EEOC Efforts to Protect Religious Freedom at Work
APPLIES TO All Employers |
EFFECTIVE August 22, 2025 |
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Discussion
The Equal Employment Opportunity Commission (EEOC) provided a press release highlighting the enforcement actions it has taken in the 200 days of the Trump Administration to “defend the religious liberty of American workers” in line with Title VII of the Civil Rights Act of 1964 prohibiting religious discrimination in the workplace. Although the press release is not enforcement guidance, it does provide insight into how the EEOC will be approaching claims of religious discrimination. The more significant aspects of the press release are summarized below.
Vaccine Mandates. Citing the more than 10,000 religious accommodation charges received by the EEOC regarding COVID-19 mandates, the EEOC states it has recovered over $55 million for workers impacted by the mandates. The EEOC also states that enforcing Title VII in regard to COVID-19 vaccine mandates under the Biden Administration occurred too slowly. Under the Trump Administration, the EEOC intends to take more aggressive steps to enforce Title VII as applied to COVID-19 vaccine mandates. Examples of aggressive enforcement actions include, but are not limited to, a $1 million settlement and employee reinstatement rights against Mercyhealth for failing to grant employees’ religious accommodations to be exempt from the vaccine mandate; filing a lawsuit against the Mayo Clinic for refusing a security guard’s request for a religious accommodation to its COVID-19 vaccination policy; and settling a claim for failing to provide religious accommodations to the vaccine mandate with two resorts in Las Vegas.
Other Religious Accommodations. The EEOC also filed lawsuits and reached settlement agreements against employers for failing to provide religious accommodations in other aspects for both employees and applicants. The Venetian Resort in Las Vegas was found to have failed to provide religious accommodations to employees of a variety of faiths and retaliated against those employees when they opposed the failure to accommodate. As a result, the Venetian was fined $850,000 and is required per consent decree to: (1) train all employees, managers, and supervisors on employee rights and obligations regarding religious accommodations; (2) retain a third-party, independent monitor to assist with review and revision of its religious accommodations policies and complaint procedures; and (3) have their compliance tracked for 36 months. Other settlements also included similar provisions in the consent decrees.
Combating Antisemitism in Universities and on College Campuses. Columbia University will pay $21 million to settle charges of harassment based on national origin, religion, and/or race. The EEOC cites allegations of antisemitism in particular. The $21 million will be used to create a class claims fund to compensate employees who may have experienced antisemitism on Columbia’s campus. This is in addition to a multi-agency agreement to pay a $200 million fine. Columbia additionally must submit to compliance monitoring and other injunctive relief.
Federal Employee Religious Rights. The EEOC also highlighted actions taken against federal agencies for failing to reasonably accommodate federal employees’ religious beliefs and practices, absent an undue hardship. In Augustine V. v. Department of Veterans Affairs and Andy B. v. Federal Reserve Board of Governors, the agencies were found liable for failing to accommodate a Muslim physician’s request to attend weekly prayer service and for failing to accommodate a Christian police officer’s request for exemption from the COVID-19 vaccine mandate, respectively.
Employers should review their policies and procedures for providing religious accommodations to both employees and applicants. The EEOC’s recent enforcement actions show that violations can result in both costly penalties and ongoing compliance monitoring which can last years.
Action Items
- Read the press release here.
- Review procedures for providing religious accommodations.
- Have appropriate personnel trained on the requirements.
- Consult with legal counsel prior to denying requests for religious accommodations due to undue hardship.
Disclaimer: This document is designed to provide general information and guidance concerning employment-related issues. It is presented with the understanding that ManagEase is not engaged in rendering any legal opinions. If a legal opinion is needed, please contact the services of your own legal adviser. © 2025 ManagEase