Massachusetts Department of Transportation v. United Steelworkers, Local 5696.

CourtMassachusetts Appeals Court
DecidedApril 10, 2026
Docket25-P-0123
StatusUnpublished

This text of Massachusetts Department of Transportation v. United Steelworkers, Local 5696. (Massachusetts Department of Transportation v. United Steelworkers, Local 5696.) is published on Counsel Stack Legal Research, covering Massachusetts Appeals Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Massachusetts Department of Transportation v. United Steelworkers, Local 5696., (Mass. Ct. App. 2026).

Opinion

NOTICE: Summary decisions issued by the Appeals Court pursuant to M.A.C. Rule 23.0, as appearing in 97 Mass. App. Ct. 1017 (2020) (formerly known as rule 1:28, as amended by 73 Mass. App. Ct. 1001 [2009]), are primarily directed to the parties and, therefore, may not fully address the facts of the case or the panel's decisional rationale. Moreover, such decisions are not circulated to the entire court and, therefore, represent only the views of the panel that decided the case. A summary decision pursuant to rule 23.0 or rule 1:28 issued after February 25, 2008, may be cited for its persuasive value but, because of the limitations noted above, not as binding precedent. See Chace v. Curran, 71 Mass. App. Ct. 258, 260 n.4 (2008).

COMMONWEALTH OF MASSACHUSETTS

APPEALS COURT

25-P-123

MASSACHUSETTS DEPARTMENT OF TRANSPORTATION

vs.

UNITED STEELWORKERS, LOCAL 5696.

MEMORANDUM AND ORDER PURSUANT TO RULE 23.0

The defendant, United Steelworkers, Local 5696 (union),

appeals from an amended judgment entered on the pleadings in

favor of the plaintiff, the Massachusetts Department of

Transportation (department). The judgment vacated an

arbitration award of backpay and seniority rights to an employee

of the department. Because we conclude that the arbitrator did

not exceed his authority, we reverse.

Background. We recite the facts as found by the

arbitrator. Adrian Braka is employed by the department in its

Highway Operations Center (HOC) as an HOC Operator II. The HOC

provides "24/7" traffic management and emergency response for

roads and tunnels in the Commonwealth. In March 2020, following the onset of the COVID-19

pandemic, the Governor declared a state of emergency. Although

much of the department's in-person operations were shut down,

the HOC continued its operations. In August 2021, the Governor

issued an executive order requiring all executive department

employees to provide proof of vaccination against COVID-19 on or

before October 17, 2021,1 or to obtain an exemption "where a

reasonable accommodation can be reached" for employees unwilling

to receive vaccination due to sincerely held religious beliefs.

The department subsequently adopted a policy that required

employees to show proof of vaccination against COVID-19 as a

condition of employment or to submit a request for a medical or

religious exemption. Under the policy, employees who failed to

comply would face progressive discipline, beginning with a five-

day suspension without pay and culminating in termination of

employment.

On September 28, 2021, Braka submitted a religious

exemption request form to the department and attached a letter

from his pastor. On October 12, Braka was interviewed by the

department's director of equal employment opportunity programs.

This interview focused solely on Braka's religious beliefs and

1 Executive Order No. 595 (Aug. 19, 2021).

2 did not cover the subject of possible accommodations.2 The

department subsequently denied Braka's request, claiming that

granting his request would impose an undue hardship and that the

department "explored the possibility of transferring or

reassigning [Braka] to a vacant position, but no alternative

assignments" were available at that time.3

On November 5, 2021, Braka submitted an appeal, proposing

possible accommodations such as remote work, regular testing for

COVID-19, and social distancing, and further suggesting that he

could work "in a separate space at the HOC or [department]

building." The department denied the appeal, claiming that

Braka had failed to provide any new or differing information or

evidence of a mistake of fact or interpretation of law or

policy. After his request for an accommodation was denied,

Braka continued to oppose vaccination on religious grounds, and

the department proceeded with the progressive disciplinary steps

outlined in its vaccination policy. The department terminated

Braka on December 14, 2021.

2 The department determined that Braka had sincerely held religious beliefs and does not challenge the sincerity of those beliefs on appeal.

3 The department's director of human resources testified that approximately one hundred applications for exemptions were filed by department employees, but that he did not recall any accommodations being granted for religious exemptions.

3 At all relevant times, the department was party to a

collective bargaining agreement (CBA) with the union. The CBA

included, in relevant part, provisions that prohibited the

department from discriminating against employees based on

"religion" or "creed" or from discharging nonprobationary

employees "without just cause." The CBA also included a

standard grievance procedure, including "final and binding"

arbitration under G. L. c. 150C.

The union grieved Braka's termination and requested

arbitration. In the meantime, because of decreasing

transmission rates and increased level of vaccinations against

COVID-19, on October 18, 2022, the department offered to

reinstate Braka, and he returned to work. The union continued

to pursue arbitration seeking lost wages, benefits, and

seniority, and claiming that the department had failed to

reasonably accommodate Braka's sincerely held religious beliefs

and had disciplined and terminated him without just cause.4

Following a hearing, the arbitrator found that the

department failed to meet its burden of proving that it had

properly considered possible accommodations for Braka's

4 The parties agreed to the following questions for arbitration: (1) "Did [the department] deny reasonable accommodation to [Braka]?" and (2) "If so, what shall the remedy be?"

4 sincerely held religious beliefs. While the department claimed

to have considered accommodations, including reassignment to

another position at the department, remote work, or work in a

separate space at the HOC, the arbitrator found that the

department's investigation into each of these options was

"cursory." He further noted that the department's conclusions

that such accommodations were unavailable or not possible "were

only supported by conclusionary statements offered at hearing,"

and that there was "insufficient evidence that anyone looked

into lists of vacant positions, or lists of vacant rooms

available, or the specifics of what was needed for [Braka] to

work remotely." The arbitrator sustained the union's grievance

and ordered back pay, benefits, and seniority credit.

The department filed a complaint in the Superior Court

pursuant to G. L. c. 150C, § 11, seeking to vacate the

arbitration award on the ground that the arbitrator had exceeded

his authority in issuing an award that "violates public policy"

in that it "imperils the safety of the traveling public and

[department] employees by limiting [the department's] ability to

provide essential public safety services." In his memorandum of

decision and order on cross-motions for judgment on the

pleadings, the Superior Court judge agreed with the department

and found that the arbitrator's award interfered with the

5 department's nondelegable rights under its enabling statute,

G. L. c. 6C, § 3 (6). Section 3 (6) grants the department, in

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Massachusetts Department of Transportation v. United Steelworkers, Local 5696., Counsel Stack Legal Research, https://law.counselstack.com/opinion/massachusetts-department-of-transportation-v-united-steelworkers-local-massappct-2026.