What "sincerely held religious belief" actually means to a federal court

What "sincerely held religious belief" actually means to a federal court

If your religious exemption request was denied, there's a good chance someone in a human resources office decided your beliefs weren't religious enough.

Maybe they told you your church hadn't taken a position. Maybe they pointed out that you'd taken other vaccines before. Maybe they simply wrote back that your request "did not establish a sincerely held religious belief," with no explanation of what would have.

In May 2024, the Eighth Circuit Court of Appeals addressed that question directly, and the answer it gave is worth understanding, because it is not the standard most employers applied.

The case

Five employees of Mayo Clinic, Kiel, Ringhofer, Rubin, Miller, and Ihde, sought religious exemptions from Mayo's COVID-19 vaccination and testing policy. Their stated beliefs were specific: that the vaccines were produced with or tested using cells derived from aborted fetuses, and that their bodies were temples of the Holy Spirit.

Mayo denied three of the requests outright. It granted two, on the condition that those employees submit to weekly testing, which they also declined on religious grounds. All five were terminated.

They sued under Title VII of the Civil Rights Act and the Minnesota Human Rights Act. The federal district court dismissed the case before it reached discovery, on several grounds: two plaintiffs had failed to exhaust their administrative remedies, others had failed to plausibly plead a conflict between their religion and the policy, and the court held the MHRA provided no cause of action at all.

That is where most of these cases end.

What the Eighth Circuit held

It reversed. All of it.

Ringhofer v. Mayo Clinic Ambulance, 102 F.4th 894 (8th Cir. 2024). The panel revived Miller's and Ihde's Title VII claims on the exhaustion issue, and held that Kiel, Ringhofer, and Miller had adequately pleaded a conflict between their religious beliefs and Mayo's policy.

The sentence that matters most is this one:

Beliefs do not have to be uniform across all members of a religion or acceptable, logical, consistent, or comprehensible to others.

Read that again, because it disposes of nearly every reason employers gave for denying these requests.

Your denomination's official position is not the test. Whether your reasoning holds together under cross-examination is not the test. Whether the person reading your request finds it persuasive, or coherent, or familiar, is not the test.

The test is sincerity. Do you actually believe it?

That principle is not new, and it runs through decades of First Amendment and Title VII jurisprudence, but a great many employers in 2021 and 2022 operated as though it were otherwise, and a great many district courts let them.

What this decision does and does not do

Here is where we want to be precise, because precision is the whole point.

Ringhofer is a reversal at the pleading stage. The Eighth Circuit did not hold that these plaintiffs win. It did not award anyone damages or reinstatement. What it held is that the district court was wrong to throw the case out before the plaintiffs had any chance to prove it. The judgment was reversed and the case sent back to the district court for further proceedings.

That is a meaningful result. In this area of law, getting past a motion to dismiss is frequently the entire fight: it is where the overwhelming majority of these cases died. But it is a procedural victory, not a final one, and anyone telling you a case like this is "won" on appeal is telling you something that isn't true.

Why it matters beyond these five plaintiffs

Ringhofer is now the controlling authority in the Eighth Circuit on two questions: what a plaintiff must plead to establish a religious conflict, and whether the Minnesota Human Rights Act reaches failure-to-accommodate claims. It held that it does.

When the Eighth Circuit decided Brokken v. Hennepin County the following year, it relied on Ringhofer for exactly that point.

If your case was dismissed on the reasoning that your beliefs were inconsistent, idiosyncratic, or unsupported by your church, that reasoning is now squarely at odds with binding circuit precedent.

If this describes your situation

The most important thing to know is that these claims have deadlines, and the deadlines are short. A Title VII charge generally must be filed with the EEOC within 300 days of the adverse action in Minnesota. A Minnesota Human Rights Act claim generally must be brought within one year. Those limits are enforced strictly.

If you have a case currently on appeal, or a dismissal you are still within time to appeal, that is the situation where this decision matters most and where the clock is shortest.

We handle these cases at the appellate level, and we will tell you on the first call, at no charge, whether we think you still have one. If you don't, we'll tell you that too.

MKLaw represented the plaintiffs in Ringhofer v. Mayo Clinic Ambulance.

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