Labor & Employment News Alert
Vaccine Mandates and Religious Accommodation – Understanding “Undue Burden” under the Americans with Disabilities Act
October 22, 2025
A recent decision from the United States Court of Appeals for the Fourth Circuit provides important guidance for healthcare employers that have implemented vaccine mandates. See Hall v. Sheppard Pratt Health System, Inc., No. 24-2048 (4th Cir. Oct. 21, 2025). It involves Covid-19. Five years after the beginning of the pandemic, healthcare employers are still defending discrimination claims because employees are resisting vaccines.
To review, employers can generally impose vaccine mandates provided that they consider requests for accommodation based upon disability or religion, but requests for accommodation are not automatic. Under Title VII of the Civil Rights Act of 1964, employers are required to accommodate an employee’s religious observance or practice unless doing so constitutes an undue hardship. Because of statutory differences, courts typically treat undue hardship under Title VII as a lower evidentiary hurdle compared to the same phrase under the Americans with Disabilities Act.
In Hall, the Fourth Circuit affirmed dismissal of a religious discrimination claim by an employee who resisted her employer’s COVID-19 vaccine mandate on religious grounds. Hall served as an Admissions Coordinator at an eating disorder center, and her duties required her to interact with patients in person. In response to the COVID-19 pandemic, Sheppard Pratt established several protocols to protect patients and staff. Sheppard Pratt experienced several COVID-19 outbreaks, which triggered isolation protocols. The isolation protocols disrupted patient treatment. Moreover, patients in the eating disorder unit were especially vulnerable to COVID-19.
Hall requested a religious accommodation when Sheppard Pratt implemented its vaccine mandate. Hall’s request was discussed with her and evaluated by Sheppard Pratt’s Vice President for Human Resources. Because Hall’s primary duties could not be performed remotely, she was advised that her request could not be accommodated, and she was offered the opportunity to apply for positions that could be performed remotely. Hall rejected this approach. Her employment was terminated and she filed suit, which was eventually dismissed by the trial court.
On appeal, the Fourth Circuit explicitly recognized that threats to health and safety of employees and patients can constitute an undue hardship, thus permitting healthcare employers to deny requests for accommodation in appropriate circumstances. The facts of Hall are unique, and the employer produced ample evidence regarding undue hardship, but the holding provides helpful guidance to healthcare employers, especially those with vulnerable patient populations.