The U.S. Court of Appeals for the Fourth Circuit affirmed a hospital's right to terminate an employee who refused COVID-19 vaccination based on religious objections, ruling that accommodating the unvaccinated respiratory therapist would create undue hardship for the medical facility.
In *Charles Miller v. Charleston Area Medical Center, Inc.*, decided Jan. 6, 2026, the appeals court upheld the U.S. District Court for the Southern District of West Virginia's grant of summary judgment in favor of the hospital. Charles Miller, a respiratory therapist, was terminated after refusing to receive the COVID-19 vaccine as required by federal regulations and hospital policy.
Judge Andre Wynn wrote the unanimous opinion for the three-judge panel, joined by Judges Roger King and A. Marvin Quattlebaum Jr. The court applied established Title VII principles requiring employers to reasonably accommodate employees' religious beliefs unless doing so would result in undue hardship.
Miller had requested a religious exemption from the hospital's COVID-19 vaccination requirement but was denied. He subsequently filed suit alleging religious discrimination under Title VII of the Civil Rights Act of 1964, claiming Charleston Area Medical Center failed to provide reasonable religious accommodation.
The Fourth Circuit rejected Miller's arguments, focusing on the unique circumstances of healthcare employment during the pandemic. "Because the district court properly concluded that the hospital could not accommodate an unvaccinated respiratory therapist without incurring a substantial risk to the health of their employees and patients, and that such a risk constituted undue hardship, we affirm," Judge Wynn wrote.
The decision highlights the critical balance between religious freedom in the workplace and public health considerations, particularly in healthcare settings where employees have direct patient contact. Respiratory therapists work closely with patients who often have compromised respiratory systems, making them especially vulnerable to COVID-19 transmission.
Under Title VII, employers must make reasonable efforts to accommodate employees' sincerely held religious beliefs unless such accommodation would impose an undue hardship on business operations. The Supreme Court clarified in recent years that undue hardship means more than minimal burden, but courts have consistently recognized that substantial health and safety risks can constitute such hardship.
The hospital's position was strengthened by federal regulations in place during the pandemic that required healthcare workers to be vaccinated against COVID-19. These regulations, implemented by the Centers for Medicare & Medicaid Services and other federal agencies, made vaccination a condition of employment for healthcare facilities receiving federal funding.
Charleston Area Medical Center argued that allowing an unvaccinated respiratory therapist to continue working would pose significant risks to both patients and other healthcare workers. The hospital likely presented evidence showing the increased transmission risks associated with unvaccinated healthcare workers, particularly those working directly with respiratory patients.
Miller was represented by Robert E. Barnes and Lexis Anderson of Barnes Law in Los Angeles. The hospital was represented by Eric E. Kinder and Chelsea E. Thompson of Spilman Thomas & Battle PLLC in Charleston.
The Fourth Circuit's decision follows a pattern of federal appellate courts generally upholding employer vaccination requirements, particularly in healthcare settings. Courts have consistently found that the health and safety risks posed by unvaccinated healthcare workers constitute undue hardship, especially when working with vulnerable patient populations.
This ruling reinforces that Title VII's religious accommodation requirements do not override legitimate health and safety concerns in the workplace. While employers must engage in good faith efforts to accommodate religious beliefs, they are not required to compromise patient safety or violate federal regulations to do so.
The decision also underscores the heightened scrutiny applied to religious accommodation requests in healthcare settings. Courts recognize that hospitals and medical facilities have heightened duties to protect patient welfare, which can limit the scope of required religious accommodations.
The case was decided as an unpublished opinion, meaning it does not create binding precedent within the Fourth Circuit. However, it provides guidance for similar disputes involving healthcare worker vaccination requirements and religious accommodation claims.
For healthcare employers, the decision provides support for vaccination policies that prioritize patient safety, even when employees object on religious grounds. The ruling suggests that courts will continue to recognize substantial health risks as constituting undue hardship under Title VII.
The case reflects ongoing tensions between individual religious liberty and collective public health measures that emerged prominently during the COVID-19 pandemic. While the immediate crisis phase of the pandemic has passed, the legal principles established in cases like this will likely influence future workplace health and safety policies.
Miller's case was originally filed in the Southern District of West Virginia under case number 2:23-cv-00340 and was decided by District Judge Joseph R. Goodwin. The appeal was submitted to the Fourth Circuit on Dec. 19, 2025, and decided just over two weeks later.