Title VII of the Civil Rights Act of 1964 (as amended in 1972) goes beyond just banning religious discrimination by employers; it requires employers to exempt sincere religious objectors even from generally applicable, neutral employment rules, unless granting the exemption would work an "undue hardship." And, as with American religious exemption regimes more generally, the question is whether the employee has a sincere religious objection, not whether the objection is endorsed by a large religious group, or makes logical sense. Here's how this was Friday's Eighth Circuit decision in Ringhofer v. Mayo Clinic, Ambulance, written by Judge Duane Benton and joined by Judges Ralph Erickson and Jonathan Kobes, applies this statutory rule:
During the Covid-19 pandemic, Mayo required all employees to receive the vaccine. Any employee exempted from vaccination was required to test weekly. On December 3, 2021, Mayo notified all employees that they must comply with the policy by January 3 or be terminated.
The plaintiffs sought religious accommodations for the vaccination requirement, citing their Christian religious beliefs. Mayo denied the accommodations for Shelly Kiel, Kenneth Ringhofer, and Anita Miller, who refused to get the vaccine. It granted vaccination exemptions to Sherry Ihde and Kristin Rubin, but required them to test for Covid-19 weekly, which they refused….
Kiel, Ringhofer, and Miller were denied vaccination accommodations and fired for not taking the vaccine. Each argues that their Christian religious beliefs prevent them from taking the Covid-19 vaccine. Each plaintiff invokes two principles in arguing that their religious beliefs conflict with the vaccine mandate: (1) their "body is a temple," and thus they shall not inject it with impure or unknown substances, and (2) their anti-abortion beliefs, rooted in their religion, prevent them from using a product developed with fetal cell lines…..
At this early stage, when the complaints are read as a whole and the nonmoving party receives the benefit of reasonable inferences, Kiel, Miller, and Ringhofer adequately identify religious views they believe to conflict with taking the Covid-19 vaccine. Each of these three plaintiffs plausibly connect their refusal to receive the vaccine with their religious beliefs:
