Tom Luetkemeyer Comments on the Significance of a Trio of EEOC Lawsuits Challenging Employer COVID-19 Vaccine Mandates

Hinshaw partner Tom Luetkemeyer was quoted in a recent Law.com article analyzing the significance of three recent suits filed by the Equal Employment Opportunity Commission (EEOC) challenging healthcare employers’ COVID-19 vaccine mandates and whether the hospital defendants satisfied their accommodation responsibilities under the Americans With Disabilities Act (ADA) and Title VII of the Civil Rights Act of 1964.

The complaints were filed on behalf of workers who were denied religious or disability-related exemptions to the employer’s vaccine requirements. The two Title VII suits come against the backdrop of the U.S. Supreme Court’s 2023 decision in Groff v. DeJoy, which created a greater burden for employers to accommodate religious discrimination claims.

Tom noted that recent public statements by EEOC acting chair Andrea Lucas further confirm the agency’s commitment to challenging religious discrimination in the workplace. He said that these latest lawsuits by the EEOC remind employers to prioritize detailed accommodation processes when responding to vaccine exemption requests.

Tom added that the agency’s actions signal a move away from examining the sincerity of an employee’s beliefs and instead focus on ensuring they receive meaningful consideration of accommodation requests.

“The two religious discrimination cases, one against Silver Cross and one against Mayo, tell us that the employer should be focusing on the accommodation issue and not necessarily on whether the beliefs are sincerely held,” he said. “The EEOC believes the employer has failed to properly accommodate individuals on either the disability or the religious side. The point is that, in each of these cases, the EEOC believed there was a failure to properly accommodate.”

• Law.com: “Do Vaccine Suits Preview What’s Coming From the EEOC?” (August 19, 2025)