Supreme Court Declines Review in New York COVID Vaccine Religious-Accommodation Case

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On June 29, 2026, the U.S. Supreme Court declined to take up Doe v. Hochul, leaving in place the lower-court outcome in a lawsuit brought by former New York healthcare workers who said they were denied religious accommodations from COVID-19 vaccine requirements.

The Court’s action is procedurally final for that case, but it is not a merits ruling on how Title VII’s religious-accommodation standard should work nationwide.

What the Supreme Court did (and didn’t do) i

In Doe v. Hochul (No. 24-1015), the Supreme Court denied certiorari. In practice, that means the dispute ends at the Supreme Court for now, and the earlier federal appellate decision remains controlling for the parties in that posture.

The accompanying materials include a recorded dissenting statement by Justice Neil Gorsuch, joined by Justices Clarence Thomas and Samuel Alito.

The core federal question: Title VII and “undue hardship” i

Title VII of the Civil Rights Act of 1964 generally requires employers to accommodate employees’ sincerely held religious beliefs—unless doing so would impose “undue hardship” on the employer.

In Doe v. Hochul, the battleground wasn’t only about whether employers must consider accommodation requests. The petitioners urged the Court to weigh how state rules on vaccine exemptions can interact with the federal “undue hardship” analysis—an issue with obvious stakes for healthcare employers and workers across the country.

In DOJ filings tied to the case, the federal question was framed around whether the petition presented a suitable vehicle for resolving the broader Title VII dispute the parties raised.

Why New York’s approach mattered to the litigation i

Federal and state policies intersected in the case because the religious-accommodation claims arose in the context of New York healthcare vaccine requirements. The lower courts rejected the workers’ Title VII position, and the Supreme Court’s cert denial means those outcomes stand for now without a national rule-setting decision.

What stays in place—and what to watch next i

For now, the practical message for healthcare employers and workers nationwide is restraint, not a universal “yes” or “no.” Because the Supreme Court did not reach the merits, future disputes—especially those involving state limits on religious accommodations—remain a live flashpoint for lower courts.

What to watch next:

• Whether other federal courts treat the Doe v. Hochul dispute as persuasive when similar state-health rules restrict accommodation options.
• How employers document individualized assessments under Title VII, rather than relying on broad assumptions about what counts as an accommodation.
• Whether a later case gives the Supreme Court a clearer opportunity to resolve the federal “undue hardship” framework question.

Sources

• U.S. Supreme Court (No. 24-1015) — Doe v. Hochul order(s)/opinion PDF (cert denial + dissent/dissenting views where reflected)
• U.S. Department of Justice — Solicitor General amicus/brief (Doe v. Hochul), DOJ PDF
• CBS News — Report on Supreme Court rejecting the New York COVID vaccine mandate legal battle for healthcare workers

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