The U.S. Court of Appeals for the First Circuit ruled Tuesday that two former Hasbro employees can pursue religious discrimination and retaliation claims against the toy company after being denied religious exemptions from its COVID-19 vaccination policy. The court vacated the dismissal of claims brought by Jennifer DeAngelis and Natalie Tomaselli and remanded the case for further proceedings.
In the decision issued Jan. 29, 2026, Circuit Judge Aframe wrote for the panel that included Chief Judge Barron and Circuit Judge Gelpí. The ruling stems from *DeAngelis v. Hasbro, Inc.*, No. 24-1655, an appeal from the U.S. District Court for the District of Rhode Island, where Judge Mary S. McElroy had previously dismissed the employees' amended complaint under Federal Rule of Civil Procedure 12(b)(6).
The case centers on Hasbro's late 2021 announcement of a policy requiring all employees entering company offices to receive vaccination against SARS-CoV-2, the virus that causes COVID-19. Natalie Tomaselli, who worked as Hasbro's Associate Manager for Global Brand Publicity at the time, and Jennifer DeAngelis both sought religious exemptions from the mandate.
According to the court's recounting of the complaint allegations, both employees requested accommodations based on their religious beliefs but were denied the exemptions they sought. Rather than comply with the vaccination requirement, both women resigned from their positions at the global toy and game company.
The employees subsequently filed discrimination and retaliation claims against Hasbro, alleging the company violated their rights under federal employment law. The district court initially dismissed their amended complaint, finding the claims legally insufficient.
However, the First Circuit disagreed with the lower court's analysis. In reviewing the dismissal under the Rule 12(b)(6) standard, the appeals court noted it must accept well-pleaded allegations as true and afford plaintiffs all reasonable inferences from those allegations, citing *Better Way Ford, LLC v. Ford Motor Co.*, 142 F.4th 67, 77 (1st Cir. 2025).
The appellate panel found that the district court erred in dismissing the claims and determined that the case should proceed to further development in the trial court. The decision suggests the appeals court found the employees had adequately stated claims for both religious discrimination and retaliation under federal law.
The ruling comes amid ongoing litigation nationwide over workplace COVID-19 vaccination policies and religious accommodation requests. During the pandemic, many employers implemented mandatory vaccination policies, leading to disputes when employees sought exemptions based on religious beliefs. Courts have grappled with balancing employer safety policies against employees' religious freedom rights.
For the plaintiffs, Stephen T. Fanning served as counsel on appeal. Hasbro was represented by Leslie D. Parker, along with Patricia K. Rocha, Christopher J. Yagoobian, and the firm Adler Pollock & Sheehan, P.C.
The case highlights the complex legal questions surrounding employer accommodation duties under Title VII of the Civil Rights Act of 1964, which requires employers to reasonably accommodate employees' religious beliefs unless doing so would cause undue hardship. The Supreme Court recently clarified the standard for religious accommodations in the workplace in *Groff v. DeJoy* (2023), emphasizing that employers must show substantial difficulty or expense to deny accommodation requests.
Hasbro, headquartered in Pawtucket, Rhode Island, is one of the world's largest toy companies, known for brands including Monopoly, Scrabble, My Little Pony, and Transformers. The company has not publicly commented on the appeals court decision.
The First Circuit's ruling does not determine the ultimate merits of the discrimination and retaliation claims. Instead, it allows the case to proceed past the initial pleading stage, meaning the employees will have the opportunity to develop their claims through discovery and potentially trial.
The decision could have broader implications for other pending cases involving COVID-19 vaccination policies and religious exemption requests. As the legal landscape continues to evolve around pandemic-era workplace policies, this case may provide guidance for both employers and employees navigating religious accommodation disputes.
The case now returns to the Rhode Island district court for further proceedings consistent with the appellate ruling. The employees will need to prove their claims through evidence and testimony, while Hasbro will have the opportunity to present its defenses to the discrimination and retaliation allegations.
The timing of the decision, more than four years after the initial policy announcement, reflects the complex procedural journey many COVID-19 related employment cases have taken through the federal court system. As workplace vaccination policies have evolved and pandemic concerns have shifted, the legal ramifications continue to work through the courts.