Appeals court hears challenge to UMass Memorial COVID-19 vaccine policy over defendant naming, religious exemption and undue-hardship claims

The Massachusetts Appeals Court heard oral argument Friday in an appeal by Rachel Jaeyoon challenging summary judgment for UMass Memorial over her COVID-19 vaccine-related termination. The three-justice panel — Justice Joseph Ditkoff, Justice Sabida Singh and Justice Paul Smith — pressed both sides on (1) whether the correct employer was named, (2) whether Jaeyoon's exemption request was based on a sincerely held religious belief and (3) whether the employer carried its burden to show undue hardship from an accommodation.

The issue matters because it raises both employer-liability questions under state anti-discrimination law and how courts draw the line between medical objections and religious objections in workplace COVID-19 policies. Appellant counsel said the case could show that a parent organization that sets vaccine policies and denies exemptions can be liable even if a subsidiary wrote paychecks; appellee counsel argued the record showed the wrong corporate defendant was named.

Appellant counsel Attorney Scott, representing Rachel Jaeyoon, told the panel the system-level committee implemented the policy, reviewed exemption requests and denied Jaeyoon's request: "It was also that same committee that denied her religious…