Overview
On October 21, 2025, the Fourth Circuit Court of Appeals issued an important decision in Hall v. Sheppard Pratt Health System, Inc., affirming summary judgment for the employer. The case involved Carolyn Hall, a hospital admissions coordinator who was fired after refusing the COVID-19 vaccine based on her religious beliefs. Hall argued that her termination violated Title VII of the Civil Rights Act, which requires employers to accommodate sincerely held religious beliefs unless doing so would create an undue hardship.
The court sided with the employer, holding that exempting Hall from vaccination would have endangered patients and placed substantial operational and financial burdens on the hospital.
The Facts
Hall worked in admissions at Sheppard Pratt’s Center for Eating Disorders, a program treating medically fragile patients. Her job required in-person interaction with patients and families on a daily basis. During the pandemic, the hospital required all employees to be vaccinated unless they qualified for a medical or religious exemption.
Hall submitted a religious exemption request supported by a letter from her pastor. The hospital denied the request after determining that her role required direct contact with vulnerable patients and that allowing her to remain unvaccinated would increase the risk of COVID-19 transmission. She was offered the opportunity to apply for other remote positions but declined. When she refused vaccination, Sheppard Pratt terminated her employment.
The Legal Framework: Religious Accommodation Under Title VII
Title VII requires employers to reasonably accommodate an employee’s religious beliefs unless doing so would impose an undue hardship on the business. For many years, courts interpreted that term to mean any burden that was more than minimal. In 2023, the Supreme Court clarified in Groff v. DeJoy that employers must show that the requested accommodation would cause substantial increased costs in relation to the conduct of their business.
The Fourth Circuit applied this updated standard in Hall’s case.
The Court’s Decision
The court found that allowing Hall to work without vaccination would have created an undue hardship for several reasons.
First, her position involved close contact with medically vulnerable patients. The hospital relied on public health guidance showing that vaccination was more effective than masking or weekly testing at preventing COVID-19 transmission. The court agreed that patient safety justified the hospital’s decision.
Second, the hospital had experienced repeated COVID outbreaks that disrupted treatment and forced temporary closures of group programs. Each outbreak caused both financial losses and harm to patient care.
Third, the court recognized that Hall’s unvaccinated status would have put her coworkers at risk, particularly during a time of staff shortages. Replacing sick employees with temporary workers was expensive and unsustainable.
Finally, Sheppard Pratt had considered alternatives. It determined that Hall’s job could not be done remotely and even invited her to apply for other positions that could be performed from home. The court also rejected Hall’s argument that she should have received the same accommodation as employees with medical exemptions. Title VII’s standard for religious accommodations is different from the Americans with Disabilities Act (ADA), which imposes a higher burden on employers to prove undue hardship.
In the end, the court concluded that granting even one exemption—let alone the 200 other requests the hospital received—would have posed unacceptable safety and operational risks.
Key Takeaways for Employees
The Hall decision is one of the first to apply the Supreme Court’s Groff ruling, and it shows that employees still face an uphill battle when requesting religious exemptions in health care settings.
- The updated “undue hardship” test is somewhat more demanding for employers than before, but safety and cost concerns can still justify denying an accommodation.
- Health and safety risks—especially to patients or coworkers—can qualify as an undue hardship even without a direct financial cost.
- Employers do not have to treat religious and medical exemptions the same way. The law sets different standards for each.
- Employees seeking religious accommodations should engage in a cooperative process with their employer and be open to alternative arrangements. Refusing to participate can weaken a claim.
- Each case depends on the specific job duties and work environment. Employees whose jobs can be done remotely or with minimal risk of harm may have stronger claims.
Why This Case Matters
Hall v. Sheppard Pratt highlights how courts are applying the new standard from Groff v. DeJoy. Although Groff was seen as a victory for employees, this case shows that in workplaces where safety is critical—like hospitals—employers can still deny religious exemptions if they present real risks or significant costs.
For employees, this decision is a reminder that religious accommodation cases are highly fact-specific. The key is to clearly explain your beliefs, suggest reasonable alternatives, and stay engaged in the process. If your employer denies your request or retaliates against you for raising a religious accommodation issue, you should talk with an experienced employment attorney about your options.
Talk to an Employment Lawyer
If you’ve been denied a religious accommodation or terminated for refusing to comply with a workplace policy because of your faith, Gibbons Law Group can help. We represent employees throughout North Carolina in religious discrimination, retaliation, and wrongful termination cases. Call us for a confidential consultation to discuss your rights and next steps.