The Ninth Circuit Court of Appeals reversed the dismissal of a religious discrimination lawsuit filed against PeaceHealth by a registered nurse who was placed on indefinite unpaid leave for refusing the COVID-19 shot.1
The Court of Appeals ruled that the district court was required to read the nurse’s written religious exemption letter before concluding her complaint failed to identify a protected religious belief. Karly Ridings was eight months pregnant and working at PeaceHealth in Oregon when the state’s governor issued an order in August 2021 requiring all healthcare workers to receive the COVID shot or lose their jobs.2 Her exemption request was grounded in her Christian faith and in her opposition to receiving a shot whose development involved cells taken from aborted children.3
Ridings described her objection in a written exemption request to PeaceHealth,
Though the aborted fetal cells used to create vaccinations in the 1970s and 1980s may be far removed from today’s vaccine, they still originate from those aborted children. The practice of using an aborted child’s body for science against his will violates my religious conscience.4
She cited Jeremiah 1:5 in the letter, “Before I formed you in the womb I knew you, and before you were born I consecrated you,” and offered to transfer to a non-patient care role or to wear a mask.5 PeaceHealth placed her on indefinite unpaid leave with no income and no health insurance.6
She filed suit under Title VII of the Civil Rights Act of 19647 and Oregon’s anti-discrimination statute,8 alleging the hospital had failed to reasonably accommodate her religious beliefs. Her complaint referenced the exemption letter she had submitted to PeaceHealth but did not attach it to the pleading.9
The District Court Dismisses
The magistrate judge assigned to the case recommended that PeaceHealth’s motion to dismiss be denied. The district court overruled the recommendation, dismissed the case, and described the complaint as “a general allegation of religious conflict without identifying a conflicting belief.” The court’s order never mentioned the religious vaccine exemption letter.10
Under a doctrine called incorporation by reference, courts deciding a motion to dismiss are required to treat as part of the complaint any document the complaint references that is central to the plaintiff’s claims, even if the plaintiff did not attach it. The religious exemption letter was what Ridings’s case rested on, and therefore, the district court was obligated to read it.11
The Ninth Circuit Reverses
The Ninth Circuit reversed the dismissal and held that the district court also abused its discretion when it denied Ridings leave to amend her complaint.12
Writing for the panel, Judge Kenneth Lee rejected PeaceHealth’s argument that Ridings had not pleaded a sufficiently religious belief. The Ninth Circuit’s standard, from Detwiler v. Mid-Columbia Medical Center, requires a plaintiff to show only that her belief is “religious rather than purely secular” and that there is “any nexus between religion and her viewpoint.”13
In Detwiler, the plaintiff had framed her objection as religious but the substance was medical, a concern that a nasal swab would cause physical harm. Ridings’s objection was different as it was purely religious in nature. Her letter drew the connection from Scripture, through the church’s opposition to the taking of unborn life, to the aborted fetal cells used in developing the shot she was ordered to receive.14
The case is not over and PeaceHealth can still raise undue hardship on remand, the employer’s affirmative defense under Title VII that no reasonable accommodation was possible without undue cost or disruption to the hospital.15
The case is now sent back to the district court, where a nurse eight months pregnant who quoted Scripture to explain why receiving the COVID shot would violate her conscience and sincerely held religious beliefs will have her letter before a judge who is required to consider it.16
Judge Lee wrote:
Judges may wear robes, but we are not men and women of cloth who can opine on religious convictions.17
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Click here to view References:1 Ridings v. PeaceHealth, No. 24-7282 (9th Cir. Sept. 24, 2026).
2 Ibid.
3 Ibid.
4 Ibid.
5 Ibid.
6 Ibid.
7 Title VII of the Civil Rights Act of 1964. 42 U.S.C. § 2000e et seq.
8 Or. Rev. Stat. § 659A.030.
9 Ridings v. PeaceHealth, No. 24-7282 (9th Cir. Sept. 24, 2026).
10 Ibid.
11 Ibid.
12 Ibid.
13 Detwiler v. Mid-Columbia Med. Ctr., 156 F.4th 886 (9th Cir. 2025).
14 Ridings v. PeaceHealth, No. 24-7282 (9th Cir. Sept. 24, 2026).
15 Ibid.
16 Ibid.
