If an employee leaves for another job, that’s a career move—not a claim.

When an employee voluntarily resigns to work somewhere else, it may feel like fallout from a workplace conflict. But under Title VII, it isn’t punishment or “discipline.”

TL;DR: A Philadelphia school employee who objected to a COVID-19 vaccination policy claimed religious discrimination after leaving for another teaching job. The Third Circuit said no violation occurred: he admitted he resigned voluntarily, not that the district punished him. Even so, the court added that the district reasonably accommodated his religious beliefs by exempting him from vaccination and requiring quarantine after exposure.

📄 Read the full opinion (PDF)

How a vaccine dispute turned into a voluntary exit

The employee objected on religious grounds to a COVID-19 vaccine requirement. The district granted him a full exemption but required him to quarantine if he was exposed to someone who tested positive.

Rather than comply with the quarantine rule, which would have required him to use his sick or personal leave, he applied for and accepted a position at a nearby charter school. He then willingly resigned from his position with the School District and started his new job.

He later sued under Title VII of the Civil Rights Act of 1964, claiming religious discrimination and failure to accommodate.

Quitting isn’t punishment

To prove religious discrimination, the employee needed to show that the district punished him for refusing to comply with a job requirement that conflicted with his beliefs. But that never happened.

He wasn’t fired, demoted, or disciplined. He chose to leave on his own to take a job at the charter school. The court made it clear that a voluntary resignation is not a disciplinary action under Title VII. Without evidence of punishment, there’s no discrimination claim.

The district still met its obligation

Even if the case had gone further, the court said the district satisfied its duty to accommodate. Its solution, no vaccine and quarantine upon exposure, eliminated the conflict between job requirements and his beliefs. Conditioning the accommodation on a quarantine protocol recommended by the CDC and Philadelphia’s Department of Public Health did not make it unreasonable.

Having to use accrued sick or personal leave during quarantine did not change that outcome either. Title VII does not require the most convenient accommodation, only a reasonable one that resolves the conflict.

No religious basis for remote work

The employee also claimed the district should have allowed him to work from home. But he never tied that request to his religion. His message simply said he would work from home “so that he does not lose sick time or pay.” The court held that such a statement failed to give the district the clear notice needed to trigger any duty to accommodate.

Employer takeaways

A resignation breaks the causal chain. When an employee voluntarily leaves for another job, that is not punishment or an adverse employment action under Title VII.
Document your accommodations. The district’s clear record, exemption granted and quarantine required, made it easy to show compliance.
Reasonable means reasonable. Employers do not have to choose the option the employee likes best, only one that actually eliminates the religious conflict.
Ask for clarity. When a religious accommodation request is unclear, ask respectful follow-up questions to understand what conflict needs to be resolved. Focus on the logistics of accommodating, not on debating belief.

The bottom line

When someone leaves on their own terms, that’s a career decision, not a legal claim.