Court says neutral health-data rules can stand – see what survived and why
Chicago’s COVID testing portal fight ends with a win for the city and a strong signal on how far HR can go with health reporting.
On December 2, 2025, the U.S. Court of Appeals for the Seventh Circuit upheld Chicago’s COVID-19 vaccination and testing policy against a challenge from a group of city employees, most of them police officers. The workers alleged that the city overstepped by requiring them to enter their vaccination status and weekly test results into an employee portal, even after granting them religious exemptions from getting the shot.
For HR leaders, the case goes to the heart of a tough pandemic-era question: once you grant a religious exemption, how far can you still push on safety rules and data reporting?
Chicago’s policy, introduced in October 2021, required city employees either to be fully vaccinated or undergo regular COVID-19 testing. The policy also required employees to report their vaccination status and, if unvaccinated, weekly COVID-19 test results through an employee portal. Employees who failed to follow those testing and reporting rules were placed in a non-disciplinary, no-pay status until they reported their results.
Seventeen employees, including sixteen current or former Chicago police officers and one officer from the Office of Emergency Management, initially refused to enter their information even after supervisors gave direct orders. Those who eventually complied returned to work for the city. The plaintiffs who refused to comply did not return.
The employees brought several legal claims, including alleged violations of their right to freely exercise religion, equal protection under the Fourteenth Amendment, Title VII of the Civil Rights Act of 1964, and the Illinois Religious Freedom Restoration Act. Their core allegation was that the city burdened their religious beliefs and subjected them to adverse actions by enforcing the portal reporting rules.
Both the district court and the appeals court focused on a key point: the city granted the religious exemptions the plaintiffs requested from vaccination. The courts noted that the plaintiffs did not explain how entering information into the portal itself conflicted with any specific religious belief.
The appeals court also examined how the policy operated. The vaccination-status reporting requirement applied to all employees covered by the policy, without distinguishing between religious and nonreligious employees. The testing-reporting requirement likewise applied to all covered employees who were not fully vaccinated by a certain date. The court rejected the claim that the city selectively enforced the reporting rules against religious employees, noting that some of the alleged inconsistencies involved individuals who had not yet requested exemptions when they were disciplined.
Because the reporting rules were neutral and generally applicable, the court applied a deferential “rational basis” standard and asked whether the policy’s requirements and enforcement mechanisms were reasonably related to a legitimate government interest. It concluded that tracking who was vaccinated and who was undergoing COVID-19 testing, and using that information to identify potential risks and protect employees and the public, was rational during a global pandemic. The use of non-disciplinary, no-pay status for noncompliance was also found to be a rational way to enforce the policy.
The court then rejected the remaining claims. The Illinois Religious Freedom Restoration Act claims were treated as rising and falling with the constitutional arguments and therefore failed as well. The Title VII claims by three plaintiffs were deemed waived on appeal because they were raised in the statement of issues but not meaningfully developed with supporting argument and authority.
For HR professionals, especially in large public and private organizations, the decision carries several practical lessons. Granting a religious exemption from vaccination does not, by itself, prevent an employer from enforcing neutral, across-the-board safety and reporting requirements. When those requirements apply to all covered employees and are not directed at any faith, they are more likely to withstand legal scrutiny.
The case also highlights the value of clear documentation. Chicago had a written policy, defined procedures for seeking exemptions, and a stated enforcement framework. Those features helped show that the city was applying its rules based on role and risk, not targeting particular religious beliefs.
Finally, the ruling underscores that employees challenging a policy need to identify a specific way a requirement conflicts with a concrete religious practice. General objections to a system, without that link, are unlikely to succeed. For HR leaders planning future vaccination, testing, or health-data protocols, the December 2 decision suggests courts may give employers considerable room to require health-related data reporting and to enforce those rules, so long as policies are neutral, consistently applied, and tied to workplace safety.
