148 F.4th 779
5th Cir.2025Background
- Donald Wright was employed by Honeywell International for fourteen years as a Dock B Operator.
- In 2021, Honeywell implemented a mandatory COVID-19 vaccine policy in line with a federal executive order for federal contractors.
- Wright, a Baptist Christian, applied for a religious exemption based on beliefs related to God-given bodily autonomy and referenced scripture with assistance from his daughter.
- Honeywell denied Wright's exemption request, finding no sincerely held religious belief prohibiting vaccination beyond his stated freedom of choice.
- Wright was suspended and then terminated for failing to comply with the vaccine mandate; he subsequently filed a Title VII lawsuit for religious discrimination.
- The district court granted summary judgment to Honeywell, finding insufficient evidence of a bona fide religious belief or that Honeywell was adequately informed of such belief; Wright appealed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Bona fide religious belief | Wright held a sincere religious belief | Wright's reasons were political or personal, not religious | Evidence sufficient for jury to decide sincerity |
| Communication of religious belief to employer | Wright properly informed Honeywell | Wright failed to sufficiently notify Honeywell | Evidence exists he adequately informed Honeywell |
| Summary judgment appropriateness | Genuine factual disputes require jury review | No genuine issue; summary judgment proper | District court erred; summary judgment reversed |
| Scope of reversal | Remand for discrimination claim only | Affirm district court on all claims | Reversal limited to religious discrimination claim |
Key Cases Cited
- United States v. Seeger, 380 U.S. 163 (1965) (defined "religious belief" broadly to include sincerely held moral and ethical beliefs)
- Welsh v. United States, 398 U.S. 333 (1970) (expanded conscientious objector status to moral, ethical, or religious beliefs held with strength of religious convictions)
- Wisconsin v. Yoder, 406 U.S. 205 (1972) (recognized protection of non-traditional but sincerely held religious beliefs)