Labor & Employment Law Daily Wrap Up, DISCRIMINATION—RELIGIOUS—5th Cir.: Honeywell employee fired for refusing COVID vax revives bias claim on appeal, (Aug 6, 2025)

By Brandi O. Brown, J.D.

A reasonable jury could find that the employee “held at least a mixed motive for his vaccine refusal: a bona fide religious belief alongside political beliefs and personal preference.”

In an appeal by a former Honeywell dock operator of a summary judgment decision against his claim of religious discrimination, the Fifth Circuit reversed and remanded the case back to the district court, explaining that a reasonable jury could find that, at least, the employee had a mixed motive for refusing the COVID vaccine—a bona fide religious belief alongside personal preference and political beliefs. His evidence “would be better weighed by a jury than by the court at the summary judgment stage” (Wright v. Honeywell International, Inc., No. 24-30667 (5th Cir. Aug. 5, 2025)).

Vaccine mandate. For 14 years, the employee worked as a dock operator at a Honeywell chemical processing plant in Louisiana. In late 2021, the employer adopted a mandatory COVID-19 vaccine policy after an executive order mandated that federal contractors require all employees who work on or with a federal contract to become fully vaccinated against COVID-19 unless they received a religious or medical exemption.

Religious exemption request. In his subsequent request for a religious exemption, the employee described why his religious beliefs prevented him from getting a COVID-19 vaccine, stating that he is a Baptist and that he believed “our creator gave us this gift to choose and decide for ourselves” and that it is “in our constitution no man should be forced to do something he . . . is not comfortable with.” He also explained that his religion does not “prevent[]” him from receiving the vaccine, “but cert[ai]n passages le[ad him] to feel very strongly about” his decision.

He also attested on his exemption request form that he “didn[’]t like the respon[s]e [his] body had” to a tetanus vaccine in 2015. He admitted this was the first time that he had sought a religious exemption from a mandatory vaccine. He also submitted a third-party attestation letter in which his daughter stated that the vaccine is the “mark of the beast” because it is man-made and went against their religion.

Denied and fired, then lost on summary judgment. The employer denied his exemption. When he still did not get vaccinated, the employee was placed on active suspension, then fired. He filed an EEOC charge and then filed suit, alleging Title VII claims for religious discrimination. The lower court granted the employer’s motion for summary judgment, concluding that the employee “failed to provide sufficient admissible evidence to raise a genuine issue of material fact that he both (1) had a bona fide religious belief at the time of termination and (2) informed [Honeywell] of this religious belief.” The employee appealed.

Appealed. A burden-shifting framework is used to analyze Title VII claims for religious discrimination, the Fifth Circuit explained, considering his appeal. First, the employee had to establish a prima facie case by presenting evidence that: (1) he held a bona fide religious belief; (2) that belief conflicted with an employment requirement; (3) he informed his employer of this belief; and (4) he experienced an adverse employment action for failing to comply with the conflicting employment requirement. If he establishes that prima facie case, the burden then shifts to the employer to demonstrate that it reasonably accommodated him or was unable to without undue hardship.

Light touch and rare challenge. According to the employee, the lower court erred in holding he failed to meet his burden as to the first and third prongs. The appeals court agreed. Regarding the first prong, it explained that the employee met his summary judgment burden, noting that the sincerity of a person’s religious belief is a question of fact that is unique to each case and that, as stated by the court in a previous case, “Bona fide religious beliefs include ‘moral or ethical beliefs as to what is right and wrong which are sincerely held with the strength of traditional religious views.’”

The court noted that it has cautioned previously that the “judicial inquiry” regarding sincerity “must be handled with a light touch, or judicial shyness” and that the “sincerity” of one’s “‘engagement in a particular religious practice is rarely challenged,’ and ‘claims of sincere religious belief in a particular practice have been accepted on little more than the plaintiff’s credible assertions.’” Nevertheless, the court noted that the belief can not just be a preferred practice but must be a religious objection that the employee sincerely believes he must uphold.

Sincere, even with political, personal statements. In this case, the employee’s answers on his exemption request form, his daughter’s third-party attestation, the employee’s deposition testimony, and the testimony of his expert witness was evidence “sufficient to establish a genuine dispute of material fact” as to whether the employee held a bona fide religious belief. They all referenced religious reasons for his refusal and while his deposition testimony and exemption request form also included “some political statements and personal-preference-based reasons for his vaccine refusal, the sincere religious content of these documents is self-evident,” the court concluded.

“In his own scheme of things,” religious? A reasonable jury, the court concluded, could find that the employee “held at least a mixed motive for his vaccine refusal: a bona fide religious belief alongside political beliefs and personal preference.” His evidence “demonstrates a “moral or ethical” belief in bodily autonomy and freedom to choose what to put in his body” and the “fact that he gave additional reasons for his vaccine refusal does not show that his belief is “merely a preferred practice.”” Instead, it showed that the refusal was based on both religious and non-religious reasons. Moreover, the appeals court explained, the inquiry on this prong is about whether his belief is a true religious tenet of his particular faith, but rather whether the belief is, “in his own scheme of things, religious.” Because a plaintiff’s sincerity in espousing a religious practice is largely a credibility issue, the court added, the employee’s evidence “would be better weighed by a jury than by the court at the summary judgment stage.”

Evidence he informed Honeywell. As for the third prong—whether he informed the employer of this bona fide religious belief—the court agreed that he met his summary judgment burden in that regard as well. His discussion in his exemption request of a religious reason for his vaccine objection, along with his daughter’s third-party affidavit, constitute sufficient evidence for a reasonable jury to return a verdict finding that he informed the employer that his belief was religious, the court explained. It reversed and remanded.

The case is No. 24-30667.

Judge: Elrod, J.

Attorneys: Helen Mary Daniel (Daniel, Williams & Associates) for Donald Wright. Hal David Ungar (Ogletree Deakins) for Honeywell International, Inc.

Companies: Honeywell International, Inc.

Cases: ReligiousDiscrimination Discrimination Covid19 Discharge LouisianaNews MississippiNews TexasNews