Letter from church didn't help heavy equipment operator's complaint of discrimination
A major energy company has successfully defended its mandatory COVID-19 vaccination policy after an equipment operator failed to prove his vaccine refusal was tied to his religion.
On Dec. 4, 2025, the Human Rights Tribunal of Alberta dismissed Robert Serfas's complaint against Canadian Natural Resources Limited, finding he couldn't establish the required connection between his anti-vaccination stance and his religious beliefs.
The heavy equipment operator described himself as a born-again Christian who opposed abortion and objected to fetal cells used in vaccine production.
Vaccination policy and exemption request
In fall 2021, Canadian Natural Resources implemented a mandatory COVID-19 vaccination policy requiring employees to be fully vaccinated by Dec. 1, 2021. The policy allowed exemptions for "verified medical or religious reasons" but did not offer testing as an alternative.
Employees who failed to comply without an approved exemption faced discipline up to termination.
Serfas, a heavy equipment operator, requested a religious exemption on Oct. 29, 2021. His request included only basic identifying information and a letter from Jesus is Lord Church, Towerville Church, dated Oct. 7, 2021.
Critically, Serfas submitted no personal statement explaining how his faith conflicted with vaccination.
Church letter undermines claim
The church letter proved problematic for his case. It stated plainly that the congregation "does not prohibit the use of any vaccine and generally encourages the use of safe and effective vaccines as a way of safeguarding personal and public health."
The letter did mention that "there is a general moral duty to refuse the use of medical products, including certain vaccines, that are produced using cell lines derived from direct abortions," but also stated such vaccines could be permissible under specific conditions.
On Nov. 23, 2021, the company denied the exemption request, finding Serfas "had not provided any evidence that he had a sincerely held belief regarding the COVID-19 vaccine that was connected to his religious beliefs." The company revoked his site access effective Dec. 1, 2021, and suspended him without pay on Dec. 22, 2021.
Missing connection to religious belief
In February 2022, Canadian Natural Resources asked suspended employees if they intended to return to work. Serfas did not respond. He filed his human rights complaint in November 2022.
During the complaint process, Serfas provided considerably more detail about his religious views than he had in his original exemption request. He described himself as a born-again Christian who participated in Sunday worship, gave tithes, and engaged in Bible study. He stated he opposes abortion and objects to fetal cells used in vaccine production. He also claimed his body was a temple that must not contain foreign unnatural substances and that the holy spirit guided him not to get vaccinated.
The Director of the Alberta Human Rights Commission dismissed the complaint, finding "the information does not show that the complainant's belief or conduct regarding the COVID-19 vaccines is a tenet of his faith, a fundamental part of his faith, or a particular line of conduct that is required." The Director noted the church letter indicated vaccines are permitted and personal belief and freedom of conscience are not protected characteristics under the Act.
No nexus between belief, accommodation
Tribunal member Dana Christianson conducted a fresh review and upheld the dismissal: "I can accept at this screening stage that the complainant is a Christian and has a sincere belief that he should not be vaccinated against COVID-19."
However, Christianson found the critical element missing: the nexus between his belief and his religion.
"There is nothing in the information before me reasonably capable of establishing that the complainant's beliefs regarding COVID-19 vaccines are a tenet of his faith, a particular line of conduct that is required by his faith, or a fundamental part of exercising his faith," Christianson wrote.
Religious accommodation explained
The tribunal explained that religious accommodation requires demonstrating both a sincerely held belief and a connection between that belief and religion. Personal convictions, even deeply held ones, do not trigger the same legal protections as religious beliefs.
The tribunal noted that "while the letter from the complainant's church says that it will generally support its members' beliefs, that does not equate to information capable of establishing that a decision not to get a vaccine is a tenet of the complainant's faith."
Regarding Serfas's focus on abortion and fetal cell lines in vaccine production, the tribunal noted he provided no evidence that the COVID-19 vaccines available to him were produced using human cell lines derived from direct abortions.
The tribunal's decision upheld the employer's determination that Serfas had not provided evidence connecting his vaccine refusal to his faith, particularly given his church's position that it did not prohibit vaccines and generally encouraged their use.
See Serfas v Canadian Natural Resources Limited, 2025 AHRC 126
