The Iowa Supreme Court has unanimously upheld the dismissal of a former Dordt University nursing student’s religious discrimination lawsuit over a COVID-19 vaccination requirement for clinical training.
In an opinion filed Friday, October 23, the court affirmed a Sioux County District Court ruling against Andrew Perry, concluding substantial evidence supported the trial judge’s finding that Perry had not demonstrated a sincerely held religious objection to the vaccine.
The decision leaves the dismissal of Perry’s lawsuit in place. However, the justices did not decide whether Dordt’s requirements for documenting a religious exemption were lawful.
How the Dispute Developed
The case stemmed from vaccination requirements imposed by healthcare facilities where Dordt nursing students completed clinical rotations. According to the opinion, Dordt did not require COVID-19 vaccination across its campus, but its clinical partners adopted requirements affecting students training at their facilities.
By October 2021, Perry was informed that all of Dordt’s clinical partners would require vaccination before spring 2022 clinicals. Those rotations were necessary to complete his nursing education.
Perry requested a religious exemption in November 2021, saying his Christian beliefs required him to treat his body as a temple and avoid a vaccine he considered dangerous.
Dordt requested documentation of his denomination’s published opposition to vaccination and evidence of a previous religious exemption during kindergarten through twelfth grade. The university denied his request after he did not provide those documents. A subsequent medical exemption request was also denied.
Perry left Dordt after his junior year in spring 2022 and transferred to Palm Beach Atlantic University. He brought his religious discrimination claim under the Iowa Civil Rights Act.
Following a trial without a jury, District Court Judge Robert Tiefenthaler dismissed the case, finding Perry’s refusal was driven by parental opposition and the potential loss of financial support rather than the religious objection he asserted.
Attorneys Disputed How Courts Should Examine Beliefs
During September 15 oral arguments, Perry’s attorney, Alan Ostergren, argued that Dordt and the district court had subjected Perry’s religious beliefs to improper scrutiny.
“Sincerity is something that takes a light touch, or, as one court put it, judicial shyness,” Ostergren said.
Ostergren also challenged Dordt’s documentation requirements and argued that evidence obtained after the university denied the exemption should not justify its decision.
Dordt’s attorney, Nicholas McGrath, argued that determining whether someone actually holds an asserted belief is different from judging religious doctrine.
“Sincerity is just a very narrow question of whether the person who is asserting the belief actually holds that belief. There’s no doctrinal interpretation. There’s no evaluation of how central the belief is to the particular religion. It’s just do they believe what they say?” McGrath said.
What the Supreme Court Decided
Writing for the court, Justice David May explained that courts cannot decide whether religious beliefs are true, reasonable, or consistent with a denomination’s teachings. However, they can examine whether a person sincerely holds the belief underlying a discrimination claim.
The justices found sufficient evidence to support the district court’s conclusion in Perry’s case.
That evidence included a May 2021 email in which Perry said he personally did not have a problem with vaccination, discussions about receiving the vaccine without his mother’s knowledge, and evidence that his mother had threatened to withdraw financial support if he received it.
The court also cited differences between Perry’s deposition and trial testimony. Although religious beliefs can change, the district court did not find his explanation credible.
The Supreme Court emphasized that imperfect religious observance does not automatically defeat a discrimination claim. It concluded the trial court’s ruling rested on the broader evidence concerning Perry’s credibility and financial circumstances.
Because Perry failed to establish a sincerely held religious objection, the justices said they did not need to resolve his challenge to Dordt’s documentation requirements. The ruling therefore upholds the dismissal of his individual claim without approving those requirements.
