The U.S. Supreme Court has declined to hear Petersen v. Snohomish Regional Fire and Rescue, a case involving religious-accommodation requests related to a COVID-19 vaccine requirement. By denying certiorari, the Court left the lower court’s ruling intact and declined to revisit the religious-accommodation framework established in Groff v. DeJoy (2023), which remains the governing federal standard for evaluating religious-accommodation requests under Title VII of the Civil Rights Act of 1964.
Background
The case arose after employees challenged a public employer’s handling of religious objections to a COVID-19 vaccination requirement. Following decisions in the lower courts, the petitioners sought Supreme Court review. The Court denied the petition on October 5, 2026, ending the litigation at the Supreme Court level.
Supreme Court Leaves Groff Framework Undisturbed
The practical significance of the denial is that the Court declined to revisit the religious-accommodation principles announced in Groff v. DeJoy.
In Groff, the Supreme Court clarified that an employer seeking to deny a religious accommodation under Title VII must show that the accommodation would result in substantial increased costs in relation to the conduct of its particular business, rejecting interpretations that had allowed denial based on only minimal burdens. As a result, employers must evaluate religious accommodations under the more demanding undue-hardship standard articulated in Groff.
By declining to hear Petersen, the Court left that framework unchanged. Employers should not view the certiorari denial as creating a new religious-accommodation rule or as modifying the Groff standard.
What the Decision Means for Employers
The denial of review does not create new law regarding:
- Religious accommodations;
- Vaccine-related accommodation requests;
- Undue hardship under Title VII; or
- Employer obligations when evaluating religious objections.
Instead, employers should continue applying existing federal law, including the Supreme Court’s guidance in Groff v. DeJoy, when assessing accommodation requests based on sincerely held religious beliefs.
Employer Takeaway
The Supreme Court’s refusal to hear Petersen v. Snohomish Regional Fire and Rescue leaves existing law unchanged. Employers should continue evaluating religious-accommodation requests under the standard established in Groff v. DeJoy, which requires employers to demonstrate a substantial burden on business operations before denying a requested accommodation based on undue hardship. The denial does not create a new accommodation standard and does not alter employers’ existing obligations under Title VII.