Katherine Anne Lafreniere v. Meridian School District

CourtDistrict Court, W.D. Washington
DecidedMay 13, 2026
Docket2:24-cv-01691
StatusUnknown

This text of Katherine Anne Lafreniere v. Meridian School District (Katherine Anne Lafreniere v. Meridian School District) is published on Counsel Stack Legal Research, covering District Court, W.D. Washington primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Katherine Anne Lafreniere v. Meridian School District, (W.D. Wash. 2026).

Opinion

HONORABLE RICHARD A. JONES 1

8 UNITED STATES DISTRICT COURT 9 WESTERN DISTRICT OF WASHINGTON AT SEATTLE 10 KATHERINE ANNE LAFRENIERE, CASE NO. 2:24-cv-01691-RAJ 11 Plaintiff, ORDER 12 v. 13 MERIDIAN SCHOOL DISTRICT, 14 Defendants. 15 16 17 18 I. INTRODUCTION 19 THIS MATTER comes before the Court on Defendants Meridian School District 20 (the “District”), James Everett, and Kurt Harvill’s Motion for Summary Judgment, Dkt. # 21 61. Also pending before the Court are Plaintiff Katherine Anne LaFreniere’s Motion to 22 Deem Requests for Admission Admitted, Dkt. # 72, Motion to Modify the Scheduling 23 Order, Dkt. # 73, and Motion for Relief from Scheduling Order Deadlines, Dkt. # 76. The 24 Court has reviewed the motions, the submissions in support of and in opposition to the 25 motion, and the balance of the record. For the reasons set forth below, the Court GRANTS 26 the District’s Motion for Summary Judgment and DENIES Ms. LaFreniere’s motions. 27 1 II. BACKGROUND 2 A. Proclamation Requiring COVID-19 Vaccination 3 In August 2021, in the wake of the COVID-19 pandemic, then-Governor Inslee 4 issued Proclamation 21-14.1 (the “Proclamation”). The Proclamation prohibited “[a]ny 5 Worker from engaging in work for the operator of an Educational Setting after October 18, 6 2021 if the Worker has not been fully vaccinated against COVID-19.” Dkt. # 63-1 at 5. 7 The Proclamation also prohibited “[a]ny operator of an Educational Setting from 8 permitting a Worker to engage in work for the operator after October 18, 2021 if the 9 Worker has not been fully vaccinated against COVID-19 and provided proof thereof[.]” 10 Id. It is uncontested that Ms. LaFreniere was a “Worker” and the District an “operator of 11 an Educational Setting” as defined in the Proclamation.1 12 The Proclamation provided for exemptions from the vaccination requirement for 13 individuals “unable to do so because of a disability or if the requirement to do so conflicts 14 with their sincerely held religious beliefs, practice, or observance.” Id. at 6. The 15 Proclamation required covered entities to provide certain disability-related reasonable 16 accommodations and sincerely held religious belief accommodations unless doing so 17 “would cause undue hardship.” Id. Prior to providing a disability-related reasonable 18 accommodation, covered entities were required, to the extent permitted by law, to “obtain 19 from the individual requesting the accommodation documentation from an appropriate 20 health care or rehabilitation professional stating that the individual has a disability that 21 necessitates an accommodation and the probable duration of the need for the 22 accommodation.” Id. at 6–7. Prior to providing a sincerely held religious belief 23 accommodation, covered entities were required, to the extent permitted by law, to 24 “document that the request for an accommodation has been made and include a statement 25 1 Under the Proclamation, “Worker” includes “A person engaged to work as an employee, on-site 26 volunteer, or on-site contractor for a State Agency, an operator of an Educational Setting, or an 27 operator of a Health Care Setting[.]” Id. at 9. “Educational Setting” includes “[a]ll public schools” and “public school districts.” Id. at 12. 1 in the document explaining the way in which the requirements of this order conflict with 2 the sincerely held religious belief, practice, or observance of the individual.” Id. at 7. The 3 Proclamation prohibited covered entities from providing accommodations that they knew 4 were “based on false, misleading or dishonest grounds or information” or “based on the 5 personal preferences of the individual and not on an inability to get vaccinated because of 6 a disability or a conflict with a sincerely held religious belief, practice, or observance.” Id. 7 The Proclamation also prohibited covered entities from providing accommodations 8 “[w]ithout conducting an individualized assessment and determination of each individual’s 9 need and justification for an accommodation; i.e., ‘rubberstamping’ accommodation 10 requests.” Id. 11 B. The District’s Implementation of the Proclamation 12 The two individual defendants in this case are Mr. Harvill and Mr. Everett. Mr. 13 Harvill is the Assistant Superintendent for the District. Dkt. # 63 ¶ 1. Mr. Everett is the 14 Superintendent for the District. Dkt. # 63-13. 15 In support of their Motion for Summary Judgment, Defendants submit a declaration 16 from Mr. Harvill. Dkt. # 63. In the declaration, Mr. Harvill explains that “[t]o comply 17 with the Proclamation, the District worked with legal counsel to develop medical and 18 religious accommodation request forms.” Id. ¶ 6. The form was “the first step to granting 19 an accommodation and exemption from the vaccination mandate.” Id. Mr. Havill 20 reviewed completed forms. Id. If the completed form “provided sufficient information to 21 comply with the Proclamation,” then Mr. Harvill met with the individual “to identify 22 appropriate safety measures” to follow. If, on the other hand, the completed form “did not 23 contain sufficient information to comply with the Proclamation,” Mr. Harvill would 24 “communicate with the individual, either in person, by phone, or by email, to discuss and 25 obtain the missing information.” Id. ¶ 7. 26 On August 27, 2021, Mr. Harvill sent all District staff an email regarding the 27 Proclamation and vaccination requirement. Id. ¶ 9. The email required staff to complete 1 a training module, which in turn provided staff with the exemption forms. Id. ¶ 9; Dkt. # 2 63-2. The email also attached a “Frequently Asked Questions” document (“FAQs”). In 3 relevant part, the FAQs explained that to obtain a religious exemption, employees must 4 “complete the form provided by their school district and/or actively participate in the 5 interactive accommodation process with a Human Resources representative.” Dkt. # 63-2 6 at 8. In addition, the FAQs explained that the Proclamation required “employees seeking 7 a religious exemption to explain the way in which the requirements of the order conflict 8 with their sincerely held religious belief, practice, or observance.” Id. Finally, the FAQ 9 stated that employees “who do not provide proof of vaccination or a medical or religious 10 exemption will be subject to non-disciplinary dismissal from employment for failing to 11 meet the qualifications of the job.” Id. Mr. Harvill sent follow-up emails regarding the 12 vaccination requirement and exemptions process on September 8, 2021 and September 24, 13 2021. Dkt. # 63 at ¶¶ 10–11; Dkt. # 63-3; Dkt. # 63-4. 14 C. Ms. LaFreniere’s Exemption Requests and Termination 15 Ms. LaFreniere was the Director of Transportation at the District. Dkt. # 63 ¶ 12. 16 On or around September 1, 2021, she sent to the District a 13-page document titled 17 “Affidavit/Declaration of Truth” and “Statement of Medical and/or Religious Exemption. 18 Id.; Dkt. # 63-5. The affidavit stated: “I am legally exempt from taking vaccines, wearing 19 any face covering, viral testing, temperature testing or inoculations.” Dkt. # 63-5 at 3. It 20 also stated: “My religious convictions or medial [sic] conditions are protected by the 21 Constitutional of United States of America” and several other laws. Id. The affidavit does 22 not appear to identify what religious conviction or medical condition prevented Ms. 23 LaFreniere from complying with the vaccination requirement. On September 3, 2021, Mr. 24 Harvill responded to Ms. LaFreniere by email. Dkt. # 63-6. He acknowledged receipt of 25 her affidavit, informed her it was not sufficient to qualify her for an exemption, reminded 26 her of the District’s exemption process, and directed her to the exemption forms. Id. 27 1 On or around September 21, 2021, Ms. LaFreniere sent a 17-page affidavit 2 “challenging the District’s authority to require her to provide the basis for any requested 3 exemption.” Dkt. # 63 ¶ 14.

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Katherine Anne Lafreniere v. Meridian School District, Counsel Stack Legal Research, https://law.counselstack.com/opinion/katherine-anne-lafreniere-v-meridian-school-district-wawd-2026.