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9th Circuit: Requested Religious Exemptions from Vaccine Mandate Would Have Imposed Undue Hardship

By Howard Friedman on May 8, 2026
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In Williams v. Legacy Health, (9th Cir., May 6, 2026), the U.S. 9th Circuit Court of Appeals upheld a hospital system’s refusal to grant religious exemptions from its Covid vaccine mandate to Vancouver, Washington hospital employees whose duties put them in close contact with patients or staff. The court upheld the dismissal of plaintiffs’ Title VII religious discrimination claims.  It concluded that granting the requested religious exemptions would have imposed “undue hardship” on Legacy Health. The court said in part:

At the time it denied Employees’ exemption requests, Legacy forecast an acute strain on its business of providing safe and effective medical care to the public. The COVID-19 Delta variant had just emerged, and Legacy predicted a surge of hospitalizations across its eight locations. In that context, Legacy reasonably sought to ensure that its employees were vaccinated. The statistical evidence available to Legacy revealed that high vaccination rates, while not a panacea, reduced overall transmission risk. Vaccination also proved highly effective at preventing infection in the healthcare setting, where other measures like social distancing were impractical or “impossible,” as one expert explained. By contrast, Legacy’s unrebutted epidemiological expert evidence showed that unvaccinated “frontline workers,” like Employees, faced a unique risk of infection—and that any infections could contribute to “significant outbreaks among patients [and] colleagues.” 

Vital Law reports on the decision.

Photo of Howard Friedman Howard Friedman

Author of the Religion Clause blog, highlighting church-state and religious liberty developments

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  • Posted in:
    Employment & Labor
  • Blog:
    Religion Clause
  • Organization:
    Howard M. Friedman
  • Article: View Original Source

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