Religious vaccine accommodations
Cara Elizabeth Liberto Dodson v. The Lutheran Village at Millers Grant
In brief
- Where it stands
- Dismissed
Petition denied.
- What it’s about
- Cara Elizabeth Liberto Dodson says The Lutheran Village at Millers Grant violated Title VII by refusing to accommodate her religious objection to its COVID-19 vaccine requirement.
- Who it affects
- The denial ends Dodson’s request for Supreme Court review but does not resolve her underlying Title VII and evidence claims.
Summary: written with AI from the case record.

What it's about
Her petition asks the Supreme Court to review the Fourth Circuit’s decision upholding summary judgment for the employer and the denial of her request to submit medical-expert evidence about undue hardship.
The case concerns a healthcare employee’s request for a religious accommodation to her employer’s COVID-19 vaccine requirement under Title VII.
Question presented
1. Did the United States Court of Appeals for the Fourth Circuit err when it affirmed the judgment of the United States District Court for the District of Maryland which granted the Employer’s motion for summary judgment against a health care Employee who brought a claim of religious discrimination under Title VII against the Employer for failing to make a reasonable accommodation for the Employee’s religious objection to the Employer’s COVID-19 vaccine mandate? 2. Did the United States Court of Appeals for the Fourth Circuit err in affirming the district court’s denial of the Employee’s Rule 56(d) motion for leave to produce an affidavit from a medical expert to substantially dispute Employer’s undue hardship claim that was essential to justify the Employee’s opposition to the Employer’s motion for summary judgment? 3. Did the United States District Court for the District of Maryland err by granting the Employer’s motion for summary judgment against a health care Employee who brought a claim of religious discrimination under Title VII against the Employer for failing to make a reasonable accommodation for the Employee’s religious objection to the Employer’s COVID-19 vaccine mandate? 4. Did the United States District Court for the District of Maryland err in denying the Employee’s Rule 56(d) motion for leave to produce an affidavit from a medical expert to substantially dispute Employer’s undue hardship claim that was essential to justify the Employee’s opposition to the Employer’s motion for summary judgment?
Each side's argument
- Cara Elizabeth Liberto Dodson
- Dodson argued that Lutheran Village failed to accommodate her religious objection and that she should have been allowed to submit expert evidence challenging its undue-hardship claim.
- The Lutheran Village at Millers Grant, Inc.
- Lutheran Village relied on undue hardship to defend its refusal to accommodate Dodson.
Documents
Docket activity
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AI analysis generated: Case Briefing
AI analysis generated: Decision Record
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Sources
Primary materials plus reporting. Best-effort analysis: this explainer relies on a mix of primary materials and trusted secondary sources. Official filings and opinions remain authoritative.