Any manager who reviewed accommodation requests claiming a need for a religious accommodation in light of a vaccine mandate has seen this genre of request. An employee objects to a workplace vaccine requirement with the words “faith”, “holistic”, “personal choice” and citations to scripture as a basis for a religious accommodation. Such requests have created a conundrum for managers and HR professionals between protecting the safety of others and determining what should be treated as religion.
On August 13, 2026, the Ninth Circuit gave California employers a useful answer. Ledezma v. Optum Services affirmed summary judgment for the employer, holding that an employee’s refusal of a COVID-19 vaccine came down to personal health preferences — not a religious belief — for purposes of a religious discrimination claim under California’s Fair Employment and Housing Act (FEHA). Scripture in the cover letter, the court explained, does not change the analysis.
Ms. Ledezma was terminated after she declined her employer’s mandatory COVID-19 vaccination policy. She asked for a religious exemption, pointing to her Catholic faith and to scripture, and argued that her body was a “temple of the Holy Spirit” that she was religiously commanded to keep free of foreign or harmful substances.
That framing is heartfelt, and no one questioned that she meant it. But the question in front of the court was not whether she was sincere. It was whether an objection...
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