The U.S. Equal Employment Opportunity Commission (EEOC) sued the Mayo Clinic, alleging the clinic violated Title VII of the Civil Rights Act of 1964 by refusing to grant a security guard a religious exemption from its mandatory COVID-19 vaccination policy.
The policy required all employees to be vaccinated unless they qualified for medical or religious exemptions. The security guard, a member of the Assemblies of God Church, requested an exemption citing religious beliefs that prohibited him from receiving the vaccine because of alleged certain ingredients and his faith's teachings on bodily sanctity. He offered to comply with masking and testing protocols instead of vaccination. However, the Mayo Clinic denied his request and later his request for reconsideration, warning that he would be terminated if he did not get vaccinated. Ultimately, to keep his job, the security guard complied with the vaccination mandate.
The EEOC's lawsuit, filed in July 2025 in federal court in Minnesota, contains allegations that Mayo Clinic refused the accommodation request because it doubted the sincerity of the guard's religious beliefs.
Under Title VII of the Civil Rights Act, employers are obligated to reasonably accommodate sincerely-held religious beliefs unless the accommodation causes an undue hardship, which recent legal rulings clarify as requiring a substantial business burden, not just minimal cost. The EEOC contends Mayo's actions forced the employee to choose between his religious conscience and his employment, violating federal law. The EEOC seeks monetary damages, punitive damages, and a court order requiring Mayo Clinic to revise its policies.
Source: https://www.eeoc.gov/newsroom/eeoc-sues-mayo-clinic-religious-discrimination
Commentary
Employers are legally required to engage in a good-faith, interactive process when presented with requests for religious accommodation and must provide such accommodations unless they can demonstrate the accommodation would impose a substantial undue hardship.
A recent Supreme Court ruling shifted the standard of undue hardship from a low threshold to one requiring substantial cost or burden relative to the employer's business, raising the bar for denying accommodations. This means healthcare employers need to carefully assess each accommodation request individually and cannot rely on generalized or minimal inconvenience arguments to refuse accommodations.
Healthcare employers should be proactive in establishing clear, documented policies and procedures to address religious accommodation requests.
Training managers and human resources personnel on sincerely-held religious beliefs and how to conduct respectful, individualized assessments is critical to both compliance and loss prevention.
Documentation of the interactive process and the basis for any decisions made is essential because courts and regulatory agencies will expect clear evidence that the employer considered alternatives before denying accommodations.
Flexible solutions, such as telework, adjusted schedules, masking, social distancing, or effective testing protocols, often present possible accommodations that do not disrupt operations (depending on the job duties) and can help avoid costly litigation or regulatory action.
The final takeaway is that ignoring or dismissing requests without a thorough exploration of alternatives increases the risk of discrimination claims and associated fines or damages.
