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new Fourth Circuit decision applying the Supreme Court’s Groff v. DeJoy standard shows that “undue hardship” still has teeth. The court sided with an employer that denied a religious exemption from its COVID-19 vaccine policy, but its reasoning stretches far beyond vaccines or
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althcare. TL;DR: In an October 2025 Fourth Circuit decision, the court affirmed summary judgment for an employer that denied a religious exemption to its COVID-19 vaccination policy. The court held that exempting the employee would have caused “substantial increased costs in relation to the conduct of its particular business” under Groff v. DeJoy (2023). The decision