New Ruling: Religious Accommodation Duty Met in COVID Dispute

COVID may feel like a thing of the past, but its legal fallout continues. A Pennsylvania school worker’s religious accommodation claim from the pandemic years just failed in court — a reminder that these disputes are still playing out.

Religious Accommodation Claim Centers on COVID Quarantine

Gregory Bingham worked for the Philadelphia School District as a special education classroom assistant beginning in January 2015. When the COVID-19 pandemic hit, the district generally required all school personnel to be vaccinated, but it allowed employees to request exemptions from the requirement for medical or religious purposes.

The district granted Bingham a religious exemption to the vaccination requirement. But when he was exposed to someone at work who tested positive, the district required him to quarantine for 10 days — or eight if he tested negative after five days and had no symptoms.

When he got that news, Bingham announced to his school that he would be working from home. His principal nixed that idea, telling him remote work was not an option and that he was free to seek an alternate accommodation. Bingham did not do so. Instead, he ignored that instruction and worked from home anyway.

No Religious Accommodation for Quarantine or Remote Work

During the 10-day quarantine period, Bingham interviewed for — and accepted — a school counselor position with a different employer.

He also submitted his resignation to the Philadelphia School District and started his new job. Further, he used paid sick leave for that period – even after he began working at the new job.

He eventually sued the district, alleging that its vaccination policies discriminated against him based on religion in violation of Title VII.

A federal district court granted summary judgment against him. On the claim of religious discrimination, it noted that the district exempted him from the vaccination requirement. It also ruled that the district was not required to let Bingham work from home instead of using sick leave while he was quarantined.

Court Finds No Religious Accommodation Request, No Bias

There was no evidence that Bingham asked for a religious accommodation regarding quarantine leave or working from home, it said. As a result, it rejected Bingham’s assertion that the district did not reasonably accommodate his sincerely held religious beliefs.

A federal appeals court upheld the district court’s ruling. It explained that to win, Bingham had to show he was disciplined because he did not comply with the job requirement based on his religious beliefs.

Bingham did not make this required showing, it said. Instead, he voluntarily resigned, and a voluntary resignation is not a disciplinary action, the court explained.

In addition, the appeals court said, the district provided Bingham a reasonable accommodation by exempting him from the vaccination requirement. The district could require him to use his personal time while quarantining, the court added, and there was nothing to suggest that Bingham’s religious beliefs required him to work from home.

Bingham never even asked to work from home as a religious accommodation, it noted.

The district court’s decision was affirmed.

Key Takeaways From This Ruling

Here are your key takeaways from this lawsuit and its result.

• To win on a discrimination claim under Title VII, employees need to show they were subjected to an adverse job action — an action that produces “some harm respecting an identifiable term or condition of employment.” That very clearly did not happen here: Bingham simply left his job to take another one.
• Be acutely aware of the legal concept of “constructive discharge,” which is when conditions at work become so bad – due to harassment, discrimination or retaliation — that a reasonable person would feel they have no choice but to resign. Again, Bingham was nowhere near that territory; he simply chose to leave.
• When the law requires accommodation, it does not require employers to grant a particular accommodation that the employee prefers. Instead, employers satisfy their duty to accommodate by offering an accommodation that is effective. In this case, the school district offered Bingham an accommodation that eliminated the conflict between employment requirements and religious practices. That is all it needed to do, the court explained.

Bingham v. Philadelphia School Dist., No. 24-2998 (3d Cir. 9/12/25).