Atlanta Employment Attorneys Blog
Employers must reasonably accommodate employees’ sincerely held religious beliefs unless doing so would impose an undue hardship. But what happens when an employee claims that a workplace requirement conflicts with religious beliefs, yet the evidence does not establish an actual conflict?
A new decision from the U.S. Court of Appeals for the Eleventh Circuit addresses that question and provides useful guidance for employers, employees, and employment litigators.
On October 20, 2026, the Eleventh Circuit affirmed summary judgment for an employer in Holland v. 3M Company, No. 25-13734, concluding that the employee failed to establish that her religious beliefs actually conflicted with the company’s COVID-19 vaccination policy.
Although the decision is unpublished and therefore not binding precedent, it illustrates an important threshold requirement in religious-accommodation litigation: an employee must establish a genuine conflict between a sincerely held religious belief and an employment requirement before the employer must demonstrate that accommodation would impose an undue hardship. Justia Law
What Happened?
Julie Holland worked in the Health Care Business Group of 3M, where her responsibilities required regular visits to major hospital systems.
During the COVID-19 pandemic, the company adopted a vaccination requirement for employees in healthcare-related positions who visited facilities subject to the federal healthcare-worker vaccination mandate.
Holland requested an exemption, explaining that her Christian beliefs prohibited her from receiving a COVID-19 vaccine. The company denied her request and ultimately terminated her employment when she refused to comply.
Holland sued under Title VII, alleging religious discrimination.
During discovery, however, her deposition testimony identified two specific religious objections that became central to the litigation.
First, she testified that she opposed mRNA vaccines because she believed they could alter her DNA, which she considered part of God’s design. Second, she maintained that mandatory medical interventions violated her God-given free will.
The employer argued that neither objection actually conflicted with its policy.
Its vaccination requirement permitted employees to receive a non-mRNA vaccine, including the Johnson & Johnson vaccine. Additionally, Holland acknowledged during her deposition that she would not have a religious objection to a mandatory influenza vaccination, even though she personally opposed receiving that vaccine.
The district court granted summary judgment for the employer, and the Eleventh Circuit affirmed. Justia Law
Why the Eleventh Circuit Rejected the Claim
Title VII requires covered employers to reasonably accommodate sincerely held religious beliefs, practices, and observances that conflict with workplace requirements, absent undue hardship.
But the employee must first establish that such a conflict exists.
In Holland, the appellate court focused on the employee’s own sworn testimony.
The court concluded that her objection to mRNA vaccines did not establish a conflict because the employer’s policy allowed a non-mRNA alternative. Similarly, her testimony concerning mandatory medical interventions undermined her asserted religious objection because she acknowledged that a mandatory influenza vaccination would not violate her religious beliefs.
The court emphasized that a plaintiff cannot rely selectively on favorable portions of deposition testimony while disregarding other sworn statements that undermine the claim.
Importantly, the court did not determine whether the employer could have accommodated Holland without undue hardship. Because she failed to establish the threshold conflict, the court concluded that it was unnecessary to address that issue. Justia Law
What About the Supreme Court’s Heightened Undue-Hardship Standard?
The decision should not be interpreted as weakening employers’ religious-accommodation obligations.
In Groff v. DeJoy, 600 U.S. 447 (2023), the Supreme Court of the United States clarified that employers cannot establish undue hardship merely by demonstrating that an accommodation would impose more than a minimal cost.
Instead, an employer must demonstrate a substantial burden in the overall context of its business, considering the accommodation’s practical impact and the nature, size, and operating costs of the employer.
That remains the governing standard when an employee establishes a qualifying religious conflict and the employer asserts undue hardship.
Holland addresses an earlier question: whether the employee established a conflict requiring accommodation in the first place. Supreme Court
Five Practical Takeaways
- Identify the actual religious conflict. Employers should determine which specific workplace requirement conflicts with an employee’s religious beliefs rather than assuming every religious objection necessarily requires an exemption from the entire policy.
- Consider alternatives that eliminate the conflict. An employer may be able to satisfy a workplace requirement through an alternative that does not interfere with the employee’s identified religious beliefs.
- Document accommodation requests carefully. Employers should record the employee’s explanation, the applicable workplace requirement, available alternatives, and the reasons for the accommodation decision.
- Employees should clearly explain their religious objections. Employees requesting accommodations should identify how their sincerely held beliefs conflict with the particular employment requirement. Religious beliefs need not conform to traditional religious doctrines, but the asserted conflict must be supported by the evidence.
- Do not confuse the threshold inquiry with undue hardship. If a genuine religious conflict exists, employers must still evaluate reasonable accommodations under the demanding standard established in Groff.
The Bottom Line
Holland reinforces an important distinction in religious-accommodation litigation.
Title VII protects employees against workplace requirements that conflict with sincerely held religious beliefs, but it does not automatically require employers to eliminate every requirement to which an employee raises a religious objection.
For Georgia employers and employees, the decision demonstrates the importance of clearly identifying the asserted religious conflict, considering available alternatives, and maintaining accurate documentation throughout the accommodation process.