June G. Valent v. Board of Review, Department of Labor and Hackettstown Community Hospital

91 A.3d 644, 436 N.J. Super. 41, 2014 WL 2515589, 2014 N.J. Super. LEXIS 79
CourtNew Jersey Superior Court Appellate Division
DecidedJune 5, 2014
DocketA-4980-11
StatusPublished
Cited by3 cases

This text of 91 A.3d 644 (June G. Valent v. Board of Review, Department of Labor and Hackettstown Community Hospital) is published on Counsel Stack Legal Research, covering New Jersey Superior Court Appellate Division primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
June G. Valent v. Board of Review, Department of Labor and Hackettstown Community Hospital, 91 A.3d 644, 436 N.J. Super. 41, 2014 WL 2515589, 2014 N.J. Super. LEXIS 79 (N.J. Ct. App. 2014).

Opinion

NOT FOR PUBLICATION WITHOUT THE APPROVAL OF THE APPELLATE DIVISION

SUPERIOR COURT OF NEW JERSEY APPELLATE DIVISION DOCKET NO. A-4980-11T2

JUNE G. VALENT,

Appellant, APPROVED FOR PUBLICATION v. June 5,2014

BOARD OF REVIEW, DEPARTMENT APPELLATE DIVISION OF LABOR and HACKETTSTOWN COMMUNITY HOSPITAL,

Respondents.

___________________________________

Submitted September 18, 2013 – Decided June 5, 2014

Before Judges Fuentes, Simonelli and Haas.

On appeal from the Board of Review, Department of Labor, Docket No. 321,223.

June G. Valent, appellant pro se.

John J. Hoffman, Acting Attorney General, attorney for respondent Board of Review (Lewis A. Scheindlin, Assistant Attorney General, of counsel; Lisa N. Lackay, Deputy Attorney General, on the brief.)

Hackettstown Community Hospital has not filed a brief.

The opinion of the court was delivered by

FUENTES, P.J.A.D.

June G. Valent appeals from the decision of the Board of

Review denying her application for unemployment compensation benefits. The Board found appellant was not entitled to

unemployment benefits from January 2, 2011 to February 26, 2011,

because her employer established she engaged in what the Board

characterized as "simple misconduct connected to the work" under

N.J.S.A. 43:21-5(b). We reverse. Appellant's employer did not

prove appellant committed misconduct by refusing to submit to

the flu vaccination policy for purely secular reasons. The

Board's decision upholding appellant's termination

unconstitutionally discriminated against appellant's freedom of

expression by improperly endorsing the employer's religion-based

exemption to the flu vaccination policy and rejecting the

secular choice proffered by appellant.

I

The facts underlying this appeal are undisputed. Appellant

was a registered nurse employed by Hackettstown Community

Hospital (HCH). She started working as a nurse at HCH on a

full-time basis on May 11, 2009. Effective September 21, 2010,

Adventist Health Care, Inc., the corporate owners of HCH, issued

a policy in its "Corporate Policy Manual" titled "Health Care

Worker Flu Prevention Plan." The purpose of the policy was to

enhance "health care worker vaccination rates and prevent[] the

spread of the flu during the flu season or pandemic, to

2 A-4980-11T2 patients, residents, [healthcare workers] and their families, as

well as the community."

Participation with the flu vaccination directive was

mandatory

unless there [was] a documented medical or religious exemption. For those with an exemption, a declination form must be signed and accompanied with an appropriate note each year. In addition, regardless of where [employees] work, for those who must decline the flu vaccine, it will be mandatory to properly wear a facemask (available at the facility) during the entire flu season, to be determined by [employer] based on [Center for Disease Control] guidelines. Failure to comply with this policy will result in progressive discipline up to and including termination.

[(Emphasis added).]

Appellant refused to be vaccinated for the flu. In

communicating her decision not to take the flu vaccine,

appellant did not allege an exemption based on medical or

religious reasons. She did agree, however, to wear a mask

during flu season, as specifically authorized by the employer's

policy for those who seek a religious-based exemption. Despite

this concession, HCH terminated appellant's employment as a

nurse based on her refusal to be vaccinated against the flu,

presumably based on purely secular personal reasons, since

appellant did not claim a religious-based exemption.

3 A-4980-11T2 The deputy claims examiner found appellant eligible for

unemployment compensation benefits. The employer appealed. The

Appeal Tribunal reversed the deputy claims examiner's decision

after a telephonic hearing in which appellant did not

participate. On appellant's appeal, the Board reversed and

remanded the matter to the Appeal Tribunal to give appellant the

opportunity to participate in the hearing.

The Appeal Tribunal conducted another telephonic hearing;

this time both appellant and her employer participated. The

Appeal Tribunal reversed its earlier ruling and found appellant

eligible to receive unemployment compensation benefits. After

reviewing the relevant regulatory standards, the Appeal Tribunal

held as follows:

In this case, the employer elected to separate the claimant from employment because she would not take a flu vaccination. The claimant's preference not to take a vaccine for her own personal health convictions simply did not demonstrate a willful disregard or neglect of the employer, as the claimant demonstrated an intent to otherwise reconcile the matter. The claimant offered to wear a mask. Furthermore, the employer permitted employees to work without the vaccine provided they wear a mask and have a letter from a spiritual leader, namely a non[-]medical professional, which further buttresses the Tribunal's conclusion that the claimant was not discharged for misconduct connected to the work. Ultimately, the claimant was discharged for reasons which do not constitute misconduct

4 A-4980-11T2 in connection with the work and no disqualification for benefits arises under N.J.S.A. 43:21-5(b). The employer has not presented evidence sufficient to disturb the determination of the Deputy that the claimant was otherwise eligible for benefits from 01/02/11; therefore, those findings will not be disturbed.

Acting on the employer's appeal, the Board reversed finding

appellant violated the employer's flu vaccination policy.

Although the Board recognized that appellant agreed to wear a

mask, as specifically provided for in the policy, the Board

found "she failed to provide the required documentation."

(Emphasis added). Although, as the Appeal Tribunal correctly

noted, the employer's vaccination policy exempted employees for

medically unrelated reasons as long as they provided religion-

based documentation, the Board found appellant "continued to

refuse getting vaccinated despite her own doctor's disagreeing

with her decision and refusing to give her medical

documentation."

Under these circumstances, the Board found "the employer's

policy requiring employees to be vaccinated was not

unreasonable." The Board concluded appellant was thus

disqualified to receive unemployment compensation benefits for

the period between January 2, 2011 through February 26, 2011,

5 A-4980-11T2 based on "simple misconduct connected to the work in accordance

with N.J.S.A. 43:21-5(b)."

II

Our standard of review of a decision made by a State

administrative agency is well-settled.

An administrative agency's final quasi- judicial decision will be sustained unless there is a clear showing that it is arbitrary, capricious, or unreasonable, or that it lacks fair support in the record.

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91 A.3d 644, 436 N.J. Super. 41, 2014 WL 2515589, 2014 N.J. Super. LEXIS 79, Counsel Stack Legal Research, https://law.counselstack.com/opinion/june-g-valent-v-board-of-review-department-of-labo-njsuperctappdiv-2014.