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In a decision that underscores the limits of workplace vaccine exemption claims, the U.S. Supreme Court on Monday declined to review a lawsuit filed by a former Johns Hopkins University Applied Physics Lab engineer who claimed she was fired for refusing the COVID-19 vaccine due to a medical condition linked to Lyme disease.

The justices, following standard procedure, offered no explanation for rejecting Sally Tarquinio’s petition, effectively ending her case. The denial leaves intact a Fourth Circuit ruling from June upholding summary judgment in favor of the Johns Hopkins Applied Physics Lab, which had argued that Tarquinio failed to provide sufficient evidence for a medical exemption under the Americans with Disabilities Act (ADA).

From Lyme Disease to Litigation

Tarquinio, who said she suffers from “Lyme-induced immune dysregulation,” claimed that the COVID-19 vaccine posed health risks given her condition. In her March 2023 complaint, she argued that the university violated the ADA when it denied her exemption request and terminated her employment.

After the federal contractor announced in 2021 that all employees were required to be vaccinated in line with government policy, Tarquinio submitted medical documentation from her physician requesting an exemption. When her employer asked for authorization to contact the doctor directly, she refused, citing privacy concerns.

Without further medical verification, the lab’s medical director denied her request, asserting that Lyme disease was not recognized by the CDC as a condition contraindicating COVID-19 vaccination. Tarquinio was later dismissed from her role.

Courts Reject Her Claim

U.S. District Judge Richard D. Bennett ruled in April 2024 that Johns Hopkins was not at fault for failing to accommodate Tarquinio, finding that she caused the breakdown of the interactive process by refusing to cooperate.

While the Fourth Circuit criticized the district court for simplifying the blame, the appellate panel nonetheless sided with the university, noting that Tarquinio had provided only vague references to immune issues without explaining how they made vaccination unsafe.

“Faced with Tarquinio’s unusual medical profile, the lab had the right to ask for more objective evidence,” the panel wrote. “Because she prevented the lab from learning why her condition required the accommodations she asked for, she cannot show that the lab had a duty to accommodate.”

A Fight Over ADA Interpretation

In her petition to the Supreme Court, Tarquinio argued that the lower courts had eroded ADA protections by allowing employers to lean on CDC vaccination guidelines instead of conducting an individualized assessment of each worker’s medical situation.

She contended that the ADA’s framework “prevents employers from second-guessing doctors’ treatment plans” and that her case was a prime opportunity for the Court to reaffirm the ADA’s individualized protections.

However, Johns Hopkins declined to respond to her petition, and the justices refused to take up the case.