Background
Karly Ridings, a registered nurse for Oregon hospital system PeaceHealth, sought a religious exemption from its mandatory COVID-19 vaccination policy. Her written request asserted two grounds: concerns that vaccination could harm her body and unborn child, and a Christian religious objection to using vaccines derived from fetal cells associated with abortion. She proposed alternatives such as reassignment to non-patient care or additional masking, but PeaceHealth instead placed her on indefinite unpaid leave without benefits.
Ridings sued under Title VII and Oregon’s parallel antidiscrimination law, alleging failure to accommodate her religious beliefs. Her complaint referenced but did not attach or describe in detail her exemption letter. After she attached the letter to her opposition to PeaceHealth’s Rule 12(b)(6) motion and requested leave to amend if necessary, the district court dismissed the claims without granting leave to amend, reasoning that the complaint alleged only a generalized religious conflict.
The Court’s Holding
The Ninth Circuit reversed. It held that the district court should have considered Ridings’s exemption letter under the incorporation-by-reference doctrine because the complaint referenced the letter, its authenticity was undisputed, and the failure-to-accommodate claims necessarily depended on what Ridings told PeaceHealth about her religious belief and its conflict with the vaccination requirement.
Considering the letter, the panel held that Ridings plausibly alleged a bona fide religious belief conflicting with an employment requirement. Her specific assertion that her Christian faith prohibited using products derived from fetal cells supplied the required nexus between religion and her objection, rather than merely presenting a secular medical concern dressed in religious terms. The court did not decide whether her separate body-as-a-temple objection independently stated a claim. It also concluded, alternatively, that entering judgment without allowing amendment was an abuse of discretion, and remanded for further proceedings.
Key Takeaways
- A court deciding a motion to dismiss may consider an undisputed document referenced in the complaint when the plaintiff’s claim necessarily relies on that document.
- A specific faith-based objection to using vaccines connected to fetal cells plausibly alleges a religious conflict under Title VII at the pleading stage.
- The decision addresses pleading sufficiency, not whether PeaceHealth ultimately violated the law or could establish an undue-hardship defense.
Why It Matters
The opinion clarifies that an employee’s actual accommodation request may be central to evaluating a religious-accommodation claim even when it was not attached to the complaint. It also distinguishes a specifically pleaded religious objection from a personal or medical judgment supported only by a generalized religious principle.
For employers and practitioners, the decision underscores the importance of the reasons communicated in an accommodation request and confirms that courts ordinarily may not assess whether a claimant’s religious convictions are reasonable or universally shared within the claimant’s faith.