Court finds plaintiffs failed to show how vaccine mandate burdened religious beliefs under Free Exercise Clause or Illinois RFRA
Scott Troogstad and over 130 other employees of the City of Chicago lost their appeal this week in the United States Court of Appeals for the Seventh Circuit. In a ruling issued on December 9, 2025, the panel affirmed the dismissal of their claims that the city’s COVID-19 vaccine policy violated their rights under the First Amendment, the Illinois Religious Freedom Restoration Act (IRFRA), and the Fourteenth Amendment’s guarantee of substantive due process.
The decision closes a chapter in a years-long legal battle involving multiple amended complaints, parallel lawsuits, and prior appeals. Although the plaintiffs may continue with a separate Title VII claim in a different case, this ruling confirms that they cannot pursue their religious or constitutional claims further in this lawsuit.
The plaintiffs—employees in Chicago’s Fire, Water, and Transportation Departments—originally sued in October 2021, alleging that the city’s vaccination policy infringed on their religious beliefs and bodily autonomy. They argued that denial of religious exemptions violated the Free Exercise Clause and IRFRA, and that the policy unconstitutionally intruded on their right to refuse medical treatment.
This case has already reached the Seventh Circuit once before. In 2022, the court rejected their request for a preliminary injunction, finding that the plaintiffs had not shown a likelihood of success. After several failed amendments, the district court dismissed their claims again in September 2024, concluding the plaintiffs still had not shown how the vaccine mandate burdened their specific religious practices .
The appeals court agreed. It found that Scott Troogstad’s statement that “the gene-altering aspect of mRNA vaccinations violates his beliefs as a Christian” lacked the specificity required by precedent. The court compared it unfavorably with recent cases where plaintiffs tied their objections directly to doctrinal religious views, such as beliefs about the sanctity of the human body .
The court also dismissed the IRFRA claim on similar grounds, noting that the plaintiffs needed to describe which religious beliefs were burdened by the policy. Without those details, the court said, it could not evaluate whether a substantial burden existed .
On the substantive due process claim, the panel reiterated its previous rulings that vaccination mandates do not infringe on any fundamental constitutional right. The court reaffirmed that rational basis review applies, and found the policy met that low threshold. Other circuits have reached similar conclusions, it noted, citing rulings from the Third and Sixth Circuits .
The court also upheld the lower court’s refusal to allow a fourth amended complaint. Although the plaintiffs submitted a more detailed religious exemption request in a motion to reconsider, they had failed to include that information in any of their three prior complaints. “Inexplicably, that information was not included in any of his complaints,” the court wrote, upholding the trial court’s discretion to deny further amendments .
Case caption: Scott Troogstad, et al. v. City of Chicago, No. 25-1575 (7th Cir. Dec. 9, 2025)
TLDR (Too Long / Didn’t Read Summary)
On December 9, 2025, the Seventh Circuit upheld the dismissal of a lawsuit by over 130 City of Chicago employees who claimed that the city’s COVID-19 vaccine policy violated their rights under the First Amendment, Illinois Religious Freedom Restoration Act (IRFRA), and the Constitution’s guarantee of bodily autonomy. The court found that the plaintiffs did not provide enough detail on how the vaccine conflicted with their religious beliefs. It also ruled that vaccine mandates do not violate constitutional due process. The plaintiffs may still pursue a separate Title VII claim in a different case, but this case is closed.
Legal Commentary
This ruling follows a consistent judicial trend in vaccine mandate litigation. Courts have required plaintiffs to do more than express general discomfort or abstract opposition; they must tie their objections directly to specific religious doctrines or practices. Troogstad’s claim that mRNA vaccines alter genes did not bridge that gap.
The court cited earlier Seventh Circuit cases, Passarella and Bube, which permitted religious exemption claims to move forward. In those cases, the plaintiffs articulated how their belief in the sanctity of the body, as created by God, conflicted with vaccination. The failure to include similar detail—even after multiple opportunities—undermined Troogstad’s position.
On substantive due process, courts across the country have declined to treat vaccine refusal as a fundamental right. That reasoning dates back at least to Jacobson v. Massachusetts (1905), which upheld smallpox vaccine mandates. Here, the court found no reason to revisit its prior ruling in Lukaszcyk v. Cook County, again applying a deferential standard to public health policy.
Lastly, the denial of leave to amend reflects a procedural discipline. Plaintiffs had three chances to allege facts. When they submitted relevant information later in a motion, the court saw that as too late. Courts generally don’t reward delayed diligence, especially after multiple amendments.
Like this article? Share it with others and subscribe to the ReligiousLiberty.TV blog at religiouslibertytv.substack.com for access to breaking news and legal analysis on religious liberty and constitutional cases.
Subscribers receive timely updates, case summaries, and analysis written in plain language.
AI Disclaimer
This article was generated with the assistance of AI and has been reviewed for accuracy against official court documents. It does not constitute legal advice. For guidance on your specific legal situation, consult a licensed attorney.
SEO Tags
Chicago vaccine mandate, religious exemption lawsuit, IRFRA Seventh Circuit, COVID-19 vaccine legal challenge, Troogstad v. City of Chicago
