Ninth Circuit Upholds Hospital’s Denial of Religious Exemptions From COVID-19 Vaccine Policy
When employers receive religious objections to workplace rules, Title VII generally requires them to consider reasonable accommodations. But that obligation has a limit. An employer does not have to grant an accommodation if doing so would create an “undue hardship” for the business.
In Williams v. Legacy Health, the Ninth Circuit addressed how that rule applies in the healthcare setting. The case involved hospital employees who requested religious exemptions from a COVID-19 vaccine requirement during the Delta variant surge. The employees argued Legacy Health should have accommodated them through measures such as masking, personal protective equipment, or testing instead of vaccination. Legacy argued that allowing unvaccinated frontline healthcare workers to remain in close contact with patients and staff would create unacceptable health, safety, staffing, and operational risks.
The Ninth Circuit agreed with Legacy and affirmed summary judgment in its favor.
The Vaccine Policy and the Religious Exemption Requests
Legacy Health is a regional healthcare system operating eight hospitals in the Willamette Valley. The plaintiffs worked at Legacy’s Salmon Creek medical center in Vancouver, Washington. Their jobs varied. Some were nurses, respiratory therapists, technicians, or other healthcare workers. But the court emphasized one shared feature: their roles required close contact with patients or staff.
In August 2021, as the Delta variant was spreading, Legacy adopted a vaccination policy for people performing services at its hospitals. Legacy had previously encouraged voluntary vaccination, but it changed course when infections and hospitalizations began rising, especially among unvaccinated individuals.
The policy required workers to become fully vaccinated by September 30, 2021, unless they received a medical or religious exemption. Legacy created a process for requesting exemptions and established a working group to review those requests.
The plaintiffs submitted timely religious exemption requests. Legacy denied them. Consistent with the policy, Legacy placed the employees on administrative leave and informed them termination would follow. One plaintiff later received the vaccine and returned to work. The others were terminated.
The Lawsuit and the District Court’s Ruling
The employees filed lawsuits alleging religious discrimination under Title VII and Washington state law. The cases were consolidated in federal district court.
For purposes of the summary judgment motion, the district court assumed the employees could establish the basic elements of a religious discrimination claim. The decisive question was whether Legacy could prove an affirmative defense: that accommodating the employees’ religious objections would have created an undue hardship.
The district court concluded Legacy had made that showing. It found the employees did not meaningfully dispute Legacy’s evidence that exempting them from vaccination would create outsized risks to patients and staff and jeopardize Legacy’s ability to provide healthcare safely and effectively. The district court granted summary judgment for Legacy.
The employees appealed.
The Legal Standard After Groff v. DeJoy
The Ninth Circuit began with the governing Title VII framework. Title VII requires employers to reasonably accommodate an employee’s religious observance or practice unless doing so would cause undue hardship to the conduct of the employer’s business.
The Supreme Court clarified that standard in Groff v. DeJoy. Before Groff, courts often treated undue hardship as anything more than a minimal cost. Groff rejected that approach. Instead, an employer must show a burden that is substantial in the overall context of the employer’s business.
That standard is fact-specific. Courts consider the proposed accommodation, its practical impact, and the nature, size, and operating costs of the employer.
The Ninth Circuit also relied on its recent decision in Petersen v. Snohomish Regional Fire & Rescue, another COVID-19 vaccine accommodation case. Petersen explained that undue hardship is not limited to direct financial cost. It can include health and safety risks, operational burdens, and risks to other employees or the public. Petersen also held that an employer does not have to wait for harm to occur. A realistic risk of undue hardship can be enough, so long as the risk is not merely speculative or hypothetical.
Why Legacy’s Evidence Was Enough
The court held Legacy satisfied the Groff standard.
At the time Legacy denied the exemption requests, it was operating hospitals during the Delta variant surge. Legacy anticipated increased hospitalizations across its facilities. The evidence available to Legacy showed vaccination reduced overall transmission risk and was especially important in healthcare settings, where social distancing was often impractical or impossible.
Legacy also presented unrebutted expert evidence that unvaccinated frontline workers faced a unique risk of infection and could contribute to outbreaks among patients and coworkers.
The Ninth Circuit identified three specific risks.
First, unvaccinated employees could become ill themselves, worsening staffing problems during a period when hospitals needed available workers.
Second, infected employees could transmit COVID-19 to other staff members, reducing the workforce needed to treat patients.
Third, transmission could affect patients, including vulnerable patients with preexisting conditions, creating additional strain on Legacy’s healthcare services.
Legacy’s expert also considered alternatives such as masking, personal protective equipment, and regular testing. The expert concluded those measures were not sufficient replacements for vaccination in the healthcare setting.
The court held those risks, taken together, created a realistic and substantial burden on Legacy’s business of providing quality healthcare.
The Court Rejected the Employees’ Main Arguments
The employees argued Legacy relied on generalized fears rather than concrete evidence. The Ninth Circuit disagreed. It found Legacy’s showing was tied to its specific healthcare operations, the Delta variant, the nature of the employees’ roles, and the risks to patients and staff.
The employees also pointed to other hospitals that granted religious exemptions. The court found that comparison unpersuasive. Under Groff, undue hardship must be assessed in the context of the particular employer’s business. The question was not what other hospitals did. The question was whether Legacy could show undue hardship based on its own circumstances.
The employees also criticized Legacy’s reliance on some pre-vaccine data. The Ninth Circuit rejected that hindsight-based argument. The question was whether Legacy reasonably relied on the scientific evidence and COVID-19 data available at the time it made the decision.
Finally, the employees argued Legacy could not rely on undue hardship because it denied the requests categorically instead of considering each possible accommodation in good faith. The Ninth Circuit rejected that argument too. Under Ninth Circuit precedent, an employer may rely on undue hardship as a complete defense even if it did not attempt an accommodation, so long as the evidence shows no reasonable accommodation was possible without undue hardship.
The court found Legacy did not cherry-pick its analysis. Its evidence showed any accommodation allowing the employees to remain in their jobs while unvaccinated would have created undue hardship because there was no effective alternative to vaccination in that setting. The employees did not offer evidence sufficient to rebut that showing.
The Takeaway for Employers
Williams does not mean employers can deny religious accommodation requests automatically. The decision is tied to a specific factual setting: frontline healthcare employees working in close contact with patients and staff during the Delta variant surge, supported by unrebutted expert evidence showing vaccination was necessary to reduce substantial health, safety, staffing, and operational risks.
The decision does, however, reinforce an important point for employers. After Groff, undue hardship is a more demanding standard than the old “more than minimal cost” test. But substantial burdens are not limited to dollars. In the right factual setting, workplace safety risks, operational disruption, staffing consequences, and risks to vulnerable patients or the public can satisfy the standard.
For healthcare employers, the case also shows the importance of contemporaneous evidence. Legacy prevailed because it tied its decision to the conditions existing at the time, the nature of its operations, the employees’ patient-facing and staff-facing roles, and expert evidence explaining why lesser measures were not adequate substitutes for vaccination.
Final Case Summary
Williams v. Legacy Health was filed on May 6, 2026, by the United States Court of Appeals for the Ninth Circuit, Case No. 24-5977. The Ninth Circuit affirmed summary judgment for Legacy Health, holding that denying religious exemptions from its COVID-19 vaccination policy did not violate Title VII or Washington law because accommodating the unvaccinated healthcare employees would have imposed an undue hardship on Legacy’s business of providing safe and effective healthcare.