Labor & Employment Law Daily Wrap Up, DISCRIMINATION—RELIGIOUS—N.D. Ill.: Religious discrimination claim brought by employee terminated for refusing COVID vaccine fails to survive summary judgment, (Jun 23, 2025)

By Nicholas Kaster, J.D.

The employee failed to state a claim under the Illinois Religious Freedom Restoration Act because he did not demonstrate how the vaccination policy prevented him from engaging in the basic tenets of his religion.

A federal district court in Illinois has ruled that a religious discrimination claim brought by an employee who was terminated for refusing a COVID-19 vaccination failed to survive summary judgment. The employee presented no evidence on which a reasonable jury could find that his disclosed objection to the COVID-19 vaccine was religious in nature, the court concluded. The employee provided various reasons he could not comply with the vaccine policy, including that the vaccines usually contain “unnatural harmful things;” the vaccines were developed rapidly and without adequate testing; the long-term effects of the vaccines were unknown; and the vaccines were considered experimental by scientists and doctors. However, the employee did not present evidence of how he was “religiously obligated” to avoid the COVID vaccines (Snyder v. Chicago Transit Authority, No. 22 CV 6086 (N.D. Ill. Jun. 20, 2025)).

COVID-19 vaccination policy. In September 2021, the Chicago Transit Authority implemented a mandatory COVID-19 vaccination policy. Employees were required to submit proof that they were fully vaccinated against COVID-19 by November 2021. The vaccination policy allowed employees to submit a Request for Religious Accommodation or Moral Conviction Exemption when a sincerely held religious belief or observance prevented them from receiving the COVID-19 vaccine.

The employee submitted a request for religious accommodation seeking a “full exemption from any vaccines” and boosters. His request for exemption was denied on the grounds that it did not “substantiate a sincerely held religious belief or moral conviction” that conflicted with the CTA’s requirement that all employees be fully vaccinated against COVID-19. When the employee did not comply with the vaccine policy, he was discharged. He sued the CTA, alleging that the employer’s failure to accommodate his request violated Title VII and the Illinois Religious Freedom Restoration Act. The CTA moved for summary judgment.

Religious discrimination claim. To make a prima facie case of religious discrimination under Title VII, a plaintiff must show that: (1) the observance or practice conflicting with an employment requirement is religious in nature; (2) the employee called the religious observance or practice to the employer’s attention; and (3) the religious observance or practice was the basis for the employee’s discharge or other discriminatory treatment. Once an employee has established a prima facie case of discrimination, the burden shifts to the employer to reasonably accommodate the religious practice or show that any accommodation would result in undue hardship.

The CTA conceded that the employee provided notice of an alleged religious practice but argued that he did not show that his objections to the COVID vaccines were sincerely held and religious in nature, nor that the CTA discharged him based on his religion.

Question of sincerity. The CTA argued that the employee did not sincerely hold his anti-vaccination beliefs but simply parroted the beliefs of his minister. The employee testified that most of the information in his request was prepared or confirmed by his minister. The CTA argued that this showed the beliefs were not the employee’s own. But the employee also testified that he personally held these beliefs. The employee’s reliance on his religious leader’s articulation of these beliefs does not negate his own sincerity, the court said.

The CTA also argued that the employee was inconsistent as to the bases for his objection to the COVID vaccines. It argued that the employee’s changing reasoning gave an objective basis to question his sincerity. While inconsistencies may undermine the employee’s credibility, said the court, whether he sincerely holds his religious beliefs is ultimately a question of fact more suitable for a factfinder. Thus, said the court, the employee created a triable issue of fact as to the sincerity of his beliefs.

Religious obligation. However, said the court, the employee failed to present evidence to support a finding that his objection to the COVID-19 vaccines was religious in nature. A belief is religious when it occupies “a place parallel to that filled by God in traditionally religious persons.” Such significant religious beliefs deal with issues of ultimate concern including “the afterlife, spirituality, or the soul.” Religious beliefs should create a religious obligation to practice or observe in a certain matter. Courts may not inquire into the truth or validity of such beliefs, nor does it matter whether the belief is part of a mainstream religion or an idiosyncratic one.

Nonreligious concerns. When seeking an exemption from a vaccine mandate, courts have required plaintiffs show a connection between their opposition to the vaccine and a specific religious belief or practice. Objections to a COVID-19 vaccination requirement that are purely based on social, political, or economic views or personal preferences, or any other nonreligious concerns (including about the possible effects of the vaccine), do not qualify as religious beliefs.

The employee provided various reasons he could not comply with the vaccine policy: vaccines usually contain “unnatural harmful things,” that are “unclean and do harm to the body long-term;” the vaccines were developed rapidly and without adequate testing; the long-term effects of the vaccines were unknown; and the vaccines were considered experimental by scientists and doctors. His cited links discussed vaccine side effects, ingredients, and development.

These beliefs cannot be considered religious in nature, the court said. The professed beliefs that vaccines may contain harmful ingredients and may cause unknown side effects do not “address fundamental and ultimate questions having to do with deep and imponderable matters” and are not “comprehensive in nature.”

Religious practices. The employee’s request for exemption also stated that he practiced the laws of cleanliness and the dietary laws outlined in the books of Leviticus, the 11th Chapter and Deuteronomy, the 14th Chapter. Specifically, the Bible instructed him to refrain from the ingestion of unclean animals, in this instance, pork or derivatives, such as gelatin which were in most vaccines. The employee did not elaborate further as to the religious significance of this practice.

The employee did not present evidence of how this practice made him “religiously obligated” to avoid the COVID vaccines. Even accepting the employee’s belief—that he abstain from “heavy metals,” “animal base product and other unnatural harmful things”—as religious, he did not connect this belief to the COVID vaccinations specifically. At best, said the court, the employee presented evidence of a general religious practice, but not how it is applicable in this specific instance.

The employee argued that he demonstrated a sincerely held belief by showing it was central to his life or faith, consistent in his actions and requests, and that he adhered to it even if it doesn’t align with mainstream doctrines. But he offered no legal or factual support for these statements. A plaintiff cannot rely on speculation and conclusions unsupported by evidence in the record at summary judgment. The employee presented no evidence on which a reasonable jury could find that his disclosed objection to the COVID-19 vaccine was religious in nature, the court concluded.

The CTA also showed that it had a legitimate business reason to discharge the employee: he failed to comply with the vaccine policy. An employer action based on safety concerns and noncompliance with a work policy is a legitimate business reason for adverse employment action. The CTA’s reasons for discharging the employee remained constant—he was subject to discipline and discharge because of his failure to comply with the vaccine policy. The employee submitted no evidence that indicated the CTA’s reason for discharging him was false. The CTA was therefore entitled to summary judgment on the employee’s Title VII claim, the court held.

Illinois Religious Freedom Restoration Act. To support a claim under the Illinois Religious Freedom Restoration Act, a plaintiff must first show that government action substantially burdened the exercise of his religion through any rule or enactment, even if it is a rule of general applicability. Once the plaintiff has established the substantial burden on the exercise of his religion, the government may defend its rule by showing that the application of the burden to the person is in furtherance of a compelling governmental interest and is the least restrictive means of furthering that compelling governmental interest.

The employee did not demonstrate how the vaccination policy prevented him from engaging in the basic tenets of his religion. His state law claim was based on his objection to the vaccines because of the connection between all three COVID-19 vaccines and the cell lines of aborted fetuses. He alleged that he holds a sincere religious belief “that all life is sacred, from the moment of conception to natural death, and that abortion is a grave sin against God and the murder of an innocent life.” Beyond his complaint, however, the employee failed to present any evidence of this religious belief.

On this record, the court concluded, no reasonable jury could find that the CTA’s vaccine policy was a substantial burden on the employee’s religious exercise. Accordingly, the CTA’s motion for summary judgment was granted.

The case is No. 22 CV 6086.

Judge: Shah, M.

Attorneys: Rashon Snyder, pro se. Peter Conrad McNamara (International Union of Operating Engineers) for Chicago Transit Authority.

Companies: Chicago Transit Authority

Cases: Discrimination ReligiousDiscrimination Discharge Covid19 StateLawClaims IllinoisNews