UnifySCC v. Cody, 5:22-cv-01019

Santa Clara County implemented a COVID-19 vaccine requirement for employees, with exemptions allowed for religious, medical, or disability reasons.
Exempt employees in "high-risk" jobs could not remain in those positions unvaccinated; they had to seek accommodation or go on unpaid leave, with the County offering transfer options or use of leave banks.
Plaintiffs challenged the County's Risk Tier System and accommodation process, alleging discriminatory treatment of religious exemptions compared to medical/disability exemptions.
The Court previously certified a class of 463 employees who received religious exemptions for high-risk jobs between August 2021 and September 2022.
Further factual development in summary judgment briefing revealed significant variations in how class members were impacted (many never went on leave or sought alternative positions, etc.), prompting reconsideration of the class certification.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the class meets commonality, typicality, and predominance reqs	Uniform County policy injured all class members equally	Individual facts, not uniform experiences, predominate	Class lacks commonality/predominance; decertified
Whether all class members suffered concrete injury (Article III)	Forced vaccination choice = injury for all	Many class members not actually injured	Plaintiffs failed to show injury for all
Whether class-wide adjudication is superior to individual claims	Yes, as common questions predominate	No; claims require mini-trials for individual members	Individual issues overwhelm common ones
Whether UnifySCC (organizational plaintiff) has standing	Concedes standing mooted by change in relief sought	UnifySCC lacks current standing	UnifySCC dismissed for lack of standing

Gen. Tel. Co. of Sw. v. Falcon, 457 U.S. 147 (class certification requirements remain fluid throughout litigation)
Wal-Mart Stores, Inc. v. Dukes, 564 U.S. 338 (commonality under Rule 23 requires same injury)
Spokeo, Inc. v. Robins, 578 U.S. 330 (Article III standing requires concrete, particularized injury)
TransUnion LLC v. Ramirez, 594 U.S. 413 (every class member must have Article III standing)
Amchem Prods., Inc. v. Windsor, 521 U.S. 591 (predominance and superiority under Rule 23(b)(3))
Tyson Foods, Inc. v. Bouaphakeo, 577 U.S. 442 (difference between common and individual questions in class certification)
Groff v. DeJoy, 600 U.S. 447 (interpreting "undue hardship" under Title VII reasonable accommodation)