The U.S. Court of Appeals for the Seventh Circuit handed a legal victory to the City of Chicago on Tuesday, affirming the dismissal of a lawsuit brought by a group of city employees challenging the enforcement of COVID-19 protocols.
The decision, authored by Circuit Judge Kolar, draws a sharp legal distinction: while employees may be granted religious exemptions from taking a vaccine, that accommodation does not give them the right to ignore administrative reporting requirements.
The plaintiffs, a group comprising sixteen former or current Chicago police officers and one official from the Office of Emergency Management, alleged the city’s policies violated their constitutional and statutory rights. Under the city’s October 2021 directive, employees were required to be vaccinated or undergo regular testing. The policy explicitly allowed for religious exemptions, which the plaintiffs applied for and received.
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Consequently, the legal battle was not about the shot itself. Instead, the plaintiffs sued because they were required to input their vaccination status and weekly COVID-19 test results into an online employee portal. Those who refused to enter the data were placed on non-disciplinary, no-pay status.
In the opinion decided December 2, 2025, the appellate panel rejected the argument that these reporting requirements burden the free exercise of religion.
“One might think this case is about the City’s failure to grant a religious exemption to a vaccine mandate, a situation that can raise serious First Amendment concerns,” Judge Kolar wrote. “It is not.”
The court determined the policy was neutral and generally applicable, noting that the requirement to report status applied to all covered employees regardless of their faith. Because the rules did not target religious practice, the court applied “rational-basis review”—a standard requiring only that the government have a legitimate reason for its regulation.
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The panel found that the city had a clear, rational interest in tracking testing results to maintain workplace safety during a pandemic.
“Without an enforcement mechanism, the City’s Policy would be nothing more than a suggestion,” the court stated, noting that discipline for non-compliance was a logical step to ensure public safety.
The ruling upholds a previous dismissal by the U.S. District Court for the Northern District of Illinois, effectively ending the plaintiffs’ claims under the First Amendment and Title VII.
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