California Court Upholds Unpaid Leave in Teacher’s Religious Vaccine-Exemption Case

Published October 8, 2026 · Court Watch
Decision and opinion publication: October 7, 2026.

California’s Second District Court of Appeal affirmed judgment for Burbank Unified School District in Smith v. Burbank Unified School District (B347288). Christian chemistry teacher Douglas Smith received a religious exemption from COVID-19 vaccination but was placed on unpaid leave.

Smith sought alternatives including testing, masking or remote work. The district argued that classroom safety, staffing and operational disruption made those alternatives an undue hardship. The court held that unpaid leave could qualify as a reasonable accommodation under California’s Fair Employment and Housing Act in these circumstances, and found no triable issue supporting Smith’s discrimination or retaliation claims.

Why it matters: The ruling addresses the difference between granting a religious exemption and providing a workable employment accommodation. Its conclusion depends on this case’s evidence; it does not establish that unpaid leave is appropriate in every religious-accommodation dispute.

Procedural status: Appellate merits decision affirming summary judgment for the district—not a finding of unlawful discrimination. Any further-review proceedings have not been verified.

Sources: California Courts opinion entry · Full published opinion.