Background
Andrew Perry was a Dordt University nursing student whose clinical-rotation partners required COVID-19 vaccination. Perry sought a religious exemption, asserting that his Christian belief in treating his body as a temple prevented him from accepting a vaccine he considered dangerous. Dordt denied the request after he did not provide requested supporting documentation, and Perry could not complete clinical rotations or finish his nursing education at Dordt.
Perry sued under the Iowa Civil Rights Act (ICRA). After a bench trial, the Sioux County District Court dismissed his claim, finding that his asserted religious objection was not sincerely held. The court found that Perry’s parents—especially his mother—opposed the vaccine and had threatened to end financial support if he received it; Perry was financially dependent on them.
The Court’s Holding
The Iowa Supreme Court affirmed. To establish a prima facie ICRA religious-discrimination claim, Perry had to prove a bona fide religious belief conflicting with the requirement, notice to the school, and a penalty for noncompliance. The parties did not dispute the latter two elements, but Perry failed to prove a sincerely held religious objection.
The court held that sincerity is a factual credibility question that courts may assess through the claimant’s words and conduct, while avoiding judgments about the truth, validity, or reasonableness of religious doctrine. Substantial evidence supported the trial court’s finding that Perry’s refusal was motivated by parental pressure and the risk of losing educational funding, rather than a sincere religious conviction. The court therefore did not reach Perry’s challenges to Dordt’s documentation requirements for exemption requests.
Key Takeaways
- An ICRA claimant alleging religious discrimination must prove that the asserted religious objection is sincerely held.
- Courts may consider testimony, contemporaneous statements, and conduct when evaluating sincerity, but may not judge a belief’s theological validity.
- Because Perry failed to establish sincerity, alleged defects in Dordt’s exemption-review process could not change the result.
Why It Matters
The decision confirms that religious-accommodation claims may require factfinders to distinguish authentic religious objections from objections driven by nonreligious motives. The inquiry must remain focused on the claimant’s honesty, not on whether the court regards the professed belief as logical, orthodox, or persuasive.
For educational institutions, the ruling leaves unresolved whether Dordt’s requested denominational statement and K–12 exemption records were proper. The dispositive point was instead the trial court’s supported finding that Perry lacked a sincere religious objection.