The matter was investigated by the EEOC's Phoenix District Office and focused on the company's handling of employee requests for religious accommodation during the COVID shot workplace mandate.1

The EEOC did not file a public complaint, and the company's identity was not disclosed as part of the resolution. The matter was resolved during the investigative phase rather than through litigation.2

Employees Denied Accommodations

The EEOC examined whether employees who sought religious exemptions from the company's COVID shot mandate were denied accommodation and subjected to adverse employment action. Certain employees were terminated or disciplined after requesting exemptions, while others were denied accommodation without individualized review of their requests.3 4

The agency's inquiry focused on whether the employer applied a process that functioned as a categorical denial of religious exemption requests, rather than conducting individualized assessments of accommodation requests under Title VII, which the EEOC treated as inconsistent with federal accommodation requirements.5

Title VII Governs Religious Accommodation

The investigation arises under Title VII of the Civil Rights Act of 1964, which prohibits employment discrimination based on religion and requires employers to provide reasonable accommodation for sincerely held religious beliefs, practices, or observances.6 Under the statute, an employer must accommodate an employee's religious practice unless doing so would impose an undue hardship on the conduct of the employer's business. The US Supreme Court has clarified that undue hardship requires a showing of substantial increased costs or operational burden, and not just minimal inconvenience.7

In the context of COVID workplace policies, federal guidance states that employers may require the controversial COVID shots, but they must evaluate religious accommodation requests individually and consider reasonable alternatives.8 Denying religious exemption requests without individualized review violates Title VII. Adverse action following denial of accommodation, absent undue hardship, constitutes religious discrimination.9 10

According to EEOC chairperson Andrea Lucas:

There was no pandemic exception to workers' civil rights and liberties… the EEOC is focused on accountability and delivering results for American workers.11