In Seagraves v. Wahington State Department of Children, Youth and Families, (9th Cir., July 21, 2026), the U.S. 9th Circuit Court of Appeals affirmed the dismissal of claims by 18 former employees of the Department of Children, Youth and Families who were separated from the agency after their requests for religious exemptions from the state's 2021 Covid vaccine mandate were rejected. The court said in part:
The [complaint] does not plausibly allege personal involvement by any of the Officials [named as defendants] in constitutional violations of the Employees’ free exercise, equal protection, or procedural due process rights. All the Employees’ requests for accommodations in their current roles were denied, based on determinations that they could not perform the essential functions of their positions unvaccinated without endangering the health and safety of others in the workplace, including children and families. Accordingly, their supposed constitutional injuries flow from this determination. Yet the [complaint] does not allege that any of the Officials [named as defendants] personally participated in evaluating the Employees’ accommodation requests or that they played a role in denying them pre-termination hearings....
The remaining factual allegations that the Employees provided in their pleadings undermine the plausibility of their “religious animus” theory. First consider Hunter’s August 23, 2021, email discussing DCYF’s communications plan for vaccination. The goal of this plan was to convince as many DCYF employees as possible to get vaccinated. Part of the plan involved addressing various potential objections to vaccination: medical safety, convenience, religious objections, and political tribalism. This plan did not single out religiously motivated objections for special treatment. Religious objections were included among several secular objections, and the aim of the plan was to convince DCYF employees that their concerns about vaccination were unfounded, regardless of the religious or secular character of those concerns. That religious objections were one of several objections to address does not, without more, indicate hostility toward religion....
