The Ninth Circuit Court of Appeals affirmed a district court's grant of summary judgment in favor of Harbors Home Health & Hospice and several of its executives in an employment dispute involving COVID-19 vaccination policies and religious accommodation claims.
In an unpublished memorandum decision filed Jan. 21, 2026, a three-judge panel unanimously concluded the case was suitable for resolution without oral argument. The decision came in the appeal *Ouida v. Harbors Home Health & Hospice* (9th Cir. 2026), which originated from the U.S. District Court for the Western District of Washington.
Plaintiff Marca Ouida, representing herself pro se throughout the proceedings, brought claims against Harbors Home Health & Hospice and five individual defendants: Chief Executive Officer Darlene Greenawalt, Human Resources Director Melissa Dhooghe, Medical Director Dr. Juliette Erickson, Chief Executive Officer Cynthia Minzey, and former Chief Executive Officer Joel Stephens.
According to court records, Ouida asserted constitutional claims, breach of contract allegations, and violations under Title VII of the Civil Rights Act of 1964. The lawsuit centered on allegations that her former employer failed to accommodate her "religious conscience" when the healthcare company instituted its COVID-19 vaccination policy.
The case reflects the broader legal landscape that emerged during the pandemic as employers, particularly in healthcare settings, implemented vaccination requirements while navigating requests for religious and medical exemptions. Healthcare facilities faced particular scrutiny given their role in patient care and the heightened infection risks in medical environments.
Title VII requires employers to reasonably accommodate employees' sincerely held religious beliefs unless doing so would cause undue hardship to the business. The law has been the subject of extensive litigation during the pandemic as workers challenged employer vaccination mandates on religious grounds.
The district court, presiding under Judge David G. Estudillo, granted summary judgment in favor of all defendants. Summary judgment is appropriate when there are no genuine disputes of material fact and the moving party is entitled to judgment as a matter of law.
The Ninth Circuit panel, consisting of Circuit Judges Richard Paez, Lance Bennett, and Michelle Sung, applied de novo review to the district court's summary judgment ruling. Under this standard, the appeals court reviews the legal conclusions independently without deference to the lower court's decision.
In their brief analysis, the panel cited *Vasquez v. County of Los Angeles*, 349 F.3d 634, 639 (9th Cir. 2003), establishing the framework for their review. The court noted that the disposition was "not appropriate for publication and is not precedent except as provided by Ninth Circuit Rule 36-3."
The unpublished nature of the decision means it cannot be cited as binding precedent in future cases, though it may be referenced under limited circumstances as outlined in circuit rules. This classification suggests the panel viewed the case as a straightforward application of existing law rather than presenting novel legal questions.
The case proceeded through the federal court system over approximately three years, beginning with Ouida's complaint filed in 2023 in the Western District of Washington under case number 3:23-cv-05356-DGE. The appeal was docketed as No. 24-3843.
Harbors Home Health & Hospice operates in the healthcare sector, providing home health and hospice services to patients. Such organizations typically face heightened regulatory scrutiny and safety requirements given their work with vulnerable patient populations.
The individual defendants named in the lawsuit held various executive and administrative roles within the organization, including current and former chief executive officers, human resources leadership, and medical directors. The inclusion of multiple individual defendants is common in employment litigation where plaintiffs allege personal involvement in alleged discriminatory conduct.
Pro se representation, where individuals represent themselves without legal counsel, presents unique challenges in complex federal litigation. Courts often provide additional guidance to pro se litigants, but they must still meet the same procedural and substantive legal standards as represented parties.
The timing of the case reflects the wave of litigation that emerged following widespread implementation of COVID-19 vaccination requirements across various industries. Healthcare employers faced particular pressure to implement such policies given their responsibility to protect both workers and patients.
While the Ninth Circuit's decision provides limited detail about the specific factual circumstances or legal reasoning, the affirmance suggests the appeals court found no reversible error in the district court's conclusion that defendants were entitled to judgment as a matter of law.
The case represents one of numerous disputes that arose during the pandemic as employers and employees navigated competing interests around public health measures, religious freedom, and workplace safety. The healthcare industry, in particular, saw significant litigation as facilities implemented vaccination requirements while addressing accommodation requests.
The affirmance closes this particular chapter in pandemic-related employment litigation, though broader questions about religious accommodation in healthcare settings continue to evolve through ongoing cases and regulatory guidance.