “physicians [are] of no value” and “have yet to cure anything.” Moreover, Daniel testified that he believed that the law protected him from needing to test for COVID-19. In its decision, the ULJ found that Daniel “feels he should have the free choice to take a medical test” and that his refusal was therefore not based on sincerely held religious beliefs. The Court, on appeal, upheld the ULJ’s determination that Daniel’s actions amounted to misconduct and were secular in nature. The ULJ properly evaluated Daniel’s testimony and found that he had not demonstrated a “sincerely held religious belief.”
However, in its nonprecedential opinion, Benish v. Berkley Risk Administrators Co., LLC, the Court found the opposite result. There, an employee (Benish) was denied unemployment benefits after he was terminated from Berkley for failing to obtain a COVID-19 vaccine. Benish testified at the ULJ hearing that his “religion does not approve nor proscribe vaccinations” but that “taking the COVID vaccine would permanently modify the body that God already made perfect.” While the ULJ issued a decision determining that Benish “did not have sincerely held religious belief” therefore his refusal was misconduct, the Minnesota Court of Appeals held that Benish had “consistently testified that his reason for refusing was religious.” The Court emphasized that Benish’s reasoning was different than Goede because her refusal was secular and therefore ineligible for benefits whereas his was based on sincere religious belief.
The Court, in Rachel Millington v. Federal Reserve Bank of Minneapolis, similarly found that an employee was entitled to unemployment benefits based on her sincerely held religious belief. The Court explained that while the facts were similar to its precedential opinion in Goede, there were important distinctions. Both Millington and Goede asserted their belief that the COVID-19 vaccine had a connection to fetal cell lines which prevented them from taking the vaccine because of their religious opposition to abortion. Goede, however, testified that she would not take the vaccine even if it had no connection to fetal cells or abortion because it “doesn’t work.” By contrast, Millington testified that her “number one” reason for not getting the vaccine was religious—even if the vaccine was 100% safe, she still would not take it because of her beliefs as a “pro-life Christian.” The Court found that Millington did have a sincerely held religious belief and that she was thus entitled to unemployment benefits.
Bottom Line
Employers and employees in Minnesota should take note of the Court’s recent decisions, especially Goede, because these decisions demonstrate the Court’s careful balance between secular and non-secular reasoning for unemployment benefit denials. An employee who claims that they cannot get a COVID-19 vaccine based on religious belief will likely need to demonstrate that their religious belief is the paramount reason for refusal—anything less or contradictory could be found insufficient.
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