The U.S. Court of Appeals for the Seventh Circuit affirmed a district court's dismissal of religious discrimination claims brought by three Illinois school employees who refused both COVID-19 vaccination and weekly testing requirements during the pandemic. The court issued its decision Feb. 13, 2026, in *Latosha Bowlin v. Board of Directors, Judah Christian School* (7th Cir. 2026).

The case involves Latosha Bowlin, Nicole Potthast, and Amanda K. Humphreys, who worked at different Illinois grade schools during the COVID-19 pandemic. When Illinois Governor J.B. Pritzker issued an executive order requiring all school employees to either receive COVID-19 vaccination or undergo weekly testing, the three employees refused vaccination based on their religious beliefs.

The schools initially offered weekly testing as a religious accommodation, but the plaintiffs rejected this option as well, claiming the testing also violated their moral consciences. Following their refusal of both alternatives, the employees were either placed on unpaid leave or terminated, consistent with the governor's executive order and joint guidance from the Illinois Department of Public Health and the State Board of Education.

The employees subsequently filed suit in the U.S. District Court for the Central District of Illinois, alleging violations of Title VII of the Civil Rights Act of 1964, the Emergency Use Authorization Act, and the Illinois Health Care Right of Conscience Act. They claimed their employers failed to provide reasonable religious accommodations and discriminated against them based on their religious beliefs.

District Judge Colleen R. Lawless granted the defendants' motion to dismiss the Title VII claim, finding that the plaintiffs had failed to adequately identify a specific religious belief that the testing requirement violated. The district court also dismissed the Emergency Use Authorization Act claim and declined to exercise supplemental jurisdiction over the state law claims.

On appeal to the Seventh Circuit, the plaintiffs contested only the dismissal of their Title VII claim. For the first time on appeal, they also argued that the defendants' actions violated the Illinois Public Health Code. The three-judge panel, consisting of Circuit Judges Frank Easterbrook, Michael Kirsch, and Doris Lee, heard oral arguments on May 24, 2024.

Circuit Judge Lee authored the opinion affirming the district court's decision. The Seventh Circuit's ruling represents another instance where federal courts have generally upheld employer COVID-19 health and safety requirements, even when employees claim religious objections.

The case illustrates the ongoing legal tensions between public health measures and religious accommodation requirements that emerged during the pandemic. Under Title VII, employers must provide reasonable accommodations for employees' sincerely held religious beliefs unless doing so would cause undue hardship to the business.

However, courts have consistently held that employers are not required to accommodate religious objections when doing so would conflict with public health and safety requirements. The Equal Employment Opportunity Commission has noted that compliance with federal, state, or local public health requirements generally constitutes a legitimate business justification that can override accommodation requests.

The plaintiffs' argument that weekly testing violated their religious beliefs presented a more complex accommodation challenge than typical vaccination objection cases. Most religious accommodation disputes during the pandemic involved employees who sought testing as an alternative to vaccination, rather than objecting to both requirements.

The Seventh Circuit's decision adds to a growing body of case law addressing COVID-19-related religious accommodation claims. Federal appeals courts have generally been skeptical of broad religious objections to pandemic safety measures, particularly in educational settings where protecting student and staff health has been deemed a compelling government interest.

The ruling also reflects the courts' reluctance to second-guess public health authorities' determinations about necessary safety measures during health emergencies. The Illinois requirements were based on guidance from state health officials and were designed to maintain safe learning environments during the pandemic.

For employers, the decision reinforces that offering alternative accommodations—such as testing in lieu of vaccination—can satisfy Title VII requirements, even if employees object to those alternatives on religious grounds. The case suggests that employers are not required to exempt employees entirely from health and safety requirements when reasonable alternatives are available.

The plaintiffs have not indicated whether they plan to seek further review from the Supreme Court. The high court has generally declined to hear COVID-19 religious accommodation cases during the pandemic, allowing lower court decisions to stand.

The case underscores the continuing legal implications of pandemic-era employment policies and the ongoing challenge of balancing religious freedom claims with public health requirements in institutional settings.