Discrimination
Ridings v. PeaceHealth (9th Cir., 2026): Nurse’s Religious Vaccine-Exemption Claim Revived
Updated
In Ridings v. PeaceHealth, the Ninth Circuit reversed the dismissal of a nurse’s religious discrimination suit, holding that the trial court should have considered her religious exemption letter under the incorporation-by-reference doctrine—and that, once considered, her complaint plausibly pleaded a Title VII failure-to-accommodate claim. The court remanded for further proceedings. The opinion was filed for publication.
Background
Karly Ridings, a registered nurse at the PeaceHealth hospital system in Oregon, objected to her employer’s mandatory COVID-19 vaccination policy on religious grounds. In a letter requesting a religious exemption, she wrote that the vaccine derives from fetal cells and that the policy conflicted with her opposition to abortion rooted in her Christian faith.
PeaceHealth responded by placing Ridings, then in her third trimester of pregnancy, on indefinite leave without benefits or pay. She sued, alleging failure to accommodate her religious beliefs under Title VII of the Civil Rights Act of 1964 and Oregon’s parallel anti-discrimination statute.
Ridings’ complaint referenced her exemption request but did not attach the letter or detail its contents. When PeaceHealth moved to dismiss, she attached the letter to her opposition and asked for leave to amend if the pleading was found insufficient.
A magistrate judge recommended denying the motion, but the district court disagreed. It characterized the complaint as a general allegation of religious conflict without identifying a conflicting belief, dismissed the claims without leave to amend, and entered judgment. Neither the magistrate nor the district court discussed the letter.
What the Court Held on Incorporation by Reference
Reviewing the dismissal de novo, the Ninth Circuit held that the district court erred by not considering the letter. Courts ordinarily look only to the complaint and its attachments, but the incorporation-by-reference doctrine lets a court treat a document as part of the complaint when the claim necessarily relies on it and its authenticity is undisputed.
The court reasoned that a Title VII failure-to-accommodate claim requires a plaintiff to show that an employment duty conflicted with a sincere religious belief and that she informed the employer of the belief and conflict. Because the merits of Ridings’ case turned on the religious reasons stated in her letter, and her complaint referenced it while no party contested its authenticity, the court should have considered its contents.
A religious exemption request letter that a failure-to-accommodate claim necessarily relies on is incorporated by reference into the complaint, and a court deciding a motion to dismiss should consider its contents even when the letter is not attached to the pleading.
Whether the Complaint Plausibly Pleaded a Religious Conflict
Considering the letter, the court held that Ridings plausibly alleged a bona fide religious belief that conflicted with the vaccination policy. Claims of religious discrimination need only meet the same plausibility standard as any other request for relief, and courts must be careful not to probe the sincerity or reasonableness of a claimant’s religious convictions.
The court distinguished its recent decision in Detwiler v. Mid-Columbia Medical Center, which requires a plaintiff to plead enough facts showing a belief is religious rather than purely secular. There, the objection to a nasal swab rested on a secular judgment that the swab was physically harmful. Here, Ridings’ letter stated with specificity that her faith bars using products derived from fetal cells made available through abortion, and she supported that objection with scripture.
Because Ridings sufficiently pleaded a religious objection based on the use of fetal cells, the court did not decide whether her other objections stated a claim. It reversed the dismissal and remanded for further proceedings.
What This Means for You
This decision confirms that a religious exemption letter central to a failure-to-accommodate claim may be considered on a motion to dismiss under the incorporation-by-reference doctrine, even when it is not attached to the complaint. It also clarifies that a Title VII religious discrimination claim need only meet the ordinary plausibility standard, and that courts may not weigh the sincerity or reasonableness of a plaintiff’s religious beliefs. The case touches disputes over religious accommodations to workplace vaccination policies.
I write these summaries as general information about developments in California employment law. They are not legal advice and don’t create a mediator–client relationship. For guidance on a specific matter, consult a qualified attorney.