Ninth Circuit Clarifies “Bona Fide Religious Belief” in Religious Discrimination Cases
The U.S. Court of Appeals for the Ninth Circuit recently issued a decision clarifying the “bona fide religious belief” element that plaintiffs must prove for a prima facie religious discrimination claim under Title VII. In Detwiler v. Mid-Columbia Med. Ctr., No. 23-3710, 2025 WL 2700000 (9th Cir. Sept. 23, 2025), the Court held that employees seeking a religious exemption from an employer’s policy must connect their request with a truly religious belief, not just invoke a broad religious tenet to transform a secular personal belief into a bona fide religious belief.
Sherry Detwiler filed federal and state claims of religious discrimination against her employer, Mid-Columbia Medical Center (MCMC), an Oregon hospital. MCMC required its employees to be vaccinated against COVID-19 during the pandemic unless they had an approved exemption. Detwiler stated that her online research revealed that the COVID-19 vaccines contained fetal cell lines, neurotoxins, and carcinogens. Based on her research findings, Detwiler argued that getting the COVID-19 vaccination violated her Christian belief that her body is a “temple,” thus supporting her request for a religious exemption.
MCMC approved Detwiler’s religious exemption request but required her to take weekly COVID-19 antigen testing. Detwiler refused, arguing that based on her online research, antigen testing contained carcinogens. She requested a reasonable accommodation that would enable her to continue working from home and undergo nasal swab testing. In response, MCMC denied her accommodation request and terminated her employment when Detwiler failed to undergo antigen testing.
Detwiler subsequently filed a lawsuit against MCMC, alleging religious discrimination under state and federal law. The U.S. District Court dismissed Detwiler’s complaint for failure to state a prima facie case of religious discrimination, in that she had failed to demonstrate a “bona fide religious belief” that conflicted with a duty of her employment. When an employee requests a reasonable accommodation under Title VII, they must present facts sufficient to exhibit that their accommodation request stems from a bona fide religious belief.
According to the District Court, Detwiler’s beliefs about COVID-19 antigen testing were secular, not religious, and the Ninth Circuit affirmed that decision. Both courts reasoned that Detwiler’s belief was merely personal and secular, as it was based on her interpretation of medical research rather than her religious beliefs. Her characterization of her body as a temple or her identification as a Christian was not enough to establish a bona fide religious exemption.
In its decision, the Ninth Circuit did not explicitly outline a test to determine whether a person’s belief is secular or religious. However, the Court confirmed that an assertion of religious belief alone does not necessarily constitute a bona fide religious belief. Although plaintiffs are not required to establish their belief as consistent, widely held, or rational, they must draw a direct connection between their requested exemption and an actual religious principle. Simply put, a person cannot convert a secular belief into a religious belief simply by claiming it is so. Otherwise, plaintiffs in religious discrimination claims could invoke the words “religious belief” to justify any accommodation, thus allowing their claims to proceed without having made a prima facie case of discrimination.
Frequently Asked Questions (FAQ)
What qualifies as a “bona fide religious belief” under Title VII?
A bona fide religious belief must be sincerely held and rooted in religious doctrine or practice—not personal, philosophical, or scientific reasoning. Courts do not require the belief to be part of an organized religion or widely accepted by the general public. Still, there must be a clear connection between the belief and a recognized principle of a religion. Simply labeling a personal conviction as “religious” is not enough to meet the legal standard.
Can an employee’s objection based on health concerns or scientific research be considered religious?
Generally, no. Objections based on medical research, health risks, or personal interpretations of science are considered secular beliefs—even if the individual also holds religious views. For a religious exemption to be applicable, the objection must stem directly from a religious tenet, rather than from concerns that are primarily scientific or personal in nature.
How can employers evaluate religious accommodation requests without violating employee rights?
Employers should assess whether the request is based on a sincerely held religious belief and whether it conflicts with a job requirement. While they must avoid questioning the validity of the religion itself, they can ask for clarification to determine whether the belief is religious or secular. Legal counsel can help organizations navigate this process while respecting employee rights and maintaining compliance with Title VII.
Legal Guidance for Navigating Religious Discrimination Laws
Understanding the complexities of religious discrimination law can be especially challenging for organizations committed to inclusive and lawful practices. At the California Center for Nonprofit Law, we specialize in helping organizations stay informed about the law while maintaining their mission and values. Whether you’re facing a legal question or want to strengthen your policies, our team is here to support you. Call us today at 949-892-1221, email info@NPOlawyers.com, or complete our contact form to learn how we can assist your organization.