Megan Passarella v. Aspirus, Inc., 108 F.4th 1005

Plaintiffs Megan Passarella and Sandra Dottenwhy, healthcare employees at Aspirus Health in Wisconsin, sought religious exemptions from the employer’s COVID-19 vaccine mandate in late 2021.
Both plaintiffs linked their exemption requests to Christian beliefs, particularly regarding the sanctity of the body as a “temple” and reliance on divine guidance, but also cited safety concerns about the vaccine.
Aspirus denied their requests, deeming them motivated by personal/medical judgment rather than genuine religious conviction, and subsequently terminated their employment.
Plaintiffs sued under Title VII, which prohibits discrimination based on religion and requires reasonable religious accommodations absent undue hardship.
The District Court dismissed the claims at the pleadings stage, finding that the exemption requests were not based on religious beliefs under Title VII.
On appeal, the Seventh Circuit reversed, holding that a request is religious if it is "plausibly based at least in part on some aspect of religious belief or practice."

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether exemption requests were religious under Title VII	Plaintiffs cited Christian beliefs, prayer, body as temple, and conscience as basis for exemption	Requests rooted in personal health/safety beliefs, not genuine religion	Requests that plausibly invoke religious beliefs, even in part, are religious under Title VII
Whether secular motivations negate religious nature	Religious and secular concerns can co-exist in beliefs	Secular motivations override claims as religious	Presence of secular reasons does not negate a religious claim
Standard for evaluating religious accommodation at pleading stage	Need only allege facts plausibly supporting religious basis	Must articulate clear, specific religious belief prohibiting vaccine	Holistic assessment: plausible religious aspect in request suffices to proceed
Appropriateness of dismissal at pleadings	Requests, taken at face value, are religiously motivated	No plausible religious basis given, so dismissal proper	Motion to dismiss improper if some religious basis plausibly alleged

Thomas v. Review Bd. of the Indiana Employment Sec. Div., 450 U.S. 707 (1981) (courts must not dissect or question the articulation or orthodoxy of religious beliefs)
Burwell v. Hobby Lobby Stores, Inc., 573 U.S. 682 (2014) (courts should not assess the reasonableness of asserted religious beliefs)
Frazee v. Illinois Dep't of Emp. Sec., 489 U.S. 829 (1989) (orthodoxy of a claimant’s belief is irrelevant to legal protection)
United States v. Ballard, 322 U.S. 78 (1944) (religious experiences may be sincere even if incomprehensible to others)
United States v. Seeger, 380 U.S. 163 (1965) (recognized religious objection may be partly based on non-religious grounds)
Welsh v. United States, 398 U.S. 333 (1970) (an objection need only be based in part on religion to be protected as religious)
Adeyeye v. Heartland Sweeteners, LLC, 721 F.3d 444 (7th Cir. 2013) (Title VII requires broad and flexible understanding of religious accommodation)
Redmond v. GAF Corp., 574 F.2d 897 (7th Cir. 1978) (Title VII protects all forms of religiously motivated conduct, regardless of eccentricity)