Rod Jenkins, an emergency room nurse, was employed by Valley Health System from 2019 to 2021. In July 2021, during the pandemic, Valley Health implemented a mandatory COVID-19 vaccination policy. Jenkins requested a religious exemption, submitting an affidavit stating the vaccines were contrary to his religious tenets and practices. When the employer required a specific form, Jenkins filled it out, certifying that it was a tenet of his church not to receive the vaccine. He also wrote that he did not agree with fetal cell therapy and that the mandate violated the First Amendment and the Nuremberg Code. Valley Health denied the request and eventually fired Jenkins for non-compliance. Jenkins sued under Title VII for failure to accommodate and retaliation. The district court granted the employer's motion to dismiss, concluding that Jenkins had failed to link his objection to fetal cell therapy to his religion, treating his statements as merely medical or political opinions rather than religious ones.
The Fourth Circuit reviewed the dismissal de novo, accepting the facts alleged in the complaint as true. The court applied the standard established in Barnett v. Inova Health Care Services and Finn v. Humane Society of the United States, which requires a plaintiff to plead that their belief is (1) an essential part of a religious faith and (2) plausibly connected to the refusal to receive the vaccine. The court emphasized that at the pleading stage, an employee's assertion that a belief is an essential part of a religious faith must be given great weight. The court found that Jenkins clearly met the first requirement by attesting to membership in a recognized religious organization and certifying that non-vaccination was a tenet of his faith. Regarding the second requirement, the court held that Jenkins plausibly connected his refusal to his religious belief by stating, 'I do not agree in fetal cells therapy.' The court noted that objection to vaccines tested on or created using aborted fetal cells is a common religious objection. The court rejected the district court's conclusion that Jenkins's inclusion of non-religious arguments, such as references to the First Amendment or the Nuremberg Code, extinguished the weight of his religious claim. The court clarified that an employee may object on both religious and non-religious grounds, and the presence of secular arguments does not defeat a religious claim. The court also reiterated that an inquiry into sincerity is a credibility assessment that cannot be determined on a motion to dismiss.
The case is remanded to the district court to allow Jenkins's failure-to-accommodate claim to proceed to discovery. The decision clarifies that employers cannot dismiss religious accommodation claims at the pleading stage simply because the employee's explanation includes non-religious arguments or lacks a detailed theological exposition, provided the employee asserts a common religious objection like the use of fetal cell lines. The ruling reinforces that the sincerity of a belief is generally a factual question for later stages of litigation, not a basis for dismissal on a motion to dismiss.
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