The First Circuit Court of Appeals’ recent decision in DeAngelis v. Hasbro, Inc., is a reminder to employers that religious discrimination claims stemming from COVID-19 vaccination policies are not yet a thing of the past. Those cases continue to offer crucial insights for employers as they navigate religious accommodation requests in other contexts.

• On January 29, 2026, the First Circuit reversed the dismissal of plaintiffs’ religious discrimination and retaliation claims arising from their employer’s COVID-19 vaccination policy.
• In doing so, the First Circuit made clear that “my-body-is-my-temple arguments rooted in a plaintiff’s religious beliefs are sufficient to plead the existence of a bona fide religious belief.”
• Additionally, although the employees resigned their employment, the court concluded that allegations regarding the investigation of one plaintiff’s alleged failure to wear a mask at an employer-sponsored event and another plaintiff’s removal from eligibility for promotions could, if proven, constitute adverse employment actions.

Two former employees filed suit against their former employer alleging claims of religious discrimination and retaliation under Title VII of the Civil Rights Act of 1964 and Rhode Island state law. Both employees requested exemptions from the company’s COVID-19 vaccination policy based on their religious beliefs. After the employer denied their exemption requests, the employees ultimately resigned from their positions.

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