The U.S. Supreme Court on September 4 denied a rehearing bid in Doe v. Hochul, a lawsuit brought by New York healthcare workers who challenged the state’s COVID-19 vaccine mandate for blocking religious exemptions.
The mandate, which required healthcare workers to be vaccinated against COVID-19, was repealed in late 2023. However, the lawsuit continued as the workers argued that lower-court rulings set a harmful precedent for future mandates that could undermine protections under Title VII of the Civil Rights Act.
The Supreme Court’s decision not to rehear the case followed its June rejection of the workers’ initial petition to review the case. In that earlier denial, Justice Neil Gorsuch dissented, joined by Justices Clarence Thomas and Samuel Alito, writing that the case raised “an important and recurring question of federal law.” Gorsuch argued the high court should have taken up the case to clarify whether employers could use state mandates to justify denying religious accommodations under Title VII.
Lower courts had ruled against the workers. The U.S. Court of Appeals for the Second Circuit upheld the mandate’s enforcement, stating that granting religious exemptions would have required employers to violate state regulations, exposing them to financial penalties or license suspensions. The appeals court concluded that such an outcome constituted an “undue hardship” under Title VII, which does not require employers to accommodate religious practices if doing so imposes significant costs or operational burdens.
The workers’ legal team argued that the state’s refusal to grant religious exemptions violated their rights under Title VII, which protects employees from discrimination based on religion. They contended that the mandate’s enforcement led to the termination of healthcare workers who refused vaccination on religious grounds, even after the mandate was lifted. The case has drawn attention to broader debates over the balance between public health mandates and religious freedoms, as well as the authority of states to impose vaccination requirements for essential workers.
The Supreme Court’s decision not to intervene leaves in place the lower courts’ rulings, which have set a legal standard that some legal scholars argue could limit future religious accommodation claims in employment contexts. The case also highlights ongoing tensions between state regulatory power and federal civil rights protections, particularly in high-stakes public health emergencies.