In White v. University of Washington, (WD WA, March 22, 2024), a Washington federal district court rejected Title VII as well as constitutional challenges brought by a healthcare worker who was denied a religious exemption from Washington's Covid vaccine mandate. In discussing Plaintiff's Title VII claim of failure to reasonably accommodate, the court said in part:
With respect to COVID-19 in particular, guidance from the EEOC indicates that “increasing ‘the risk of the spread of COVID-19 to other employees or to the public’” is a ground for finding undue hardship on employers asked to grant religious exemptions to COVID-19 vaccination mandates....
The Ninth Circuit also has found on a motion to dismiss that undue hardship is established as a matter of law where a religious accommodation would require an employer to violate state or federal law.
The court also rejected plaintiff's due process, equal protection and free exercise claims, saying in part:
Plaintiff has made no allegations regarding what her religious beliefs are, let alone how they were burdened by Defendants’ adherence to Proclamation 21-14.
