Under Title VII, employers must provide a “reasonable accommodate” sincerely held religious beliefs, unless doing so would impose an “undue hardship” on the conduct of their business. Courts continue to refine what “reasonable accommodation” and “undue hardship” mean in this context, particularly in safety-sensitive environments. For many years, courts interpreted undue hardship to mean anything more than a “de minimis” burden. In Groff v. DeJoy, however, the Supreme Court corrected that understanding, and held that employers must now demonstrate that a requested accommodation would impose “substantial increased costs” in relation to the operation of their particular business. This analysis requires consideration of all relevant factors, including the nature, size, and operating costs of the organization, the employee’s specific job duties, the practical impact of alternative accommodations, and the cumulative effect of granting the same accommodation to many employees. At the same time, Groff reaffirmed that Title VII’s undue-hardship standard remains less demanding than the Americans with Disabilities Act, meaning employers may grant medical accommodations under the ADA while declining comparable religious accommodations under Title VII when the operational impacts differ.
A recent Fourth Circuit decision, Hall v. Sheppard Pratt Health System, Inc. (No. 24-2048, 4th Cir. Oct. 21, 2025), provides practical and timely guidance on how courts are applying the Groff framework, and illustrates the kind of evidence that meets the “substantial increased costs” standard. As many employers face growing numbers of religious accommodation requests, from vaccine exemptions to scheduling conflicts, Hall offers valuable direction for evaluating such requests consistently and defensibly.
Background of the Case
In Hall, the Fourth Circuit applied these principles to a residential treatment program serving medically fragile patients with eating disorders. The plaintiff, an admissions coordinator, sought a religious exemption from the employer’s COVID-19 vaccination requirement. Her job required frequent, close, in-person contact with patients, families, and other staff members. The employer evaluated her request through a documented, individualized process, concluding that the position could not be performed remotely, that alternatives such as masking and weekly testing were less effective than vaccination at reducing transmission risk, and that granting exemptions to the hundreds of employees who had made similar requests would significantly increase the likelihood of COVID-19 outbreaks at the treatment facility. The record showed that the facility had already experienced twenty-two (22) outbreaks, each of which caused unit lockdowns, disrupted treatment programming, halted new admissions, and required the employer to hire higher-cost temporary staff in the midst of a statewide healthcare labor shortage.
Why the Employer Prevailed
The Fourth Circuit affirmed summary judgment for the employer and held that the combination of patient-safety risks, operational disruptions, and financial consequences satisfied the “substantial increased costs” standard. The court emphasized that allowing an unvaccinated employee to continue working in a setting with medically compromised patients posed an “unacceptably high risk to patient safety,” accepting the employer’s evidence on that issue as undisputed in the record. The court also explained that, consistent with Groff v. DeJoy and Trans World Airlines, Inc. v. Hardison, employers may consider the cumulative effect of granting the same accommodation to large numbers of employees—in this case, more than two hundred religious-exemption requests across the hospital system. Finally, the court confirmed that the employer was not required to offer the same accommodations provided to employees with medical exemptions, because the ADA and Title VII impose different legal standards and because the employer presented unchallenged evidence that masking and weekly testing were less effective than vaccination in this clinical environment.
Takeaways for Employers in Any Industry
Document Real-World Impacts: Courts expect employers to show how the requested accommodation would affect their actual operations. Employers should be prepared to document role-based duties, workflow demands, safety considerations, staffing limitations, and the likely operational consequences of the requested accommodation.
Evaluate Alternatives Carefully and Individually: Title VII requires employers to consider whether any reasonable alternative accommodation would avoid the undue hardship. This evaluation means engaging in a genuine, individualized interactive process and assessing whether each proposed alternative would mitigate the operational or safety risks identified, based on the realities of the employer’s workplace.
Distinguish Between Religious and Medical Accommodations When Appropriate: Hall confirms that accommodations granted under the ADA for medical reasons do not control the outcome of religious accommodation requests under Title VII. Because the ADA and Title VII apply different undue-hardship standards, employers may reach different conclusions so long as the distinction is grounded in documented legal, operational, or safety-based differences.
Consider the Total Number of Similar Requests: If many employees might seek the same accommodation, employers may consider the aggregate burden if granting one request would necessitate granting many others. When a requested accommodation could result in substantial cumulative operational or safety impacts across a workforce, courts will permit employers to account for that broader context.
Communicate with Transparency and Consistency: Clear explanations of business needs, the reasoning behind decisions, and the factors considered in the interactive process help demonstrate that decisions are neutral and grounded in legitimate concerns.
It is equally important for employers to understand what Hall does not do and the limits that still apply when navigating religious accommodation requests. The decision does not permit employers to issue blanket denials without individualized review, and each request must still be considered on its own merits through a genuine interactive process. It does not lessen the obligation to evaluate reasonable alternatives, and even in safety-sensitive settings employers must determine whether any accommodation would allow the employee to perform the job without creating substantial increased costs. The ruling is not confined to healthcare. Although Hall involved medically vulnerable patients, its reasoning applies to any industry where an employer can demonstrate a concrete operational or safety impact. The decision also does not allow employers to rely on broad assumptions about inconvenience or hypothetical burdens, as courts continue to require specific, evidence-based justification tied to the employer’s actual operations.
Hall v. Sheppard Pratt shows that the law of religious accommodation continues to develop in the wake of Groff. Employers should expect courts to require detailed, fact-specific evidence linking the requested accommodation to substantial increased costs, whether measured in financial terms, operational disruption, or identifiable safety risks. Organizations that invest in clear documentation, strong policies, and consistent processes will be better positioned to navigate religious accommodation requests in 2026 and beyond.
If you have any questions about the religious accommodations, medical accommodations, or any other employment law matter, please contact the lawyer you regularly work with at Airdo Werwas, LLC, Michael A. Airdo at mairdo@airdowerwas.com, or Felicia L. Owen at fowen@airdowerwas.com.
