This Littler Lightbulb highlights some of the more significant employment and labor law developments in the federal courts of appeal in the last month.
Ninth Circuit Affirms Summary Judgment for Fire Department in Claim for Failure to Grant Religious Exemption from Vaccine Mandate
In Petersen v. Snohomish Regional Fire and Rescue, 150 F.4th 1211 (9th Cir. Sept. 2, 2025), the Ninth Circuit affirmed summary judgment for a regional fire department in a lawsuit by firefighters claiming the employer violated Title VII and Washington State law by failing to grant them religious exemptions from a state COVID-19 vaccination mandate. In doing so, the court assumed plaintiffs had set forth a prima facie case, declining to scrutinize plaintiffs’ religious beliefs. Applying the United States Supreme Court’s decision in Groff v. DeJoy, 600 U.S. 447, 453–54 (2023), which “requires employers to accommodate the religious practice of their employees unless doing so would impose an ‘undue hardship on the conduct of the employer’s business,’” the Ninth Circuit analyzed the fire department’s claim that accommodating the firefighters’ exemption request would impose an undue hardship.
First, based on unrebutted medical evidence, the court concluded that allowing firefighters to work unvaccinated imposed increased health and safety risks to its own workforce and the public because firefighters could not always mask and social distance. Next, the court noted that almost one quarter of the...
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