Maryland employers—especially in healthcare and safety-sensitive fields—may be able to deny religious accommodation requests that would materially increase risks or costs, according to a recent Federal Court ruling.

The United States Court of Appeals for the Fourth Circuit’s decision in Hall v. Sheppard Pratt Health System addressed whether a Maryland healthcare employer lawfully denied a religious exemption from its COVID-19 vaccine mandate.

While disability and religious accommodation requests related to COVID-19 appear to mostly be a thing of the past, the Hall case is the Fourth Circuit’s first opportunity to implement the new standard for assessing religious accommodation since the Supreme Court handed down its decision in Groff v. DeJoy in 2023.

The case also provides useful guidance that employers can apply to address other situations beyond COVID-19 policies.

Background of the Hall Case

Carolyn Hall, an Admissions Coordinator at Sheppard Pratt’s Center for Eating Disorders, refused vaccination on religious grounds and requested an accommodation. Her role, however, required daily in-person contact with vulnerable patients and staff.

The hospital denied her request, citing patient safety concerns and state health directives, and terminated her employment after she declined vaccination. Hall sued under Title VII of the Civil Rights Act, alleging religious discrimination and failure to accommodate.

The district court granted summary judgment for Sheppard Pratt, finding that allowing Hall to remain unvaccinated would create an undue hardship on the hospital’s operations.

The Facts on Appeal

On appeal, the Fourth Circuit affirmed. The court evaluated the case in light of the Supreme Court’s decision in Groff, which clarified that “undue hardship” under Title VII means an accommodation imposing substantial increased costs on the conduct of the employer’s business—not merely “more than de minimis” costs as under prior precedent.

This newer, stricter standard necessitated a close examination of whether Hall’s requested exemption would have meaningfully burdened the hospital.

Applying Groff, the Fourth Circuit concluded that Sheppard Pratt satisfied its burden. The employer presented detailed evidence that Hall’s position could not be performed remotely and that unvaccinated staff increased the risk of transmitting COVID-19 to medically fragile patients.

The Center had experienced multiple outbreaks lasting weeks, which disrupted treatment programs and increased costs. The hospital also demonstrated that it had explored alternatives—masking, testing, and remote work—but found them infeasible for Hall’s patient-facing duties. Hall herself admitted that her position required in-person contact.

The court emphasized that non-economic harms, such as health and safety risks or operational disruption, can qualify as “substantial costs” under the Groff standard. Importantly, it also noted the significance of scale: with more than 200 employees requesting religious exemptions, the cumulative effect of granting many similar accommodations could meaningfully impair the hospital’s ability to operate safely.

The Fourth Circuit therefore concluded that enforcing the vaccination mandate against Hall and denying her requested accommodation imposed no Title VII violation because accommodating her would have caused an undue hardship.

What Employers Should Take Away from this Decision

The decision provides important guidance for employers, particularly in healthcare and other safety-sensitive fields.

Even under the new, heightened standard for assessing requests for religious exemptions to workplace policies, employers can deny such requests when they can demonstrate that granting them would materially increase risks or costs, including the cost or disruption of having to apply such an exemption across the board, but they must document their analysis—considering job duties, feasibility of alternatives, and institutional risks.

Additionally, the company’s success in this case was attributed to the robust interactive process it engaged in with Ms. Hall before reaching its final decision. The ruling underscores the need for clear, consistent accommodation procedures and thorough individualized assessments rather than blanket denials.

For employees and practitioners, this case illustrates that post-Groff, courts expect concrete evidence from employers but remain deferential where the workplace involves health and safety concerns.

Employees seeking religious exemptions should propose practical accommodations and recognize that roles requiring in-person care are less likely to qualify.

More broadly, Hall signals that in post-pandemic litigation, while courts will balance religious rights against workplace safety using the Groff framework, Title VII’s protections remain strong but not absolute when substantial operational burdens exist.

Jim Hammerschmidt’s practice includes a range of commercial, corporate, and employment counseling and litigation in Maryland and the District of Columbia. For more information, please contact Jim at jrhammerschmidt@lerchearly.com or 301-841-0189.