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The National Law Review

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Seventh Circuit Affirms Summary Judgment for Hospital Employer in Religious Vaccine Exemption Case

In a recent decision providing important guidance for health care employers navigating religious accommodation requests related to vaccination policies, the Seventh Circuit Court of Appeals affirmed summary judgment in favor of a hospital employer that terminated a pharmacist who refused to receive the COVID-19 vaccine on religious grounds. The decision in Mason v. Cook County, Illinois underscores that employers in health care settings can successfully demonstrate undue hardship when denying religious exemptions to vaccine mandates, though a vigorous dissent highlights the evidentiary showings courts may expect. The Employer’s COVID-19 Vaccination Policy In Mason v. Cook County, Illinois, the plaintiff worked as a pharmacist in a room with approximately twenty other pharmacists and forty pharmacy technicians and also frequently interacted with patients and visited patient floors. In August 2021, Cook County implemented a policy mandating that staff members receive the COVID-19 vaccine by October 2021. The County based this policy on guidance from federal and state public health authorities, including the Centers for Disease Control and Prevention’s (CDC) finding that COVID-19 vaccination was the best way to reduce transmission and prevent severe illness, hospitalization, and death. The County determined that other mitigation methods alone — such as masking, social distancing, and

Cook County, IL · 10-05