Reported / Citable
Background
Brittany MacDonald, a nurse in a hospital mother-and-baby unit, sought a religious exemption from Oregon Health and Science University’s COVID-19 vaccination requirement. The university denied the request, and she sued the institution and individual officials under Title VII and the Free Exercise Clause.
The district court granted qualified immunity to the individual defendants and summary judgment to the hospital on the accommodation claim. MacDonald appealed, arguing both that officials discriminated against her asserted beliefs and that the hospital had not met Title VII’s demanding undue-hardship standard.
The Court’s Holding
The Ninth Circuit affirmed. The majority held that no clearly established law placed the constitutional question beyond debate when officials evaluated MacDonald’s asserted religious objection, so the individuals were protected from damages by qualified immunity.
The hospital also proved that allowing an unvaccinated nurse to keep working in the unit would impose substantial health and safety costs. That evidence satisfied the Supreme Court’s Groff standard, which requires substantially increased costs in relation to the employer’s particular business, not merely a minimal burden. Judge Tung dissented from the qualified-immunity ruling but agreed with the Title VII result.
Key Takeaways
- Healthcare employers must support undue hardship with evidence tied to the employee’s actual role and patient setting.
- Groff requires substantial increased costs, but material patient and workforce safety risks can meet that standard.
- Qualified immunity turns on whether prior law clearly established the right in the specific context.
- A sincerely asserted religious objection does not automatically require the employer to accept every requested accommodation.
Why It Matters
This published opinion gives California healthcare employers and employees additional guidance on post-Groff religious-accommodation analysis. Employers still need an individualized, evidence-based assessment; the decision does not create a categorical rule that every vaccination exemption causes undue hardship.