Katherine Anne Lafreniere v. Meridian School District

District Court, W.D. Washington·Decided May 13, 2026·No. 2:24-cv-01691·Unknown

Opinion

HONORABLE RICHARD A. JONES

UNITED STATES DISTRICT COURT AT SEATTLE KATHERINE ANNE LAFRENIERE, CASE NO. 2:24-cv-01691-RAJ Plaintiff, ORDER v. MERIDIAN SCHOOL DISTRICT, Defendants. THIS MATTER comes before the Court on Defendants Meridian School District (the “District”), James Everett, and Kurt Harvill’s Motion for Summary Judgment, Dkt. # 61. Also pending before the Court are Plaintiff Katherine Anne LaFreniere’s Motion to Deem Requests for Admission Admitted, Dkt. # 72, Motion to Modify the Scheduling Order, Dkt. # 73, and Motion for Relief from Scheduling Order Deadlines, Dkt. # 76. The Court has reviewed the motions, the submissions in support of and in opposition to the motion, and the balance of the record. For the reasons set forth below, the Court GRANTS the District’s Motion for Summary Judgment and DENIES Ms. LaFreniere’s motions. A. Proclamation Requiring COVID-19 Vaccination In August 2021, in the wake of the COVID-19 pandemic, then-Governor Inslee issued Proclamation 21-14.1 (the “Proclamation”). The Proclamation prohibited “[a]ny Worker from engaging in work for the operator of an Educational Setting after October 18, 2021 if the Worker has not been fully vaccinated against COVID-19.” Dkt. # 63-1 at 5. The Proclamation also prohibited “[a]ny operator of an Educational Setting from permitting a Worker to engage in work for the operator after October 18, 2021 if the Worker has not been fully vaccinated against COVID-19 and provided proof thereof[.]” Id. It is uncontested that Ms. LaFreniere was a “Worker” and the District an “operator of an Educational Setting” as defined in the Proclamation.1 The Proclamation provided for exemptions from the vaccination requirement for individuals “unable to do so because of a disability or if the requirement to do so conflicts with their sincerely held religious beliefs, practice, or observance.” Id. at 6. The Proclamation required covered entities to provide certain disability-related reasonable accommodations and sincerely held religious belief accommodations unless doing so “would cause undue hardship.” Id. Prior to providing a disability-related reasonable accommodation, covered entities were required, to the extent permitted by law, to “obtain from the individual requesting the accommodation documentation from an appropriate health care or rehabilitation professional stating that the individual has a disability that necessitates an accommodation and the probable duration of the need for the accommodation.” Id. at 6–7. Prior to providing a sincerely held religious belief accommodation, covered entities were required, to the extent permitted by law, to “document that the request for an accommodation has been made and include a statement 1 Under the Proclamation, “Worker” includes “A person engaged to work as an employee, on-site volunteer, or on-site contractor for a State Agency, an operator of an Educational Setting, or an operator of a Health Care Setting[.]” Id. at 9. “Educational Setting” includes “[a]ll public schools” and “public school districts.” Id. at 12. in the document explaining the way in which the requirements of this order conflict with the sincerely held religious belief, practice, or observance of the individual.” Id. at 7. The Proclamation prohibited covered entities from providing accommodations that they knew were “based on false, misleading or dishonest grounds or information” or “based on the personal preferences of the individual and not on an inability to get vaccinated because of a disability or a conflict with a sincerely held religious belief, practice, or observance.” Id. The Proclamation also prohibited covered entities from providing accommodations “[w]ithout conducting an individualized assessment and determination of each individual’s need and justification for an accommodation; i.e., ‘rubberstamping’ accommodation requests.” Id. B. The District’s Implementation of the Proclamation The two individual defendants in this case are Mr. Harvill and Mr. Everett. Mr. Harvill is the Assistant Superintendent for the District. Dkt. # 63 ¶ 1. Mr. Everett is the Superintendent for the District. Dkt. # 63-13. In support of their Motion for Summary Judgment, Defendants submit a declaration from Mr. Harvill. Dkt. # 63. In the declaration, Mr. Harvill explains that “[t]o comply with the Proclamation, the District worked with legal counsel to develop medical and religious accommodation request forms.” Id. ¶ 6. The form was “the first step to granting an accommodation and exemption from the vaccination mandate.” Id. Mr. Havill reviewed completed forms. Id. If the completed form “provided sufficient information to comply with the Proclamation,” then Mr. Harvill met with the individual “to identify appropriate safety measures” to follow. If, on the other hand, the completed form “did not contain sufficient information to comply with the Proclamation,” Mr. Harvill would “communicate with the individual, either in person, by phone, or by email, to discuss and obtain the missing information.” Id. ¶ 7. On August 27, 2021, Mr. Harvill sent all District staff an email regarding the Proclamation and vaccination requirement. Id. ¶ 9. The email required staff to complete a training module, which in turn provided staff with the exemption forms. Id. ¶ 9; Dkt. # 63-2. The email also attached a “Frequently Asked Questions” document (“FAQs”). In relevant part, the FAQs explained that to obtain a religious exemption, employees must “complete the form provided by their school district and/or actively participate in the interactive accommodation process with a Human Resources representative.” Dkt. # 63-2 at 8. In addition, the FAQs explained that the Proclamation required “employees seeking a religious exemption to explain the way in which the requirements of the order conflict with their sincerely held religious belief, practice, or observance.” Id. Finally, the FAQ stated that employees “who do not provide proof of vaccination or a medical or religious exemption will be subject to non-disciplinary dismissal from employment for failing to meet the qualifications of the job.” Id. Mr. Harvill sent follow-up emails regarding the vaccination requirement and exemptions process on September 8, 2021 and September 24, 2021. Dkt. # 63 at ¶¶ 10–11; Dkt. # 63-3; Dkt. # 63-4. C. Ms. LaFreniere’s Exemption Requests and Termination Ms. LaFreniere was the Director of Transportation at the District. Dkt. # 63 ¶ 12. On or around September 1, 2021, she sent to the District a 13-page document titled “Affidavit/Declaration of Truth” and “Statement of Medical and/or Religious Exemption. Id.; Dkt. # 63-5. The affidavit stated: “I am legally exempt from taking vaccines, wearing any face covering, viral testing, temperature testing or inoculations.” Dkt. # 63-5 at 3. It also stated: “My religious convictions or medial [sic] conditions are protected by the Constitutional of United States of America” and several other laws. Id. The affidavit does not appear to identify what religious conviction or medical condition prevented Ms. LaFreniere from complying with the vaccination requirement. On September 3, 2021, Mr. Harvill responded to Ms. LaFreniere by email. Dkt. # 63-6. He acknowledged receipt of her affidavit, informed her it was not sufficient to qualify her for an exemption, reminded her of the District’s exemption process, and directed her to the exemption forms. Id. On or around September 21, 2021, Ms. LaFreniere sent a 17-page affidavit “challenging the District’s authority to require her to provide the basis for any requested exemption.” Dkt. # 63 ¶ 14. On September 30, 2021, Mr. Harvill sent another email to Ms. LaFreniere. In the email, he explained the “two affidavit letters we have received from you did not provide us with the information we need in order to be able to exempt you from the Governor’s proclamation.” Dkt. # 63-7 at 2. He again asked Ms. LaFreniere to complete the District’s exemption form to

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