Supreme Court declines Title VII vaccine-exemption case in Doe v. Hochul

The U.S. Supreme Court declined to take up a religious-accommodation dispute involving healthcare workers who sought exemptions from COVID-era vaccination requirements, after denying certiorari in Doe v. Hochul on June 29, 2026.

Practically, the denial means the decision below—coming from the U.S. Court of Appeals for the Second Circuit—remains in effect for cases arising from similar facts in that circuit. A certiorari denial, however, is not a Supreme Court ruling on the merits.

What the Supreme Court did (and did not do)

In Doe v. Hochul (No. 24-1015), the Court denied the petition for a writ of certiorari. That procedural move leaves the lower court’s judgment in place, but it does not decide whether the legal reasoning used below was correct as a matter of Supreme Court law.

What the underlying case was about

The dispute centers on Title VII’s requirement that employers accommodate an employee’s sincerely held religious beliefs unless doing so would impose “undue hardship” on the employer’s conduct of business.

According to the dissenting opinion from Justice Gorsuch, the plaintiffs include New York State healthcare workers, including “John Doe 2,” a Christian Scientist who worked for New York-Presbyterian Healthcare System (NYP) for about a decade and did not receive vaccines based on his religious beliefs.

When vaccines became available in late 2020 and early 2021, the dissent describes that New York’s statewide COVID-19 healthcare mandate included exemptions for medical reasons and for sincere religious objections—so Doe’s longstanding exemption was initially maintained. But the dissent says that when state leadership changed, the state did away with the religious exemption. After that shift, NYP required vaccination, and when Doe declined, he was fired.

The dissent also describes that NYP rejected Doe’s proposed accommodation, which included “weekly testing and 100% Mask compliance.”

Why employers and workers care about this outcome

The key legal tension is how “undue hardship” is evaluated when an employer argues that accommodating a religious objection would put it at odds with state vaccine requirements.

In describing what the Second Circuit did, the dissent says the lower court held that granting the requested religious accommodations would impose “undue hardship” because it would require employers to violate the state vaccine regulation, potentially triggering financial penalties or other licensing consequences.

With the Supreme Court declining review, that framework remains the practical path courts in the Second Circuit are likely to follow for similar Title VII religious-accommodation disputes tied to healthcare vaccination rules—until another case changes the landscape.

What to watch next

For healthcare workers and employers, the “watch next” question is whether other religious-accommodation cases—especially those presenting different facts about exemptions, testing/safety alternatives, or the scope of state vaccine restrictions—ask the Supreme Court to revisit the issue.

Until then, the most immediate real-world impact is that disputes over religious exemptions in healthcare may continue turning on how lower courts apply the existing undue-hardship approach when accommodation requests collide with state vaccination requirements.

Sources

• U.S. Supreme Court order list (June 29, 2026) — certiorari denied in Doe v. Hochul (No. 24-1015)
• Cornell LII — Doe v. Hochul (No. 24-1015) case page