Federal Judge Dismisses NYC Teacher’s Religious Discrimination Lawsuit Over COVID-19 Vaccine Mandate
Brooklyn, NY – A federal judge has dismissed a lawsuit brought by a New York City special education teacher who claimed she was unlawfully terminated for refusing the COVID-19 vaccine on religious grounds.
In a ruling issued this week, U.S. District Judge Brian M. Cogan granted summary judgment to the New York City Department of Education (DOE), finding that Michelle Beckles’ refusal to comply with the vaccine mandate would have imposed an “undue hardship” on the city’s public school system, particularly given her close-contact role with medically vulnerable students.
Beckles, a Christian who opposes vaccination on religious grounds, filed suit under Title VII of the Civil Rights Act of 1964. She claimed the DOE unlawfully denied her requests for religious exemption from the city’s vaccine mandate and ultimately fired her in retaliation for her beliefs.
Judge Cogan disagreed.
“The summary judgment record makes undeniable, as a matter of law, that her proposed accommodations would have imposed an undue hardship on defendant,” the judge wrote.
A Teacher in Close Contact
Beckles, a special education teacher since 2005, worked with students who had severe medical conditions and required hands-on assistance — including guiding their hands, managing seizures, and helping bedridden children with daily tasks.
The DOE argued, and the Court agreed, that exempting Beckles from vaccination would have created a “substantial increased risk and cost” for both student safety and school operations.
Cogan noted that public health concerns during a pandemic are “not theoretical,” and that Beckles’ daily, close-contact duties made accommodation unworkable.
Two Rejected Requests, No Appeal
After the vaccine mandate was announced in August 2021, Beckles applied for a religious exemption — twice. Both requests were denied. She was placed on unpaid leave in October 2021 and terminated in February 2022, one day before the mandate was rescinded.
She filed suit in federal court within 90 days of receiving a right-to-sue letter from the EEOC.
Beckles initially raised three claims — under federal, state, and city anti-discrimination laws — but voluntarily withdrew the state and city claims, leaving only the Title VII claim for the court to consider.
No Dispute of Fact
Judge Cogan emphasized that the case did not involve a factual dispute, but rather a legal conclusion: that Beckles’ refusal to be vaccinated posed too great a burden for her employer to accommodate without compromising student health.
“Undue hardship,” the judge explained, doesn’t require proof of actual harm but rather a substantial risk of harm — which, in the middle of a public health crisis, was satisfied.
The court concluded that Beckles’ termination was lawful and dismissed her claim.
