Lavelle-Hayden v. Employment Dept.

The First Amendment’s Free Exercise Clause states that a state cannot deny unemployment benefits to a person who loses their job for conduct based on sincere “beliefs rooted in religion.”

Claimant argues that the Employment Appeals Board (EAB) erred in finding her objection to the COVID-19 vaccine was secular rather than religious, resulting in an improper denial of unemployment benefits under the Free Exercise Clause. Lavelle-Hayden was fired from her hospital job after refusing the COVID-19 vaccine. The EAB denied benefits, concluding that her objection was “more likely than not” personal and not religious. The First Amendment’s Free Exercise Clause states that a state cannot deny unemployment benefits to a person who loses their job for conduct based on sincere “beliefs rooted in religion.” The state must prove that the denial is the least restrictive means in achieving the state's interest. Here, the EAB lacked substantial evidence for its finding, the claimant consistently cited scripture for her reasons and showed evidence of a decade-long flu shot religious exemption. The EAB improperly discounted the evidence and focused on the plausibility of the claim, which is not the standard to follow. Because her objections were religious and sincere, the state could deny benefits only by showing a compelling interest furthered through the least restrictive means. The Employment Department offered no such evidence. Reversed and remanded.