Three workers cited religion but couldn't explain how testing violated their actual beliefs
A federal appeals court has ruled that saying workplace requirements violate your "moral conscience" is not enough to claim religious discrimination under employment law.
The Seventh Circuit delivered that message on February 13 when it affirmed the dismissal of claims brought by three Illinois school employees who refused both COVID-19 vaccination and weekly testing during the pandemic.
The case centered on what happened after Governor J.B. Pritzker issued an executive order in September 2021 requiring school personnel to either get vaccinated or submit to weekly testing. Amanda Humphreys, Latosha Bowlin, and Nicole Potthast all worked at different school districts and all sought religious exemptions from the vaccine requirement.
Their employers offered weekly testing as an accommodation. But all three refused that option too. Humphreys was suspended without pay and later terminated from North Mac CUSD No. 34. Bowlin was fired from Judah Christian School. Potthast was suspended without pay from Staunton CUSD No. 6.
The employees sued in November 2022, arguing their employers violated federal civil rights law by discriminating against them based on religion. They claimed the testing requirement violated their "moral consciences" because they should not have to submit to health care procedures they did not believe were medically necessary.
They also said their consciences prevented them from participating in workplace procedures that discriminate between employees based on health care choices. Instead of testing, they offered to self-monitor for symptoms, wear masks when appropriate, and voluntarily report potential symptoms.
The district court was not persuaded and dismissed the case. The employees appealed, but the Seventh Circuit agreed with the lower court.
Writing for the panel, Circuit Judge Lee explained that employees seeking religious accommodations must identify specific religious beliefs, practices, or observances that a workplace requirement would violate. The problem here was that the employees never connected their objection to testing with any particular religious belief.
The court pointed to a recent similar case where an employee opposed testing but could not cite any religious teaching against it or explain how testing interfered with religious practice. General objections based on personal medical autonomy or moral discomfort simply do not qualify for protection under federal employment discrimination law.
The court also rejected the argument that being treated differently from other employees through an accommodation somehow violated the employees' religion. That logic would allow anyone to refuse any accommodation simply because it creates different treatment, which makes no sense given that accommodations by definition involve differential treatment.
Even if the employees had properly identified a religious objection, the court said, their requested accommodation would have failed anyway. What they wanted was exemption from both vaccination and testing, but the governor's order required one or the other with no additional options. Executive orders carry the force of law, the court noted, and allowing the employees to work without complying would have forced the schools to break the law.
That crosses the line into what employment law calls undue hardship. Every federal appeals court to address the question has held that employers do not have to accommodate religious beliefs if doing so would require violating federal or state law.
The decision offers important guidance for human resources professionals navigating religious accommodation requests. The takeaway is clear: employees need to do more than invoke religion or conscience. They must explain what specific belief or practice is at stake and how the workplace requirement conflicts with it.
The ruling also confirms that reasonable accommodation does not mean giving employees whatever arrangement they prefer. Once an employer offers an alternative that eliminates the conflict between work requirements and religious practice, the legal obligation is satisfied.
For organizations implementing government-mandated policies, the case provides reassurance that accommodations cannot require legal violations, even when employees frame their objections in religious terms.
