In a decision issued October 15, 2026, the Massachusetts Appeals Court affirmed summary judgment against Timothy Jangl, a Department of Children and Families social worker who sought a religious exemption from the state’s COVID-19 vaccination requirement.
According to court documents, Jangl’s role involved extensive face-to-face contact with children and families—including medically vulnerable youth—home visits, court appearances, and emergency responses. After Governor Baker’s Executive Order No. 595 mandated vaccination for executive department employees in August 2021, Jangl requested remote work, masking, and weekly testing as accommodations. The department denied the request, citing undue hardship. He resigned and sued under G. L. c. 151B, § 4 (1A), alleging religious discrimination.
The Superior Court granted summary judgment to the defendants. On appeal, the court rejected Jangl’s challenge to the affidavit of Dr. Lawrence Madoff, medical director of the state’s infectious disease bureau. The judges held Dr. Madoff fully qualified by training and experience; challenges to his methodology were waived, and criticisms of his sources went to weight rather than admissibility.
On the merits, the court found the department met its burden of showing undue hardship. Allowing an unvaccinated employee in this role risked compromising public health and the agency’s ability to serve vulnerable populations amid existing staffing shortages. Jangl offered no contrary expert evidence.
The decision aligns with similar First Circuit rulings and underscores that sincerely held religious beliefs must still yield when accommodation would endanger public health and essential services. Judgment affirmed.