Chinnery v. Kaiser: The Fourth Circuit Reaffirms the Minimal Pleading Standard for Sincerity in Title VII Religious-Accommodation Claims

Introduction

The unpublished opinion in Naisha Chinnery v. Kaiser Foundation Health Plan of the Mid-Atlantic, No. 24-1697 (4th Cir. June 23, 2025), offers an important clarification on what a plaintiff must allege at the Rule 12(b)(6) stage to pursue a Title VII failure-to-accommodate claim based on religion. Ms. Chinnery, a devout Christian, refused both COVID-19 vaccination and nasal testing, asserting that each violated her faith’s mandate to keep her body “pure” as a “temple of the Holy Spirit.” The district court dismissed her complaint, insisting on more “detailed allegations” about the sincerity of her beliefs. On appeal, the Fourth Circuit vacated that dismissal—relying heavily on its own recent decision in Barnett v. Inova Health Care Services, 125 F.4th 465 (4th Cir. 2025)—and remanded for further proceedings.

Summary of the Judgment

Reviewing de novo, the Fourth Circuit held that the district court applied too stringent a pleading standard. Under Ashcroft v. Iqbal and Twombly, a complaint must be “plausible,” but a plaintiff need not plead her entire prima facie case or provide evidentiary detail. The panel emphasized two points drawn from Barnett:

• At the motion-to-dismiss stage, courts must accept well-pleaded allegations of religious sincerity as true unless they are inherently implausible or conclusory.
• Sincerity is “almost exclusively a credibility question” that is ill-suited to resolution before discovery.

Because Ms. Chinnery alleged that (1) she is a “faithful Christian,” (2) God commanded her to keep her blood and body free from “unpure” substances, and (3) nasal swab testing would be a sinful “foreign assault” on her body, the panel found her complaint facially plausible. Accordingly, it vacated the Rule 12(b)(6) dismissal of her religious-accommodation claim and remanded for further proceedings. (Her separate religious discrimination and retaliation claims were not before the court.)

Analysis

1. Precedents Cited

The court’s reasoning intertwines classic Supreme Court decisions with its own contemporary precedent:

• Ashcroft v. Iqbal, 556 U.S. 662 (2009) – Sets the plausibility standard for Rule 12(b)(6) motions.
• Swierkiewicz v. Sorema, 534 U.S. 506 (2002) – Clarifies that employment-discrimination complaints need not plead a prima facie case.
• Welsh v. United States, 398 U.S. 333 (1970) & United States v. Seeger, 380 U.S. 163 (1965) – Define “religious belief” broadly, encompassing moral and ethical convictions.
• Barnett v. Inova Health Care Services, 125 F.4th 465 (4th Cir. 2025) – Articulates the two-prong test (sincerity; religious nature) and cautions against resolving sincerity at the pleading stage.
• Fourth Circuit procedure cases such as Francis v. Giacomelli, 588 F.3d 186 (4th Cir. 2009) and Wag More Dogs, LLC v. Cozart, 680 F.3d 359 (4th Cir. 2012), which flesh out Rule 12(b)(6) mechanics.

By applying Barnett retroactively, the panel treats it as controlling precedent that lower courts must now follow in analyzing Title VII religious-accommodation pleadings.

2. Legal Reasoning

The court’s logic proceeds in four steps:

1. Pleading Standard. Under Iqbal, a plaintiff must allege facts that nudge a claim from “conceivable to plausible.” She need not prove her claims or offer evidence at the outset.
2. Elements of a Failure-to-Accommodate Claim. While a final merits inquiry asks whether (a) the plaintiff holds a sincerely held religious belief, (b) she notified the employer, and (c) the employer failed to provide reasonable accommodation, those elements need not be exhaustively pleaded.
3. Two-Prong Test from Barnett. A complaint must at least allege (i) sincerity and (ii) religious nature. The sincerity question is fact-intensive and usually requires discovery.
4. Application to Chinnery. The allegations—faithful Christianity, concern for bodily purity, biblical mandate, and refusal of foreign substances—meet both prongs and are anything but “threadbare.” Therefore, dismissal was improper.

3. Impact

The decision, though unpublished, carries persuasive weight and sends a clear signal to district courts in the Fourth Circuit:

• Lower Pleading Bar. Plaintiffs alleging religious-accommodation violations can clear Rule 12(b)(6) by articulating a coherent, personal religious rationale—no theological treatise or corroborating evidence required.
• Discovery Gatekeeping. Employers must contest sincerity later (summary judgment or trial) and cannot use early motions to dismiss to avoid factual inquiry.
• Administrative & HR Policies. Employers in healthcare and other regulated industries should anticipate longer litigation timelines and possibly higher settlement values when religious-based accommodation requests go to discovery.
• Strategic Litigation. Plaintiffs’ counsel will cite Chinnery alongside Barnett to ward off motions to dismiss. Employers may shift strategies toward early settlement or stipulating to sincerity while contesting undue hardship.

Complex Concepts Simplified

• Plausibility Standard: The complaint’s facts must make it believable—not proven—that the defendant broke the law.
• Sincerely Held Belief: The court asks whether the plaintiff is genuinely motivated by faith, not whether her beliefs align with mainstream doctrine.
• Religious in Nature: The belief must concern ultimate questions of faith, morality, or purpose rather than secular preferences.
• Undue Hardship (not yet reached): If the claim survives, the employer can still argue that accommodating the request imposes more than a minimal cost or risk.
• Unpublished Opinion: Not binding precedent, but persuasive and often followed, especially when building on a published case like Barnett.

Conclusion

Chinnery v. Kaiser fortifies a growing doctrinal trend in the Fourth Circuit: sincerity is presumed at the pleading stage. By vacating the dismissal, the court underscores that Rule 12(b)(6) is a blunt instrument unsuited to probing religious authenticity. Whether Ms. Chinnery ultimately prevails will hinge on subsequent phases—particularly whether Kaiser can show undue hardship—but the opinion ensures she will at least have her day in court. Practitioners should heed this renewed emphasis on lenient pleadings, while employers must prepare for more extensive discovery whenever employees raise earnest religious-accommodation requests.