The Ninth Circuit Court of Appeals has affirmed a jury's decision against the San Francisco Bay Area Rapid Transit District (BART) in a significant employment discrimination case. The court ruled that BART failed to accommodate the religious objections of six former employees regarding a COVID-19 vaccine mandate. This ruling, filed on September 11, 2026, underscores the importance of religious freedom in the workplace and sets a precedent for how employers handle similar situations in the future.
The case, Lewis-Williams v. San Francisco Bay Area Rapid Transit District (docket number 25-740), involved six plaintiffs who claimed that BART did not properly accommodate their sincere religious beliefs against receiving the COVID-19 vaccine. The jury awarded the plaintiffs a total of $7,824,580 in damages, finding that BART had violated Title VII of the Civil Rights Act and the California Fair Employment and Housing Act (FEHA).
Background
The plaintiffs in this case are Tonya Lewis-Williams, Raymond Lockett, Rosalind Parker, Bradford Mitchell, Ryan Rivera, and Szu-Cheng Sun, all of whom were former employees of BART. In October 2021, BART implemented a mandatory COVID-19 vaccination policy, requiring employees to be fully vaccinated by December 13, 2021, unless they qualified for a medical or religious exemption.
To assess requests for religious exemptions, BART's Leave Management Department created forms to gather information about employees' beliefs and the accommodations they sought. However, BART ultimately concluded that it could not accommodate any of the requests without incurring undue hardship. As a result, 73 employees, including the six plaintiffs, lost their jobs either by being denied an exemption or by being told they could not be accommodated.
The Ruling
The Ninth Circuit upheld the jury's verdict, stating that BART did not provide sufficient evidence to prove that accommodating the plaintiffs' religious objections would cause undue hardship. The court noted, "BART did not carry its burden of showing that the employees’ religious objections could not be accommodated without undue hardship." The judges emphasized that BART needed to demonstrate that any alternative to vaccination would pose a significant safety risk, which they failed to do.
Judge Ryan D. Nelson, who authored the opinion, stated that BART's reliance on public health guidance was not enough to justify its actions. The court found that even if the vaccine was the most effective way to prevent COVID-19 transmission, that did not automatically make other preventive measures unreasonable. The court ruled that BART's arguments did not meet the legal threshold for proving undue hardship.
Impact
This ruling has significant implications for employees and employers alike. It reinforces the idea that employers must take religious beliefs seriously and make genuine efforts to accommodate them. The court's decision highlights the need for employers to demonstrate that any refusal to accommodate is based on substantial evidence rather than general safety concerns.
The ruling could set a precedent for similar cases involving vaccine mandates and religious exemptions, particularly as more employers navigate the complexities of workplace safety and individual rights. It serves as a reminder that employees have the right to seek accommodations for their religious beliefs and that employers must carefully consider these requests.
What's Next
BART may seek to appeal the ruling to the U.S. Supreme Court, but details on any potential appeal were not available in the court filing. Additionally, the case has raised questions about the broader implications of vaccine mandates and religious freedoms in the workplace, which may prompt further legal challenges in the future.