In September 2023, federal trial courts in Wisconsin and Kentucky issued decisions dismissing plaintiffs’ claims related to employers’ COVID-19 vaccination and testing requirements. The decisions (1) interpreted “undue hardship” following the Supreme Court of the United States’ Groff v. DeJoy decision; (2) determined whether an objection to testing was based on “religious beliefs” or merely “isolated moral teaching”; (3) determined whether Title VII of the Civil Rights Act of 1964 requires employers to engage in the interactive process with respect to religious accommodation claims; and (4) determined whether testing and vaccination requirements constitute a “medical examination” under the Americans with Disabilities Act (ADA).
