The New Era of Religious Accommodations: Clarifying the Standard for “Sincere Religious Beliefs” and Evaluating Undue Hardship
At a Glance The Second Circuit clarifies an employee’s burden is minimal, but not non-existent, to establish the employee held a sincere religious belief in conflict with an employer’s policy. The EEOC provides a framework for employers in determining whether a proposed accommodation is “reasonable” and what amounts to an undue hardship. Since vaccines became available in response to COVID-19, courts have dealt with an onslaught of litigation involving religious accommodation in the workplace. Most recently, the U.S. Court of Appeals for the Second Circuit weighed in on when an employee’s accommodation request to be exempt from a vaccination requirement amounts to a sincerely held religious belief under Title VII. The case is Gardner-Alfred v. Federal Reserve Bank of New York , 143 F.4th 51 (2d Cir. 2025). The EEOC also recently weighed in with opinions that emphasize that an employer must face a significant hardship before it can show that the religious accommodation reque...