On August 21, 2025, Kitsap County received a unanimous defense verdict in Tammy Duryea v. Kitsap County after a three-week jury trial in Kitsap County Superior Court. Kitsap County was represented by Lael Carlson and Kate Cummings of the Kitsap County Prosecutor’s Office. The trial involved a former Kitsap County District Court employee who was terminated in November 2021 for failure to receive a COVID-19 vaccine in accordance with a vaccine mandate implemented by the Kitsap County Superior and District Courts. Plaintiff had requested an exemption from the vaccine mandate on the basis of both religious beliefs and disability. Plaintiff brought claims only under the Washington Law Against Discrimination. Plaintiff’s claims for failure to accommodate a disability and wrongful discharge in violation of public policy were dismissed at summary judgment.

At trial, Plaintiff claimed failure to accommodate her religious beliefs and retaliation. To demonstrate a failure to accommodate religious beliefs, Plaintiff was required to prove that she had a bona fide religious belief that conflicted with her ability to receive the COVID-19 vaccine. During trial, Plaintiff did not articulate any specific tenet or belief that conflicted with her ability to receive the COVID-19 vaccine and instead testified that she had simply prayed about whether to receive the vaccine. In conversations with the jury after trial, jurors indicated they did not doubt the sincerity of Plaintiff’s religious beliefs, but that they had been unable to discern a connection between those beliefs and her inability to receive the vaccine. Plaintiff also claimed retaliation by Plaintiff’s manager, the District Court Presiding Judge, Human Resources, and legal counsel for the District Court.