Quick Hits

• The Second Circuit amended its July 2026 decision, clarifying that the decision was not meant to establish that a heightened motive requirement exists for failure-to-accommodate cases.
• The court clarified that employees need not prove discriminatory animus against religion to substantiate their claims, but they must show that the denial was motivated by a desire to avoid the accommodation.

The case, Bergin v. New York State Unified Court System, involved an officer of the New York Unified Court System (UCS) who had requested a religious exemption from UCS’s COVID-19 vaccination requirement. UCS denied the request after the employee initially failed to answer supplemental questions and refused to reconsider. The employee was later placed on administrative leave and then discharged.

In its July 15, 2026, decision, the Second Circuit found that the employee failed to bring a prima facie case for failure to accommodate under Title VII of the Civil Rights Act of 1964 and remanded the case back to the district court for reconsideration. The court held that to state a prima facie case, an employee must allege: (1) the need for an accommodation of a religious practice, (2) “the employer’s desire to avoid” the accommodation “was a motivating factor,” and (3) “an adverse employment decision.”

The Second Circuit’s amended opinion adds a footnote clarifying that it does “not suggest that a new, heightened discriminatory motive requirement exists in failure-to-accommodate...

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