February’s Employment Appellate Roundup highlights important legal decisions

In the recent Employment Appellate Roundup, various significant employment law developments in federal courts of appeal have been highlighted.

One notable case from the First Circuit, Melino v. Bos. Med. Ctr., 127 F.4th 391 (1st Cir. 2025), involved a claim of religious discrimination under Title VII. The plaintiff requested a religious exemption from the hospital’s COVID-19 vaccination mandate and was terminated for refusing vaccination. The district court granted summary judgment for the hospital, ruling that granting the exemption would impose undue hardship due to increased COVID-19 transmission risks. The First Circuit upheld this decision, emphasizing the employer’s reliance on scientific data, including CDC recommendations supporting vaccine efficacy in mitigating virus spread.

In Murray v. UBS Securities LLC, __ F.4th __ (2d Cir. Feb. 10, 2025), the Second Circuit addressed the standard of proof in a whistleblower retaliation case. The plaintiff alleged termination following whistleblowing activities violating SEC regulations. The jury instruction defining a “contributing factor” in termination was deemed overbroad by the Second Circuit, emphasizing that whistleblowing should be directly responsible for adverse employment actions rather than merely influence decisions.

In Kramer v. Am. Elec. Power Exec. Severance Plan, __ F.4th __ (6th Cir. Feb. 10, 2025), the Sixth Circuit upheld summary judgment for an employer in an ERISA benefits recovery claim, citing the arbitrary-and-capricious standard for reviewing benefit denials. The court found substantial evidence supporting the termination for cause due to policy violations, leading to the denial of employee benefits.

The Eleventh Circuit, in Rosado v. Sec’y, Dep’t of the Navy, 127 F.4th 858 (11th Cir. 2025), clarified summary judgment standards in federal-sector discrimination cases compared to private-sector cases. Federal employees need to demonstrate that protected characteristics were a factor in employer decision-making to defeat summary judgment. The court found insufficient evidence of discrimination in promotion decisions or retaliation for discrimination complaints in the case at hand.

Overall, these appellate decisions shed light on the evolving landscape of employment law and emphasize the necessity for employers to comply with legal standards in areas such as vaccination requirements, whistleblower protections, benefit denials, and discrimination claims. As the courts continue to interpret and apply existing laws, employers must remain vigilant in upholding employee rights and obligations under federal regulations.