Sixth Circuit Reverses Dismissal in Religious Accommodation Case

Mixed Religious and Medical Objections to COVID Testing Protected Under Title VII

In a significant ruling for religious accommodation jurisprudence, the U.S. Court of Appeals for the Sixth Circuit has reversed the dismissal of an employee's Title VII claim challenging a COVID-19 testing requirement. In Prida v. Option Care Enterprises, Inc. (No. 23-3936, Feb. 11, 2025), the court held that objections to medical procedures that combine religious and scientific concerns may still qualify for Title VII protection at the pleading stage. The decision is here.

Leah Prida worked at Option Care for about 25 years before being terminated in March 2022 for refusing to comply with the company's weekly COVID-19 testing requirement. While Option Care granted Prida a religious exemption from vaccination, it denied her request for accommodation from testing. Prida objected to the testing based on her belief that her body is "God's temple" and concerns about Ethylene Oxide, a carcinogen used in test swabs.

The district court dismissed Prida's claims, finding that her objections were "largely secular" rather than religious. However, the Sixth Circuit, applying its recent precedents in Lucky v. Landmark Medical, determined that Prida had sufficiently alleged her refusal was a part of her religious beliefs.

"Where a plaintiff pleads both religious and secular concerns, particularized allegations of religious beliefs in the complaint are sufficient at the motion to dismiss stage," wrote Circuit Judge Jane B. Stranch for the unanimous panel.

The court emphasized that Prida consistently cited scripture in her communications with her employer and explicitly stated she "strongly believe[d] that vaccines and/or testing violate [God's] requirements set forth in the Bible."

The decision reinforces that employers must consider accommodation requests that involve both religious and scientific objections. The mere presence of scientific or medical concerns does not automatically negate the religious nature of an employee's objections at the pleading stage.

The court also reversed the dismissal of Prida's retaliation claim, finding she had plausibly alleged protected activity through her affidavit that referenced Title VII and her right to employment without discrimination.

The case has been remanded for further proceedings consistent with the opinion.