Background
Legacy Health, a regional healthcare system, implemented a mandatory vaccination policy for its hospitals in August two thousand and twenty-one during the Delta variant surge. Employees who held religious objections to the vaccine requested exemptions, which Legacy denied. The employees were placed on administrative leave and subsequently terminated. They filed suit alleging religious discrimination under Title VII and Washington state law. The district court granted summary judgment for Legacy, finding that accommodating the employees would impose an undue hardship on the business.
The court’s reasoning
The panel applied the Supreme Court’s decision in Groff versus DeJoy, which clarified that undue hardship under Title VII requires a burden that is substantial in the overall context of the employer’s business. The court noted that costs need not be exclusively monetary and can include health and safety risks and operational burdens. The court found that Legacy demonstrated realistic risks that accommodating the employees would cause staffing issues, endanger other staff, and threaten the patient population. The court rejected arguments that the employer must first attempt accommodation or that it must show prohibitive financial hardship, holding that the substantial burden on providing quality healthcare was sufficient.
Undue hardship is shown when a burden is substantial in the overall context of an employer’s business.
Groff v. DeJoy, 600 U.S. 447, 468 (2023)
What it means going forward
The decision reinforces that healthcare employers can deny religious exemptions for vaccination policies when they can demonstrate realistic risks to patient safety and operational capacity, even without proving direct financial loss.
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