A post by Prof. Howard Friedman (Religion Clause), which he kindly allowed me to pass along:
Yesterday, the Minnesota Court of Appeals decided four separate appeals from decisions of Unemployment Law Judges who denied unemployment benefits because an applicant refused on religious grounds to comply with an employer's Covid vaccine mandate. Goede v. Astra Zeneca Pharmaceuticals, LP, (MN App., June 12, 2023), was the only one of the four cases published as a precedential decision. The court affirmed the ULJ's denial of benefits even though the state Department of Employment and Economic Development urged its reversal. The court said in part:
The ULJ found that "Goede does not have a sincerely held religious belief that prevents her from receiving a COVID-19 vaccine." The ULJ explained: "Goede's testimony, when viewed as a whole, shows by a preponderance of the evidence that Goede's concern is about some vaccines, and that she is declining to take them because she does not trust them, not because of a religious belief." The ULJ further stated that "[w]hen looking at the totality of the circumstances, Goede's belief that COVID-19 vaccines are not okay to put in her body is a personal belief not rooted in religion."
In Daniel v. Honeywell International, Inc., (MN App., June 12, 2023), the appellate court again upheld a denial of benefits, this time to a former employee who refused both the Covid vaccine and refused to comply with the employer's religious accommodation. The court said in part:
Relator asserts that Honeywell's COVID-19 policy requiring that he get weekly COVID-19 tests and submit the results "required [him] to defy [his] religious faith." He asserts that he was upholding his religious faith "by practicing [his] God given right of 'control over [his] medical' by not subjecting Jesus Christ's temple to forcefully coerced medical treatments such as weekly PCR and/or rapid antigen test requirements."…
The ULJ found that relator lacked credibility because he provided inconsistent testimony and he struggled to explain his religious beliefs.
The court reversed the ULJ's denial of benefits in two other cases. In Benish v. Berkley Risk Administrators Company, LLC, (MN App., June 12, 2023) the court said in part:
