In 2025, the United States Court of Appeals for the Second Circuit issued an important decision concerning the evaluation of the sincerity of employees’ objections to vaccine mandates. The ruling highlights several key evidentiary standards applied to evaluating employers' efforts to accommodate employees' religious beliefs. The Second Circuit emphasized that there are only “rare” circumstances where employers may successfully rebut the sincerity of their employees' religious beliefs, and that jurors, not courts, should decide whether employees sincerely object to employers' mandatory vaccine policies based on their religions.
Background
During the height of the COVID-19 pandemic, many U.S. employers instituted mandatory vaccination policies (either voluntarily or pursuant to legal requirements). The Federal Reserve Bank of New York was one such employer.
Shortly after the policy was implemented, two employees alleged that the Federal Reserve discriminated against them by denying their requests for religious exemptions from its mandatory COVID-19 vaccine policy and correspondingly terminating their employment. After filing suit, the District Court granted summary judgment in favor of the Federal Reserve, and both plaintiffs appealed.
The Second Circuit's opinion
On appeal, the Second Circuit affirmed the dismissal of one plaintiff’s claim, finding she failed to demonstrate a sincere religious belief and supported her claim with “only a sham issue of fact” that no...
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