Reported / Citable
Background
Legacy Health is a regional healthcare system operating eight hospitals in Washington and Oregon. In August 2021, with the Delta variant driving a surge of COVID-19 hospitalizations, Legacy adopted a vaccination policy requiring employees who performed services at its hospitals to be vaccinated or to obtain a religious or medical exemption by September 30, 2021. The policy created a structured exemption-review process.
Nine plaintiffs — physician assistants, respiratory therapists, nurses, and technicians at Legacy’s Salmon Creek medical center in Vancouver, Washington — were denied religious exemptions. All of their roles required close contact with patients or with other clinical staff. They sued under Title VII of the Civil Rights Act of 1964 (which bars religious discrimination in employment) and Washington state law, claiming Legacy was required to accommodate their religious objections to vaccination.
Title VII requires employers to make reasonable accommodations for an employee’s sincere religious beliefs unless doing so would cause "undue hardship" to the employer’s business. The U.S. Supreme Court in Groff v. DeJoy (2023) clarified that "undue hardship" means a substantial burden in the overall context of the employer’s business — not merely a more-than-de-minimis cost as some lower courts had previously held. The district court granted summary judgment to Legacy, finding that granting the exemptions would impose a substantial burden on Legacy’s healthcare-delivery business. The employees appealed.
The Court’s Holding
Judge McKeown, writing for a unanimous panel (joined by Judges Paez and Desai), affirmed in a published opinion. The court applied Groff‘s undue-hardship test and held Legacy carried its burden.
The court emphasized three points about Groff‘s standard. First, the relevant inquiry is whether the burden is substantial in the overall context of the employer’s business. Second, drawing on the Ninth Circuit’s earlier decision in Petersen v. Snohomish Regional Fire & Rescue (9th Cir. 2025), the court confirmed that substantial costs need not be exclusively monetary — they can include health and safety risks and operational burdens. Third, the costs need not have already materialized. A realistic risk of undue hardship is enough, provided the risk is not merely conceptual or hypothetical.
Applied to Legacy: granting the religious exemptions during the Delta surge posed three concrete risks. (1) The exempt employees themselves were more likely to fall ill, creating staffing shortages at a time of surging hospitalization demand. (2) Their elevated infection risk threatened other clinical staff who would also have to be pulled from patient care. (3) The transmission risk to patients — many already medically vulnerable — was severe. Together, these risks were realistic, substantiated by Legacy’s evidence about the Delta variant’s epidemiology, and substantial in the context of running a regional healthcare system. The plaintiffs did not meaningfully dispute Legacy’s evidentiary showing.
Summary judgment in Legacy’s favor on the Title VII claim affirmed.
Key Takeaways
- Groff’s undue-hardship test, as applied in the Ninth Circuit: the burden must be substantial in the overall context of the business — but health/safety risks and operational burdens count, not just direct monetary costs.
- Realistic risk is enough. Employers don’t have to wait for harm to actually occur before raising the undue-hardship defense; they can rely on prospective risk if it’s grounded in evidence rather than speculation.
- Healthcare-employer context is favorable to the employer. The combination of vulnerable patients, demand for clinical staffing, and transmission risk makes it relatively straightforward for healthcare systems to establish substantial burden from clinical-staff vaccine exemptions during outbreaks.
- Petersen v. Snohomish (9th Cir. 2025) remains the controlling Ninth Circuit interpretation of Groff‘s scope, and Williams applies it cleanly. Practitioners can cite both together.
- For California healthcare employers who faced (or face) similar Title VII challenges from COVID-era vaccine-policy denials: this opinion is now binding precedent in the Ninth Circuit and supports summary judgment where the evidentiary record on Delta-era staffing and patient-vulnerability risks is well developed.
Why It Matters
The post-Groff wave of Title VII religious-exemption cases brought by employees fired for refusing COVID vaccines has been working through the courts. The threshold question — what does Groff‘s "substantial burden in the overall context" standard actually require employers to show — has produced varying outcomes. Williams joins Petersen in giving the Ninth Circuit a stable, employer-favorable application of the test in the healthcare context: realistic risk is enough, the costs are substantial when patient safety is on the line, and summary judgment is appropriate where the employer’s evidentiary showing goes unrebutted.
For California hospital systems, public-health agencies, and large healthcare employers facing carryover litigation from 2021-2022 vaccine-mandate decisions, Williams provides clear authority for summary judgment in the typical case. For employee-side counsel, the path forward is narrower: the productive arguments will be on whether the employer’s evidence actually supports its undue-hardship claim, not on the legal standard itself, which is now well settled.