HR Legalist

Pennsylvania Court Dismisses Religious Discrimination Claim Over COVID-19 Vaccine Mandate

In a win for employers, a Pennsylvania Federal Court recently dismissed a religious discrimination case filed by a Christian employee who refused to comply with her employer’s COVID-19 vaccine mandate, finding that her inability to attend in-person events posed a competitive disadvantage to her employer.

In Romaine Cleckner v. 3M Company,[1] Romaine Cleckner worked as a medical device specialist for 3M, promoting 3M’s products in healthcare facilities. At the onset of the COVID-19 pandemic, Cleckner began working remotely. However, once vaccines became widely available, 3M reinstated its pre-pandemic requirement for in-person work.

Pursuant to the Centers for Medicare and Medicaid Services (CMS) mandate, 3M required employees who previously performed in-person roles at healthcare facilities to be vaccinated against COVID-19. While 3M provided an online portal to request exemptions, the company denied Cleckner’s request for a religious exemption.

In her first request, Cleckner asserted that receiving the vaccine would violate her religious beliefs, claiming she could not alter her cells or immune system, and that God had directed her not to receive the vaccine. Notably, she had previously received other vaccines. On her second attempt for exemption, she cited her belief that all the available vaccines were connected to aborted fetal cells.

After her exemption requests were denied, 3M terminated Cleckner for failing to comply with its vaccination policy. Cleckner then filed suit, alleging religious discrimination under Title VII of the Civil Rights Act and the Pennsylvania Human Relations Act (PHRA), among other claims.

The District Court held that Cleckner’s belief articulated in her first exemption request constituted an “isolated moral commandment” that was self-defined and not part of a comprehensive religious doctrine. The Court reasoned that providing blanket protection for such beliefs would impose unwanted legal obligations and create an unmanageable “blanket privilege.” However, the Court held that abortion-related beliefs were sufficient to survive a motion to dismiss. Therefore, the Court continued on to analyze whether Cleckner’s second accommodation request constituted an undue hardship on 3M.

Citing multiple decisions of the Third Circuit Court of Appeals, the court reiterated that an employer can defeat a religious discrimination claim by showing that accommodating the employee’s belief would impose an “undue hardship.”

3M argued that in the competitive healthcare industry, in-person work was essential. While 3M’s competitors were sending their employees out to promote their products in person at healthcare facilities, exempting employees like Cleckner from vaccination, and therefore in-person work, would hinder 3M’s ability to compete. Additionally, 3M contended that granting a significant number of vaccine exemptions could increase the risk of COVID-19 transmission, leading to potential production disruptions and increased health risks for employees, healthcare providers, and patients.

The Court found Cleckner’s argument that she could continue to work remotely as she had during the early pandemic was unpersuasive. It emphasized that ongoing remote work was no longer a viable substitute for in-person engagement in the healthcare industry.

Ultimately, the Court concluded that requiring 3M to accommodate Cleckner’s refusal to be vaccinated would impose an undue burden by reducing the company’s competitiveness and increasing health-related risks and costs.

This case underscores the importance of having well-documented, consistently applied policies around vaccination and religious accommodations especially in industries where in-person work is essential to maintaining competitiveness. Employers should be mindful that while Title VII requires reasonable accommodations for sincerely held religious beliefs, those accommodations need not be granted if they would cause an undue hardship. Employers also need to keep in mind that the Supreme Court clarified the standard for employers to demonstrate undue hardship for religious accommodations in 2023 (Groff v. Dejoy, 600 U.S. 447 (2023), covered by HR Legalist here). In Cleckner, the court cited Groff in its decision, noting that undue hardship required a showing of a burden that is significant in the overall context of the employer’s business. The standard considers not just individual cases, but the broader implications of allowing widespread exemptions. This decision reinforces that “undue hardship” includes not only financial or logistical burdens but also competitive disadvantages in the marketplace.

Have questions about vaccine mandates or religious accommodations in the workplace? Contact an Obermayer labor and employment attorney to ensure your policies and decisions are legally sound.

[1] [Cleckner v. 3M Co., No. 1:22-CV-02055, 2025 LX 300827 (M.D. Pa. Sep. 2, 2025)]

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