In Washington, eight firefighters with Snohomish Regional Fire and Rescue (SRFR) sought religious exemptions from Washington State’s 2021 COVID-19 vaccine mandate for healthcare workers. SRFR denied their requests, concluding it could not safely or feasibly accommodate unvaccinated firefighters in frontline roles. Instead, pursuant to a memorandum of understanding between SRFR and the firefighters’ union, SRFR allowed affected employees to use accrued leave or take an unpaid leave of absence, with rights to reinstatement if the mandate changed. The firefighters sued under federal and state law, claiming the leave option fell short of a reasonable accommodation of their sincerely held religious beliefs. The district court granted summary judgment for SRFR, dismissing the firefighters’ claims, and the Ninth Circuit affirmed.
The Court analyzed the firefighters’ claims under the Title VII framework set forth in the Supreme Court’s 2023 Groff v. DeJoy decision. Although it was not disputed that the firefighters had bona fide religious objections to the vaccine mandate, the Court nonetheless concluded that their claims failed, because SRFR established that allowing exemptions would impose an undue hardship on the department’s operations. Citing unrebutted medical testimony, the Court found that unvaccinated firefighters posed heightened risks of contracting and transmitting COVID-19, and that masking, testing, and social distancing were inadequate substitutes given the realities of firehouse life and emergency response. Operationally, nearly one-quarter of SRFR’s firefighters sought exemptions, creating a risk of widespread absences and outbreaks that could cripple essential emergency services. Financially, accommodating the exemptions threatened the loss of a $400,000 annual contract with the Department of Corrections, increased staffing burdens, and exposure to uninsured liability for COVID-19 transmission claims.
Because these health, operational, and financial costs were substantial in the context of SRFR’s mission, the Court concluded that allowing unvaccinated firefighters to remain in service would have imposed an undue hardship. The firefighters’ leave options therefore satisfied SRFR’s legal obligations, and the Court affirmed summary judgment for the department.
Petersen v. Snohomish Regional Fire and Rescue, No. 24-1044, 2025 WL 2503128 (9th Cir. 2025).