Sherry H. Detwiler v. Mid-Columbia Medical Center, et al.

Portland, Oregon, civil rights lawyer represented the Plaintiff on an employment discrimination theory.



Sherry M. Detwiler worked as a Privacy Officer and the Director of Health Information for Defendant-Appellee

Mid-Columbia Medical Center ("MCMC”), a hospital in The Dalles, Oregon, from September 14, 2020, through

December 20, 2021. In her own words, Detwiler is a practicing Christian who believes her body is a temple of the

Holy Spirit and sincerely believes she has a "religious duty to avoid defiling her 'temple' by taking in substances that

the Bible explicitly condemns or which could potentially cause physical harm to her body.”



Some sacrifice of total autonomy is a natural consequence of gainful employment. Even in the best of

times, job obligations may conflict with one's personal preferences. That said, an employment contract does not

terminate the right to exercise one's religion. Federal and state legislatures protect workers from discrimination,

harassment, and harms that rise above mere conflict with an employee's predilections.



In response to the COVID-19 pandemic, employers across the country instituted vaccine and testing requirements to comply with government mandates. These policies have surfaced the tension between individual beliefs and the demands of the workplace. Employees across the country have filed suits challenging these relatively new obligations, and many assert these policies amount to religious discrimination. Courts must tread carefully in evaluating these claims. On the one hand, courts have long safeguarded the rights of religious believers, even when their beliefs are not mainstream, traditional, or even internally6 DETWILER V. MID-COLUMBIA MEDICAL CENTER consistent. On the other hand, legislatures crafted religious discrimination statutes of limited scope, striking a balance between individual entitlements and the reality of the workplace. Accordingly, lower courts must consistently enforce pleading requirements to respect this legislative intent.



This appeal from the dismissal of a religious discrimination claim asks what is sufficient to plead a bona fide religious belief under Title VII and the parallel Oregon state statute. To be sure, assertions of religious belief are entitled to deference, particularly at the pleading stage. However, courts have not uniformly agreed on a standard for evaluating the nature of a belief. Supreme Court guidance in the First Amendment context, considered alongside the requirements of federal pleading, reflects that references to generic religious principles cannot transform a specific secular preference into a basis for a religious discrimination claim. Broad invocations of religion cannot shield employees from any unwanted job obligation. Accordingly, we affirm the trial court's dismissal of this action for failure to state a claim.

Affirmed