Labor & Employment Law Daily Wrap Up, WORTH NOTING—Recent developments involving religious discrimination, (Sep 12, 2025)

By WK Editorial Staff

A roundup of recent decisions involving religious discrimination cases of interest to the labor and employment law community.

E.D. Cal.: Employee’s proposed addendum to oath would not have caused state office undue hardship. After being hired by a state office, an employee refused to sign a mandatory oath due to her religious beliefs as a Jehovah’s Witness. She proposed an addendum to the oath clarifying her religious stance, which the state office rejected, leading to the rescinding of her job offer. She sued, alleging violations under Title VII, Section 1983, and state law. The parties filed cross-motions for summary judgment. The court granted summary judgment for the employee on her Title VII failure-to-accommodate claim, determining that her religious beliefs genuinely conflicted with the oath and that the state office did not demonstrate undue hardship in accommodating her request. However, the court found a material fact issue on the disparate impact claim, precluding summary judgment for either party. The court dismissed the Section 1983 claim as untimely and dismissed the remaining claims (Bolden-Hardge v. Office of the California State Controller, No. 2:20-cv-02081-JAM-SCR (E.D. Cal. Aug. 29, 2025)).

M.D. Pa.: COVID accommodations would have subjected employer to undue hardship. An employee of a healthcare company was terminated for failing to comply with the company's COVID-19 vaccine mandate, which she claimed conflicted with her religious beliefs. She sued the company, alleging religious discrimination under Title VII and the Pennsylvania Human Relations Act. The healthcare company moved for summary judgment, arguing that the employee “failed to establish that she had a sincerely held religious belief that conflicted with a job requirement and informed 3M of that belief,” and that providing her accommodations “would have subjected it to an undue hardship.” The court held that accommodating the employee’s request would impose an undue hardship on the employer due to potential competitiveness and safety-related concerns. Accordingly, the court granted summary judgment for the employer (Cleckner v. 3M Co., No. 1:22-cv-02055-JPW (M.D. Pa. Sept. 2, 2025)).

S.D.N.Y.: Employee alleged harassment, discrimination due to beard. A former parks department employee sued the parks department alleging discrimination, retaliation, and a hostile work environment under Title VII, primarily due to his religious practices, which included wearing a beard and attending Sunday services. He alleged that his supervisor made disparaging remarks regarding his beard. After receiving a religious accommodation to wear his beard and take one Sunday off per month for religious services, he claimed he faced harassing comments from superiors. He eventually resigned due to an “ongoing history of harassment,” and sued the parks department. The parks department moved for summary judgment and the court found he could not demonstrate that the delay in receiving “shielded” status or his transfer to a different park constituted adverse employment actions as there was no evidence of promotions being withheld or that the transfer negatively impacted his employment terms. Additionally, the court determined that his employee’s failure-to-accommodate claim was time-barred. The court also held that the alleged retaliatory actions, including threats of write-ups and negative comments, did not rise to the level of materially adverse actions that would dissuade a reasonable person from engaging in protected activity. The hostile work environment claim failed because the conduct described was not sufficiently severe or pervasive (Stancu v. New York City Parks Department, No. 1:20-cv-10371-MMG-HJR (S.D.N.Y. Aug. 25, 2025)).

W.D. Wash.: Vaccine mandate accommodation would have been undue hardship for healthcare system. A regional healthcare network implemented a policy requiring all employees to be vaccinated against COVID-19, aligning with state and federal mandates. This policy allowed exemptions for medical or religious reasons, but employees with such exemptions were placed on unpaid leave if their roles could not be performed remotely. Fifty-three employees sued the healthcare network, alleging failure to accommodate, disparate treatment, disparate impact, and hostile work environment under Title VII and the Washington Law Against Discrimination, among other things. The healthcare network moved for summary judgment, arguing that accommodating the employees would pose an undue hardship due to increased health and safety risks to patients and staff. The court found in favor of the healthcare network, ruling that “accommodating [the employees]—by allowing them to continue working at [the healthcare network’s] facilities while unvaccinated—would have imposed ‘substantial increased costs’ to its business, resulting in an undue hardship” (Zimmerman v. PeaceHealth, No. 3:22-cv-05960-TMC (W.D. Wash. Aug. 26, 2025)).

Cases: ReligiousDiscrimination Discrimination Discharge Covid19 PublicEmployees