The ruling puts teeth into the new 'undue hardship' standard – and HR leaders need to take note
A federal appeals court has handed healthcare employers a significant win on vaccination mandates – with clear lessons for HR leaders beyond hospital walls.
On May 6, 2026, the Ninth Circuit affirmed summary judgment in favor of Legacy Health in a Title VII religious discrimination case brought by nine employees who were denied religious exemptions from the company's COVID-19 vaccination policy. The court noted it has had few opportunities to apply the Supreme Court's 2023 Groff v. DeJoy undue-hardship standard, and this decision draws a clearer line for employers navigating the tension between workplace safety and religious accommodation.
Legacy Health operates eight hospitals in Washington and Oregon. In August 2021, as the Delta variant was driving a sharp rise in hospitalizations among unvaccinated individuals, Legacy moved from encouraging voluntary vaccination to requiring it. Every person performing services at its facilities had until September 30, 2021, to get fully vaccinated or secure an exemption. A working group was set up to review religious and medical exemption requests.
Nine employees at Legacy's Salmon Creek medical center in Vancouver, Washington – working in roles that included physician assistant, respiratory therapist, nurse, and technician – submitted religious exemption applications. Legacy denied all of them. The employees were placed on administrative...
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