Williams v. Legacy Health
Applying the post-Groff undue-hardship standard, the Ninth Circuit affirms the rejection of healthcare workers’ Title VII religious-accommodation claims, holding that exempting them from a COVID-19 vaccination requirement would have imposed a “substantial” burden — measured by realistic health, safety, and staffing costs — on the hospital system.
Williams v. Legacy Health (9th Cir. 2026) 174 F.4th 1201
Ninth Circuit — binding federal authority on Title VII in the Ninth Circuit, including the district courts of California. Note: this case arose in the Pacific Northwest (Western District of Washington; Oregon-based employer), so it has no California-specific facts; it is included for its binding Title VII analysis. Confirm subsequent history before relying on it.
Discrimination
Title VII — religion
Undue hardship
Affirmed
In brief. Nine employees of Legacy Health, a Pacific Northwest hospital system, sought religious exemptions from its COVID-19 vaccination requirement and sued under Title VII when the exemptions were denied. The Ninth Circuit affirmed judgment for the employer. Under Groff v. DeJoy, Title VII undue hardship requires more than “a de minimis cost”; it is shown when a burden is “substantial in the overall context of an employer’s business.” Those substantial costs “need not be exclusively monetary” and may include “health and safety costs and operational burdens.” Legacy made that showing: in the context of the Delta variant, exempting unvaccinated clinical staff posed realistic risks of employee illness and absence, transmission to other staff needed to treat patients, and danger to its patient population — together a “substantial” burden. (Williams v. Legacy Health (9th Cir. 2026) 174 F.4th 1201, 1203–1205.)
By Jonathan J. Delshad
Draft for review · source-verification pending
Facts and statutory framework
Title VII “requires employers to make reasonable accommodations for their employees’ religious beliefs unless doing so would cause undue hardship to the employer’s business.” (174 F.4th at p. 1203; 42 U.S.C. § 2000e(j).) After the Supreme Court’s decision in Groff v. DeJoy (2023) 600 U.S. 447, “[s]howing more than a de minimis cost is insufficient to establish undue hardship”; rather, “undue hardship is shown when a burden is substantial in the overall context of an employer’s business.” (Id. at p. 1203, citing Groff, 600 U.S. at p. 470.) Under the Ninth Circuit’s decision in Petersen v. Snohomish Regional Fire & Rescue (9th Cir. 2025) 150 F.4th 1211, the “substantial additional costs need not be exclusively monetary”; they “can extend to health and safety costs and operational burdens,” and a projected hardship “will suffice, provided it is realistic and not merely conceivable or hypothetical.” (Id. at pp. 1203–1204.)
The plaintiffs were nine employees of Legacy Health, a public-benefit hospital system, and an affiliated acute-care group. (174 F.4th at p. 1201.) During the COVID-19 pandemic, Legacy adopted a vaccination requirement based on the scientific evidence and COVID data then available. (Id. at p. 1204.) The plaintiffs requested religious exemptions; Legacy denied them, concluding the exemptions would impose undue hardship, and the employees sued under Title VII. (Id. at pp. 1203–1204.)
Procedural history
The district court entered judgment for Legacy, and the Ninth Circuit affirmed in an opinion by Judge McKeown. (174 F.4th at pp. 1201, 1205.) The panel decided the case without oral argument. (Id. at p. 1201, fn. *.)
Issue
Did granting the plaintiffs’ requested religious exemptions from a healthcare employer’s COVID-19 vaccination requirement impose an “undue hardship” under Title VII, as that standard is understood after Groff v. DeJoy — such that the employer was not required to accommodate the exemptions? (174 F.4th at pp. 1203–1204.)
Holding
Affirmed. Exempting the plaintiffs would have caused undue hardship within the meaning of Title VII as construed in Groff. (174 F.4th at pp. 1203–1205.) The relevant costs “need not be exclusively monetary” and may include “health and safety costs and operational burdens,” so long as the projected hardship is “realistic and not merely conceivable or hypothetical.” (Id. at pp. 1203–1204.) In the context of the Delta variant, Legacy — “a healthcare system” — showed three realistic burdens from exempting unvaccinated clinical staff: the risk that employees “would become ill” and cause “staffing issues from their absence”; the transmission risk to “other staff needed to treat patients”; and the risk to “Legacy’s patient population.” (Id. at pp. 1204–1205.) “Taken together, Legacy’s ‘realistic’” concerns “threatened a ‘substantial’ burden on its business,” establishing undue hardship. (Id. at p. 1205.)
Reasoning
1. Groff raised the bar — but did not eliminate the defense. The court applied Groff’s clarified standard: undue hardship is no longer “more than a de minimis cost,” but a burden “substantial in the overall context of an employer’s business.” (174 F.4th at p. 1203, citing Groff, supra, 600 U.S. at p. 470.) That heightened threshold still permits employers to decline accommodations whose costs are genuinely substantial. (Ibid.)
2. Undue hardship is not limited to dollars. Drawing on Petersen, the court held the “substantial additional costs need not be exclusively monetary” and may include “health and safety costs and operational burdens as well as traditional financial” ones. (174 F.4th at pp. 1203–1204.) An employer may rely on a projected hardship, “provided it is realistic and not merely conceivable or hypothetical.” (Id. at p. 1204.) This framing is critical in the healthcare and public-safety contexts, where the principal harms of an accommodation are operational and safety-related rather than purely financial.
3. The healthcare context supplied realistic, substantial burdens. Applying that standard, the court found Legacy’s showing sufficient. Against the backdrop of the Delta variant, exempting unvaccinated clinical employees presented three concrete risks: those employees becoming ill and creating staffing shortfalls; transmitting the virus to coworkers needed to care for patients; and endangering Legacy’s patient population. (174 F.4th at pp. 1204–1205.) These were “realistic” rather than speculative, and “[t]aken together” they amounted to a “substantial” burden — undue hardship as a matter of law. (Id. at p. 1205.)
4. Sequencing of the undue-hardship inquiry. The court reiterated the structural point that an employer must engage the accommodation question in good faith — undue hardship is a defense to be assessed against a proposed accommodation, not asserted in the abstract — but held that Legacy’s evidence met the standard on this record, given the nature of its operations and the pandemic conditions it faced. (174 F.4th at pp. 1203–1204.)
Significance
Although Williams arose in the Pacific Northwest and involves no California facts, it is binding Ninth Circuit authority on Title VII that governs the federal district courts of California, where many religious-accommodation disputes are litigated. Its importance is twofold. First, it confirms that Groff’s elevated “substantial cost” standard did not abolish the undue-hardship defense, particularly for healthcare and other safety-sensitive employers. Second, it makes explicit — following Petersen — that undue hardship encompasses non-monetary “health and safety costs and operational burdens,” assessed by a realistic (not merely hypothetical) projection. For California employers and employees alike, the decision is a useful template for how COVID-19 vaccine-exemption and other religious-accommodation claims will be evaluated in the Ninth Circuit, even as parallel claims under California’s FEHA proceed under state-law accommodation standards.
Key quotes
“Showing more than a de minimis cost is insufficient to establish undue hardship under Title VII. Rather, undue hardship is shown when a burden is substantial in the overall context of an employer’s business.” (Williams, supra, 174 F.4th at p. 1203.)
“[T]he substantial additional costs need not be exclusively monetary. They can extend to health and safety costs and operational burdens … provided [the hardship] is realistic and not merely conceivable or hypothetical.” (Williams, supra, 174 F.4th at pp. 1203–1204.)
Read the full opinion (U.S. Court of Appeals, Ninth Circuit) →
Practice pointer
For Title VII religious-accommodation claims in the Ninth Circuit, do not assume Groff dooms every undue-hardship defense — but hold employers to the “substantial” burden standard and to a realistic, evidence-backed projection rather than speculation. Plaintiff-side counsel should probe whether the asserted hardship is concrete and supported (here, Delta-era staffing, transmission, and patient-safety evidence in a hospital) or merely “conceivable,” and should distinguish safety-sensitive settings from ordinary workplaces where exemptions impose little operational cost. Employers asserting undue hardship should build a contemporaneous record tying the specific accommodation to substantial health, safety, or operational consequences. And remember the forum and law matter: a parallel claim under California’s FEHA is governed by state accommodation standards, which counsel should analyze separately from Title VII. (174 F.4th at pp. 1203–1205.)
Open questions
Because the burden here was rooted in pandemic-era, healthcare-specific facts, the opinion does not establish how the “substantial … health and safety costs and operational burdens” framing applies outside safety-sensitive industries, where exempting a single employee may impose little realistic hardship. (174 F.4th at pp. 1204–1205.) It also leaves for future cases how granular an employer’s evidentiary showing must be — and how individualized — when many employees seek the same exemption, as opposed to relying on a generalized operational projection. (Id. at p. 1204.) Finally, the decision does not address how its Title VII analysis compares with California’s FEHA religious-accommodation and undue-hardship standards, which may diverge. (Id. at p. 1203.)