Hospital Entitled to Summary Judgment in COVID-19 Vaccine Termination Case

A Massachusetts hospital can terminate the employment of an unvaccinated employee without violating the employee's rights under Title VII or the Massachusetts General Laws Chapter 151B, according to a recent court decision. The hospital showed that accommodating the employee's request for a religious exemption from its COVID-19 policy would have resulted in significant costs that amount to undue hardship. The court found that the employee's refusal to be vaccinated would have put patients and staff at risk of COVID-19 transmission, and the hospital's reputation for providing safe care would have been harmed.

Key Takeaways:

• The hospital demonstrated that accommodating the employee's request for a religious exemption would have resulted in significant costs, including increased risk of COVID-19 transmission to patients and staff, staffing shortages, and harm to the hospital's reputation.
• The court found that the employee's refusal to be vaccinated was not protected conduct under Title VII or the Massachusetts General Laws Chapter 151B.
• The hospital's decision to terminate the employee's employment was based on the hospital's COVID-19 policy, which required vaccination to protect patients and staff.
• The court determined that the employee failed to adduce evidence to support her contention that the COVID-19 vaccine is ineffective.
• The hospital is entitled to summary judgment on the employee's religious discrimination claims under Title VII and the Massachusetts General Laws Chapter 151B.
• The court also found that the employee's allegation of unlawful retaliation was without merit, as she did not oppose COVID-19 vaccination before the hospital announced its policy.

Statistics:

• 1,200 patients treated for COVID-19 at the hospital before implementing the COVID-19 policy.
• 200 patients died from COVID-19 or related complications.
• Several hundred staff members contracted COVID-19 during this period.
• The hospital had to convert a unit and use wings of other units to care for patients with COVID-19.
• The cost of accommodating the employee's request for a religious exemption would have been significant, including increased risk of COVID-19 transmission and staffing shortages.

Sources:

• Geronimo v. Melrose-Wakefield Healthcare Corporation, Lawyers Weekly No. 02-394-25 (July 22, 2025).
• Massachusetts General Laws Chapter 151B.
• Title VII, 42 U.S.C. 2000e-3(a).
• Geronimo v. Melrose-Wakefield Healthcare Corporation, 1:23-cv-11138-JEK.