When Faith Meets the Workplace: The Teresa Harmon Religious Discrimination Case

Teresa Harmon had been caring for cancer patients at Kaiser’s Gaithersburg oncology center for nearly two years when the email arrived.

Like millions of healthcare workers across America in August 2021, she faced a choice that would upend her life: get vaccinated against COVID-19 or risk losing her job.

For Harmon, a registered nurse whose religious convictions made vaccination unacceptable, this wasn’t just a workplace policy — it was a collision between her faith and her calling to care for others.

What followed was a bureaucratic maze that would culminate in Harmon’s termination just days before Christmas 2021, setting the stage for a legal battle that would test the boundaries of religious protection in Maryland workplaces.

The Maryland Appellate Court’s July 2025 decision in Harmon v. Kaiser Permanente Insurance Company offers crucial lessons about how courts evaluate religious discrimination claims — and why even sincere believers can lose their cases on technical grounds.

What Actually Happened in the Harmon v. Kaiser Case?

Teresa Harmon’s story began promisingly enough.

When Kaiser Permanente implemented its COVID-19 vaccination requirement on August 2, 2021, the healthcare giant offered employees a way out: they could seek exemptions based on religious and/or medical grounds.

The policy seemed straightforward — employees with “sincerely held religious beliefs” that prohibited vaccination could apply for an exemption by completing an online questionnaire.

Harmon submitted her first exemption request on August 23, 2021.

The process required her to answer “several personal questions” about her religious beliefs — questions she answered, as she later put it, because she was “proud of [her] religious beliefs and had nothing to hide.”

Then came the waiting. And the questions.

Kaiser requested more information about Harmon’s beliefs on September 21, 2021.

It’s unclear from the court record exactly what additional information Harmon provided, but on September 29, she received the news she’d been hoping for: Kaiser approved her religious exemption.

There was a catch, however.

As an unvaccinated employee, Harmon had to submit to COVID-19 testing twice weekly — a requirement that didn’t apply to her vaccinated colleagues.

Still, she had her exemption; she could continue working at Kaiser’s medical center in Gaithersburg.

Harmon’s Religious Exemption Unravels; Kaiser Changes Its Mind

Everything changed for Teresa Harmon on November 3, 2021.

That morning, Ms. Harmon applied for a full-time oncology nursing position within Kaiser — a natural career progression for an experienced nurse.

But later that same day, Kaiser’s human resources department blindsided her with a request: she needed to complete the religious exemption questionnaire again.

The request made no sense to Harmon; she already had an approved exemption.

Why did applying for a different position require her to justify her religious beliefs all over again? When she asked Kaiser for an explanation, she hit a wall of silence.

Frustrated and concerned, Harmon hired an attorney on November 8. Over the following weeks, she and her lawyer repeatedly sought clarification from Katherine Ballesteros, her supervisor, and Suzanna Williams from human resources.

According to the unreported case released on July 24, 2025, no one explained to Harmon why she needed to resubmit her exemption request.

As November turned to December, Ms. Harmon filed an internal discrimination complaint with Kaiser. She spoke with someone named “Suraj” about her treatment, specifically complaining about Kaiser’s human resources’ refusal to provide basic information like her HR director’s name.

On December 9, Kaiser delivered its verdict: Harmon’s exemption request was denied. The company now viewed her September approval as merely “provisional.”

About a week later, Ballesteros, Harmon’s immediate supervisor, informed Harmon that unless she got vaccinated, she could not return to work and would be placed on administrative leave.

The timing felt particularly cruel. Just days before Christmas 2021 — a holiday Harmon later emphasized as significant to her Christian faith — Kaiser terminated her employment.

Teresa Harmon had refused to get vaccinated, and now she was out of a job.

Harmon’s Legal Battle Begins

Ms. Harmon didn’t go quietly from Kaiser after they fired her.

On March 7, 2023, Harmon filed a sprawling 33-page complaint against Kaiser and the two supervisors involved in her termination. When Kaiser moved to dismiss that complaint, Harmon responded with an even longer 42-page amended complaint raising eight different legal claims.

Her core allegations were straightforward: Kaiser had discriminated against her based on her religious beliefs and retaliated against her for complaining about that discrimination.

Harmon painted a picture of an employer that “mocked” her beliefs, subjected them to “mysterious” scrutiny by unnamed reviewers with “secret standards,” and ultimately fired her not for poor performance but for “exercising [her] God given rights.”

Kaiser Saw Things Differently Than Teresa Harmon

Kaiser moved to dismiss Harmon’s amended complaint, arguing she hadn’t provided enough factual detail to support her legal claims.

After a hearing, Circuit Court Judge [name not provided] issued a detailed written opinion on October 17, 2023, dismissing all of Harmon’s claims.

Harmon tried one more time, filing a motion asking the court to reconsider and seeking permission to file yet another amended complaint.

The court denied that request as well, leading Teresa Harmon to appeal to Maryland’s intermediate appellate court.

Understanding Religious Discrimination Law

To understand why Teresa Harmon lost — and why the appellate court affirmed that loss — we must examine how religious discrimination law operates in Maryland.

The state’s Fair Employment Practices Act (FEPA) closely mirrors federal civil rights law, making it illegal for employers to discriminate against employees “because of religion.”

But what does “because of religion” mean in practice?

Maryland courts recognize two distinct theories of religious discrimination; understanding the difference between them is crucial.

Two Ways to Prove Religious Discrimination

1. Failure to Accommodate

Failure to Accommodate claims focus on an employer’s duty to make reasonable adjustments for an employee’s religious practices.

Think of a Jewish employee who needs Saturdays off for Sabbath observance, or a Muslim worker who requires prayer breaks.

Federal and state law require employers to accommodate these religious needs, unless doing so would cause an “undue hardship” to the business.

2. Disparate Treatment

Disparate Treatment claims, by contrast, allege that an employer treated someone worse specifically because of their religion.

In Harmon’s case, she vaguely alleged that ‘Jehovah’s Witnesses are allowed religious exemptions at Kaiser,’ but never claimed to be a Jehovah’s Witness or explained how her beliefs were similar.

While Ms. Harmon’s complaint never clearly stated which theory she was pursuing — failure to accommodate or disparate treatment — this ambiguity was just one of several fatal flaws in her pleadings.

Teresa Harmon’s Fatal Flaw: Connecting Belief to Practice

Here’s where Harmon’s case fell apart, and where the appellate court’s opinion offers its most important lesson for future plaintiffs and their attorneys.

To prove a failure-to-accommodate claim, an employee must establish three elements:

1. They have a genuine religious belief that conflicts with a job requirement
2. They told their employer about this belief
3. They faced discipline for refusing to comply with the requirement

Based on the facts in the record, Harmon appears to have satisfied the second and third elements — she informed Kaiser about her beliefs when she requested religious exemptions, and she was ultimately terminated for refusing to be vaccinated.

But the court never reached these elements because it found she failed to adequately plead the first element. Furthermore, the first element requires more than just claiming to be religious. Courts need to see a clear connection between the religious belief and the challenged practice.

Throughout Harmon’s 42-page amended complaint, she repeatedly asserted that she held “sincerely held religious beliefs” that prevented her from getting vaccinated.

She mentioned being “Christian” exactly once — in an attachment to her complaint.

However, she never explained why her Christian faith prohibited vaccination; she failed to articulate the specific religious doctrine, biblical passage, or faith-based reasoning that connected her religious beliefs to her refusal to be vaccinated.

What Other Courts Have Required

The Appellate Court of Maryland’s opinion includes a revealing footnote comparing Harmon’s allegations to successful religious discrimination cases from other jurisdictions.

The contrast is stark.

Harmon’s vague assertions about “religious convictions” and “sincerely held religious beliefs” pale by comparison.

The Disparate Treatment Problem

Harmon’s disparate treatment claim faced similar problems.

To prove this type of discrimination, she needed to show that Kaiser treated her worse than “similarly situated” employees outside her protected class — in other words, that employees with different or no religious beliefs received better treatment for comparable exemption requests.

Her only attempt to make this showing was a single sentence: “On information and belief, Ms. Harmon states that Jehovah’s Witnesses are allowed religious exemptions at Kaiser.”

This allegation fails for multiple reasons.

Again, Harmon never claimed to be a Jehovah’s Witness or to share similar beliefs.

Second, she provided no details about these other employees — were they in similar positions? Did they request exemptions at the same time? Were their stated religious objections similar to hers?

Without such facts, the court couldn’t determine whether these unnamed Jehovah’s Witnesses were truly “similarly situated” to Harmon.

Harmon’s Retaliation Claim’s Missing Link

Ms. Harmon’s retaliation claim suffered from a different but equally fatal defect.

While she established that she engaged in protected activity (filing an internal discrimination complaint) and suffered adverse action (termination), she failed to demonstrate a causal connection between the two.

The timeline matters here:

• Harmon refused vaccination in August 2021.
• Kaiser began the process that led to her termination in early December 2021.
• Harmon filed her internal complaint somewhere in between.
• But Kaiser’s stated reason for termination was her refusal to be vaccinated — not her discrimination complaint.

Teresa Harmon never alleged facts suggesting that her complaint motivated or influenced Kaiser’s decision to fire her.

Lessons & Takeaways for Different Audiences

For Pro Se Litigants and Employees

If you’re considering a religious discrimination claim, Harmon’s case offers crucial guidance:

Document Your Beliefs Specifically

• Don’t just say you’re religious.
• Explain exactly how your faith conflicts with the workplace requirement.
• What specific teachings, scriptures, or religious principles are at stake? Write this down when you request an accommodation.

Know Your Comparators

Gather specifics if you believe others received better treatment: 

• Who were they?
• What positions did they hold?
• What did they request?
• When?
• What reasons did they give?

Disparate treatment claims often fail without these critical details.

Understand Timing

For retaliation claims, the proximity between the protected activity and the adverse action is crucial.

But proximity alone isn’t enough — you need facts suggesting your complaint actually influenced the employer’s decision.

The Amendment Opportunity

Judge Friedman’s concurrence highlights a crucial procedural point: when defendants file a motion to dismiss identifying legal defects in your complaint, you can file an amended complaint addressing those defects without seeking court permission.

This is essentially free legal research — use it to your advantage.

For Legal Practitioners

This case reinforces fundamental pleading principles that attorneys sometimes overlook in employment discrimination cases:

• Specificity Matters: Federal courts have made clear that “an employment discrimination plaintiff need not plead a prima facie case,” but the allegations must still “plausibly state a violation above a speculative level.” Generic assertions about religious beliefs won’t suffice.
• Connect the Dots: The failure-to-accommodate analysis requires showing how religious doctrine connects to workplace conduct. Don’t assume courts will infer these connections—spell them out.
• Comparative Evidence: For disparate treatment claims, identify specific comparators and explain why they’re similarly situated. Vague references to other employees receiving different treatment invite dismissal.
• Use Precedent as a Guide: The court’s footnote ten provides a roadmap of successful religious accommodation allegations. Study these examples when drafting complaints.

For Citizens and Observers

This case illustrates a harsh reality of civil litigation: you can be right on the merits but still lose on procedure.

• Harmon may well have faced genuine religious discrimination.
• She may have held sincere beliefs that made vaccination impossible.
• Kaiser’s shifting explanations and revocation of a previously approved exemption raise troubling questions.

But courts can only rule on what’s properly before them. The legal system requires plaintiffs to plead specific facts supporting each element of their claims.

This isn’t bureaucratic nitpicking — it’s how courts ensure that only viable claims proceed to the expensive and time-consuming discovery process.

The Broader Context: Religious Freedom in the Workplace

Teresa Harmon’s case arrived at Maryland courts during a period of intense national debate about COVID-19 vaccine mandates and religious freedom.

Federal courts across the country grappled with similar claims, creating a patchwork of decisions that offer essential context.

Some courts have been sympathetic to religious objectors, especially when they articulated specific faith-based concerns about vaccines developed using fetal cell lines or about body autonomy as a religious principle.

Others have upheld employer mandates, particularly in healthcare settings where patient safety concerns add weight to the “undue hardship” analysis.

The Supreme Court’s 2023 decision in Groff v. DeJoy clarified that employers must demonstrate that accommodations would result in “substantial increased costs” to claim undue hardship—a more stringent standard than some courts had previously applied.

However, this higher bar only benefits employees who first demonstrate a need for a religious accommodation.

Maryland’s Approach: Following Federal Guidance

Because Maryland’s Fair Employment Practices Act is modeled after Title VII of the Civil Rights Act of 1964, Maryland courts look to federal Precedent for guidance.

This means Maryland employees enjoy similar protections to federal law, but also face similar pleading requirements. The appellate court’s reliance on federal cases from multiple circuits shows Maryland’s commitment to mainstream religious discrimination jurisprudence.

Doing so provides predictability for employers and employees alike — the same basic rules apply whether you’re in Baltimore or Birmingham.

What This Means Going Forward

For Maryland employers, Harmon reinforces that religious accommodation policies need clear standards and consistent application.

Kaiser’s shifting explanations and requests for additional information, made without clear justification, created the appearance of arbitrariness that fueled this litigation.

For employees, the case underscores that religious beliefs deserve workplace protection — but claiming that protection requires more than conclusory assertions.

The law protects specific religious practices that conflict with job requirements, not general preferences couched in religious language.

For attorneys on both sides, Harmon provides a clear roadmap.

The plaintiffs’ counsel must ensure that complaints include specific factual allegations that connect religious beliefs to the challenged practices.

Defense counsel can rely on the Iqbal and Twombly standards to challenge vague or conclusory allegations of discrimination.

Conclusion: The Price of Imprecision

Teresa Harmon’s story began with a Maryland registered nurse trying to reconcile her faith with her profession during an unprecedented pandemic.

It ended with an appellate court opinion that never reached the merits of whether Kaiser actually discriminated against her.

The tragic irony is that Harmon may have had a viable claim.

Kaiser’s decision to revoke a previously approved exemption, its refusal to explain its changed position, and its termination of a nurse with nearly two years of satisfactory performance raise serious questions.

But those questions remain unanswered because Harmon’s legal pleadings failed to connect her religious identity to her vaccination refusal with the specificity Maryland law requires.

Judge Friedman’s concurrence highlights the missed opportunity: Harmon had the chance to address the deficiencies in her complaint after Kaiser’s motion to dismiss identified them.

Instead of using Kaiser’s legal research to strengthen her allegations, she filed an amended complaint with the same fundamental flaws.

The lesson is clear but painful: in civil rights litigation, how you tell your story matters as much as the story itself.

Religious discrimination law protects sincere believers who face genuine conflicts between their faith and their work. But accessing that protection requires more than sincerity — it demands precision.

But for Teresa Harmon, that precision came too late.

For future plaintiffs navigating the intersection of faith and employment, Ms. Harmon’s case stands as both a cautionary tale and a detailed guide: The law remains ready to protect religious freedom in the workplace.

First, however, you must show the court exactly what needs to be protected.

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Case Citation: Harmon v. Kaiser Permanente Insurance Company, No. 2122, September Term 2023 (Md. App. July 24, 2025) (unreported)

Important Notice: Civil litigation involving claims of religious discrimination can have severe employment consequences. Do not rely on this article alone for legal decisions. Seek immediate legal counsel if facing employment discrimination based on religion.