Holding: A city's implementation of a COVID-19 vaccine mandate for firefighters was not generally applicable and failed strict scrutiny because it exempted neighboring firefighters while denying religious exemptions, and less restrictive means were available.
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Bacon v. Woodward (No. 22-35611) is a Free Exercise case in 2024. The court held that a city's implementation of a COVID-19 vaccine mandate for firefighters was not generally applicable and failed strict scrutiny because it exempted neighboring firefighters while denying religious exemptions, and less restrictive means were available.