Sherry Detwiler worked for the Mid-Columbia Medical Center in Oregon (MCMC). Detwiler is a Christian who believes her body is a temple of the Holy Spirit, and that she has a duty to avoid defiling her ‘temple’ with substances that the Bible explicitly condemns or which could potentially harm her.
Detwiler sought a religious exemption from MCMC’s policy requiring healthcare workers to be vaccinated against COVID-19, absent an approved exemption. Detwiler, relying on sources she found online, believed that COVID-19 vaccines were created from fetal cell lines and contained potentially harmful substances. She informed MCMC that her religious beliefs against abortion and the use of harmful substances conflicted with the vaccine requirement.
MCMC approved Detwiler’s request for a religious exemption from vaccination. As part of that accommodation, MCMC required Detwiler to wear personal protective equipment while in the office and to submit to weekly antigen testing for COVID-19 through a nasal swab. Detwiler informed MCMC that she believed that nasal swabs contained a carcinogenic substance and reasserted her religious beliefs.
Detwiler proposed that MCMC allow her either to submit to saliva testing for COVID-19 or to work remotely full-time. MCMC’s Chief Human Resources Officer (CHRO) responded that MCMC had granted her request for an exemption from the vaccine requirement, but denied her requested accommodations of saliva testing or full-time remote work. CHRO advised her that saliva testing would be impractical due to the delay for test results. In addition, MCMC might ask Detwiler to appear for same-day, in-person work because of dissatisfaction with Detwiler’s work during her remote work periods. MCMC placed Detwiler on unpaid leave until she complied with the vaccine mandate, the terms of her approved religious exemption, or accepted reassignment. Detwiler chose none of those options, and MCMC terminated her employment.
Detwiler sued MCMC for religious discrimination in violation of Title VII of the Civil Rights Act of 1964. MCMC filed a motion to dismiss the case for failure to state a claim. MCMC argued Detwiler’s objection to antigen testing stemmed from her secular, medical judgment rather than a bona fide religious belief. The District Court dismissed the complaint, accepting Detwiler’s bona fide religious beliefs but noting that Detwiler’s specific determination of what is harmful was not premised on her religion. Detwiler appealed.
The U.S. Court of Appeals for the Ninth Circuit opined that it had not yet endorsed a test for determining the nature of a religious belief underlying a Title VII claim. The Court ultimately held that an employee seeking a religious exemption must plead a clear connection between her faith and the specific belief that conflicts with her work requirement.
The Court emphasized that an employee does not need to show that their belief is consistent, rational, or widely shared, but it must demonstrate that the requested accommodation flows from a truly religious principle rather than a personal or secular concern. The panel rejected the notion that generic references to broad religious tenets, such as treating one’s body as a temple, can automatically transform a secular preference into a religious belief. The Court reasoned that allowing such assertions would permit employees to bypass workplace requirements by reciting “magic words.” The Court concluded that judges must verify whether the asserted belief is religious in nature, as opposed to merely secular, but may not question the sincerity or reasonableness of the belief.
Applying that standard, the Court found that Detwiler’s complaint was not sufficient. Although the Court accepted her general Christian conviction that her body is a temple, the Court determined that her actual objection—the belief that antigen test swabs were carcinogenic—rested on her personal interpretation of medical research. Because her belief arose from a secular judgment rather than a religious doctrine, the Court ruled it was not protected under Title VII. The Court stressed that Detwiler had no religious conflict with the testing policy apart from her secular opinion about chemicals she believed to be in the swab materials. The Court warned that adopting Detwiler’s proposed lenient approach would create an unmanageable expansion of religious accommodation claims and force employers and courts to treat ordinary personal preferences as matters of faith.
Detwiler v. Mid-Columbia Med. Ctr., 2025 U.S. App. LEXIS 24567 (9th Cir. 2025).