Williams v. Legacy Health, 2026 WL 1239760 (9^th Cir. 2026)

Employees of Legacy Health were denied religious exemptions from the employer’s COVID‑19 vaccination policy based on the undue hardship the exemptions would have caused the employer’s business. Granting the employees’ exemption requests posed undue hardship to Legacy in that it created a risk that employees would become ill and cause staffing issues from their absence and the infection could jeopardize the health of Legacy’s patient population. In applying the undue hardship test as recently clarified by the Supreme Court in Groff v. DeJoy, 600 U.S. 447 (2023), the Ninth Circuit affirmed summary judgment for the employer, holding that proof of “prohibitive financial hardship” is not necessary to show undue hardship and “while that type of hardship may be sufficient, it is not necessary. ‘Health and safety costs’ matter, too.” See also Cardenas v. Los Angeles Unified School Dist., 2026 WL 1283679 (Cal. Ct. App. 2026) (employees forfeited challenge to summary judgment in COVID‑19 vaccine accommodation case where there was no citation to record evidence in either the trial or appellate court).