Religious Discrimination Under the ICRA: Courts May Test Sincerity, but Not Religious Truth

1. Introduction

In Andrew Perry v. Dordt University, the Iowa Supreme Court clarified an important boundary in religious-discrimination litigation: courts cannot judge whether a religious belief is true, reasonable, orthodox, or theologically sound, but they may—and, when necessary, must—determine whether the claimant honestly holds it.

Andrew Perry, a former nursing student at Dordt University, alleged that the university violated the Iowa Civil Rights Act (ICRA) by denying his request for a religious exemption from COVID-19 vaccination requirements applicable at its clinical partner facilities. Following a bench trial, the district court rejected his claim because it did not believe that his objection to vaccination was sincerely religious. Instead, it found that parental opposition and threatened withdrawal of educational funding explained his refusal.

The supreme court unanimously affirmed. Its central contribution is not a new definition of religion or approval of a particular vaccination policy. Rather, it explains how courts should evaluate sincerity while respecting religious freedom, and why a supported adverse credibility finding defeats the religious-discrimination claim presented here.

2. Background and Procedural History

The vaccination requirement and Perry’s response

Perry’s nursing program required clinical rotations at outside medical facilities. Dordt itself did not initially impose a campus-wide COVID-19 vaccination requirement. Instead, its clinical partners progressively required vaccination, and by fall 2021 the university informed Perry that all available clinical sites would require it before the spring 2022 rotations.

Several facts became central to the district court’s assessment:

• Initial willingness: Perry trained to administer COVID-19 vaccines in April 2021. In a May 19 email to the nursing department chair, he wrote, “I personally do not have a problem with the vaccine,” and identified his parents’ beliefs and concerns as the main obstacle.
• Financial dependence: His parents paid essentially all his educational and living expenses. His mother threatened to end that support if he received the vaccine.
• Contemplated secret vaccination: Perry discussed obtaining the vaccine without his mother’s knowledge. His father also discussed that possibility with a university official.
• The asserted religious objection: In November, Perry requested an exemption on the ground that his body was a temple of God and that introducing something he regarded as carrying only risk would violate his duty of bodily stewardship.
• Credibility concerns: The district court identified discrepancies between Perry’s deposition and trial testimony, including whether he would have accepted vaccination if his mother approved.

The exemption process and litigation

Dordt requested documentation of a published denominational position opposing vaccination and evidence of a religious exemption previously granted during kindergarten through twelfth grade. It denied Perry’s religious-exemption request after he failed to provide the requested materials. A later medical-exemption request was also denied.

Unable to participate in clinical rotations without vaccination, Perry left Dordt after his junior year and transferred to Palm Beach Atlantic University. He then pursued his ICRA religious-discrimination action.

The district court dismissed the action after a trial on the merits, not at the pleading stage. Perry appealed both that judgment and the refusal to reopen the record for additional damages evidence. Because the supreme court upheld the rejection of liability, it did not reach the damages-evidence issue.

3. Summary of the Opinion

The court’s reasoning proceeded through four principal steps:

1. A student must establish a prima facie case. Under Iowa Code section 216.9 (2022), the student must prove a bona fide religious conflict with an educational requirement, notice to the institution, and a penalty for noncompliance.
2. A bona fide religious objection has two dimensions. The asserted belief must be religious in the claimant’s own understanding and sincerely held.
3. Sincerity is a factual question, subject to strict limits. Courts may assess honesty through testimony, conduct, and surrounding circumstances. They may not evaluate religious truth or demand orthodoxy or flawless observance.
4. The district court’s finding survived appellate review. Substantial evidence supported its conclusion that Perry’s asserted religious objection was not sincere. Because an essential element failed, his claim could not succeed.

The court accepted, for purposes of the appeal, that Perry’s body-as-temple explanation could qualify as religious. It also treated notice and penalty as undisputed. The decision therefore turned on sincerity alone.

Importantly, the court did not decide whether Dordt’s documentation requirements were lawful. It affirmed because Perry failed to prove his own sincere religious objection, independently of those requirements.

4. Legal Reasoning

A. The statutory threshold: an actual religious conflict

The court applied a three-part prima facie framework. Perry had to establish, by a preponderance of the evidence, that:

1. He genuinely believed compliance with the educational requirement would conflict with his religious belief or practice.
2. He informed Dordt of that conflict.
3. He was penalized for failing to comply with the requirement.

The second and third elements were satisfied for purposes of the appeal: Perry communicated his claimed conflict, and his inability to complete clinical rotations prevented completion of his nursing education at Dordt. That the vaccination requirements originated with clinical partners did not eliminate those elements in the court’s analysis.

The first element remained decisive. A religious explanation capable of receiving legal protection does not, by itself, establish that the particular claimant genuinely holds it.

B. Religiousness and sincerity are different inquiries

The court distinguished the character of a belief from the claimant’s honesty in asserting it. Religiousness asks whether the belief functions as religious within the individual’s “own scheme of things.” Sincerity asks whether the individual actually holds that belief.

This distinction allowed the court to avoid defining religion comprehensively. It did not reject the possibility that Christian bodily stewardship could support a religious objection to a vaccine. Instead, it examined whether that explanation genuinely motivated Perry’s objection.

The decision thus concerns the authenticity of a particular claimed conflict, not the validity of Christianity, bodily-stewardship beliefs, or religious vaccine objections generally.

C. Credibility assessment is permitted; theological adjudication is not

The opinion describes sincerity review as requiring a “light touch” or “judicial shyness.” That restraint does not require unquestioning acceptance of every asserted religious objection. It requires keeping the inquiry within its proper evidentiary boundaries.

A court may consider a claimant’s statements, conduct, inconsistencies, and surrounding circumstances. It may not decide:

• Whether the religious teaching is true or false.
• Whether the belief is reasonable, logical, or comprehensible.
• Whether the belief is an essential or correct component of a faith.
• Whether the claimant’s interpretation matches a denomination’s official doctrine.

Agreement with denominational teaching may corroborate sincerity. But disagreement cannot automatically defeat it, and membership in an organized religion is not a prerequisite to protection.

D. Why the evidence supported the finding against Perry

The district court expressly recognized that Perry’s beliefs could have changed between May and November. It simply did not find that a religious change was the likely explanation on this record. The supreme court therefore did not establish that an earlier willingness to comply permanently defeats a later religious objection.

Nor did the opinion establish that financial concerns or family influence necessarily invalidate a religious belief. Its conclusion was narrower: the factfinder reasonably determined that Perry had not proved the sincere religious objection he asserted. Although the district court observed that honoring his parents might have supplied a different religious explanation, Perry had not advanced that theory.

E. Imperfect observance does not equal insincerity

Perry challenged the reliance on vaping and drinking, arguing that it improperly tested his religious performance. The court agreed with the underlying limitation: sincere believers may violate their beliefs, and courts cannot demand perfect compliance.

Nevertheless, conduct remains potentially relevant to credibility. The court read the district court’s decision as resting on the whole evidentiary picture, especially Perry’s statements and financial circumstances, rather than on a rule that unhealthy behavior disqualifies a bodily-stewardship belief.

The court also rejected the contention that conduct unknown to Dordt when it denied the request was necessarily irrelevant. At trial, sincerity required a full factual examination. This reasoning concerned proof of Perry’s underlying belief; it did not establish a general rule validating every institutional decision through subsequently discovered evidence.

F. Appellate deference was central

The supreme court reviewed statutory interpretation for errors at law. It applied a different standard to factual findings: because this damages action was tried at law to the court, those findings were binding if supported by substantial evidence.

The question was therefore not whether another judge could have believed Perry. It was whether a reasonable factfinder could reach the findings actually made. Viewing the record favorably to the judgment and respecting the trial judge’s superior position to assess testimony, the supreme court concluded that the findings were adequately supported.

5. Precedents Cited and Their Influence

A. Appellate review and evidentiary sufficiency

• Boyle v. Alum-Line, Inc., 710 N.W.2d 741 (Iowa 2006), supplied the errors-at-law standard for reviewing ICRA questions. It preserved independent appellate scrutiny of the governing legal rules.
• State v. Fordyce, 940 N.W.2d 419 (Iowa 2020), established that factual findings after a bench trial in an action at law have the effect of a special verdict and bind the appellate court when substantially supported. This principle structured the review of Perry’s sincerity.
• CMT Highway, LLC v. Logan Contractors Supply, Inc., 34 N.W.3d 508 (Iowa 2026), quoting Meyers v. Delaney, 529 N.W.2d 288 (Iowa 1995), defined substantial evidence as evidence a reasonable mind would accept as adequate to reach the findings. The court did not require the evidence to compel only one possible conclusion.
• Crow v. Simpson, 871 N.W.2d 98 (Iowa 2015), quoting Postell v. Am. Fam. Mut. Ins., 823 N.W.2d 35 (Iowa 2012), emphasized that evidence remains substantial even when competing conclusions are possible. These decisions explain why an alternative interpretation favorable to Perry did not require reversal.
• 5th & Walnut Parking LLC v. City of Des Moines, 36 N.W.3d 741 (Iowa 2026), required viewing the evidence in the light most favorable to the trial court’s judgment. State v. Weaver, 608 N.W.2d 797 (Iowa 2000) (en banc), reinforced the trial factfinder’s usual primacy in determining credibility.

B. The prima facie framework

• King v. Iowa C.R. Comm'n, 334 N.W.2d 598 (Iowa 1983), was the central Iowa authority for both the claimant’s burden and the three elements of a religious-discrimination claim. The court applied its framework to an educational requirement.
• Tex. Dep't of Cmty. Affs. v. Burdine, 450 U.S. 248 (1981), appeared through the quotation in the Iowa authority supporting proof of a prima facie case by a preponderance of the evidence. The opinion relied on that threshold burden without needing to resolve later stages of discrimination analysis.
• Murphy v. Edge Mem'l Hosp., 550 F. Supp. 1185 (M.D. Ala. 1982), supplied the formulation quoted in the Iowa precedent: a bona fide religious conflict, notice, and a penalty for noncompliance. Its influence was the structure of the claim rather than a factual analogy to university education.
• Kincannon v. United Airlines, Inc., 168 F.4th 713 (5th Cir. 2026), Williams v. Legacy Health, 174 F.4th 1201 (9th Cir. 2026), and Zarn v. Minn. Dep't of Hum. Servs., 165 F.4th 1143 (8th Cir. 2026), supplied contemporary, analogous Title VII formulations. They supported the framework without converting Perry’s state-law educational claim into a federal employment action.

C. Separating religious character from sincerity

• United States v. Seeger, 380 U.S. 163 (1965), provided the opinion’s conceptual foundation: the belief must be sincerely held and religious within the claimant’s own understanding. It also characterized sincerity as a factual question and prohibited judicial examination of religious truth.
• Patrick v. LeFevre, 745 F.2d 153 (2d Cir. 1984), described this as a two-part inquiry and explained sincerity as good faith in expressing religious belief. Its insistence on a full exposition of facts supported consideration of the complete trial record rather than a superficial impression of what religion should look like.
• EEOC v. United Health Programs of Am., Inc., 213 F. Supp. 3d 377 (E.D.N.Y. 2016), illustrated the difficulty of defining religion for discrimination law. The Iowa court used that difficulty to explain why it would not attempt a universal definition unnecessary to the appeal.
• Barnett v. Inova Health Care Servs., 125 F.4th 465 (4th Cir. 2025), and Littlefield v. Forney Indep. Sch. Dist., 268 F.3d 275 (5th Cir. 2001), supported distinguishing conscientious belief from an insincere assertion. Their role was to confirm the legitimacy of an authenticity inquiry, not to authorize theological evaluation.

D. The limits of judicial scrutiny

• Wright v. Honeywell Int'l, Inc., 148 F.4th 779 (5th Cir. 2025), treated sincerity as factual while requiring a restrained judicial approach. Its quotation from Davis v. Fort Bend County, 765 F.3d 480 (5th Cir. 2014), supplied the “light touch” or “judicial shyness” formulation.
• State v. Amana Soc'y, 109 N.W. 894 (Iowa 1906), supplied a longstanding Iowa prohibition against deciding what should be essential to religious faith. It grounded the opinion’s restraint in state precedent as well as federal authority.
• Thomas v. Rev. Bd. of the Ind. Emp. Sec. Div., 450 U.S. 707 (1981), was especially important. It recognized the delicacy of identifying religious beliefs, rejected demands that beliefs be logical or comprehensible, and protected individual convictions that diverge from organizational doctrine.
• Burwell v. Hobby Lobby Stores, Inc., 573 U.S. 682 (2014), prohibited rejecting a religious belief as mistaken or insubstantial. New Doe Child #1 v. Cong. of the U.S., 891 F.3d 578 (6th Cir. 2018), similarly rejected reasonableness as a judicial test of religious belief.
• Detwiler v. Mid-Columbia Med. Ctr., 172 F.4th 1072 (9th Cir. 2026), supplied the formulation that the asserted belief must be “truly held.” The Iowa court expressly quoted Judge Forrest’s dissent; that passage functioned as persuasive reasoning, not as a representation of the federal majority’s holding.

E. Conduct, orthodoxy, and imperfect observance

• Moussazadeh v. Tex. Dep't of Crim. Just., 703 F.3d 781 (5th Cir. 2012), served several related purposes: sincerity review is a credibility assessment; conduct may inform it; individual beliefs may differ from institutional doctrine; and even sincere practitioners sometimes stray. It supported both scrutiny and restraint.
• Ackerman v. Washington, 16 F.4th 170 (6th Cir. 2021), focused the inquiry on whether the claim is honest. It also supported considering the relationship between beliefs and conduct, using doctrinal alignment as possible corroboration, and filtering out insincere requests.
• Jackson v. Mann, 196 F.3d 316 (2d Cir. 1999), confirmed judicial competence to evaluate sincerity and the relevance of external evidence. It also reinforced that religious protection does not depend on membership in an organized religious body.
• Haight v. Thompson, 763 F.3d 554 (6th Cir. 2014), supported both corroborative use of religious doctrine and rejection of insincere accommodation requests. In this opinion, those propositions remained subject to the prohibition against requiring orthodoxy.
• Grayson v. Schuler, 666 F.3d 450 (7th Cir. 2012), captured two essential safeguards: heretics retain religious rights, and imperfect observance does not extinguish them. Its discussion of “backsliders, penitents, and prodigal sons” directly answered Perry’s concern about an impermissible perfect-performance test.
• Vinning-El v. Evans, 657 F.3d 591 (7th Cir. 2011), confirmed that a personal religious faith receives protection comparable to a faith espoused by an organized group. That principle cautions against equating sincerity with denominational endorsement.

F. Courts need not accept every assertion uncritically

• Cutter v. Wilkinson, 544 U.S. 709 (2005), recognized that prison officials may question the authenticity of religiosity offered to support an accommodation request. The Iowa court used it to reinforce the distinction between questioning religious truth and testing authenticity.
• Harris v. Muhammad, 165 F.4th 1345 (9th Cir. 2026), supplied a hypothetical illustrating why religious protections do not require accommodation of an insincere claim. Its function was illustrative, not to equate Perry’s circumstances with the hypothetical.

Several cited decisions arose in prison litigation rather than educational discrimination. The court drew on them for general principles of sincerity assessment, not to import the distinct statutory frameworks governing prisoners into the ICRA.

The opinion also cited scholarship on defining religion and constitutional restraint, together with historical accounts of Martin Luther and Søren Kierkegaard. Those nonjudicial sources illustrated why sincere faith may coexist with disagreement with religious authorities; they were not independent legal holdings.

6. Questions the Court Did Not Decide

Dordt’s documentation requirements

Perry argued that Dordt acted unlawfully by requesting denominational documentation and earlier vaccination-exemption records, and by denying his request when he did not supply them. The supreme court expressly declined to resolve those arguments.

The district court had disclaimed reliance on compliance with those documentary requirements when making its dispositive credibility finding. Thus, even assuming the requirements were improper, the failure to establish sincerity independently defeated this claim.

The affirmance is therefore not approval of Dordt’s exemption process. Indeed, the opinion’s protection of individual and nonorthodox beliefs cautions against treating denominational endorsement as universally necessary, although the legality of these particular requests remained open.

Other unresolved matters

• The court did not formulate a comprehensive definition of religion.
• It did not decide what accommodation would have been required if Perry had proved sincerity.
• It did not adjudicate vaccine safety, efficacy, or the theological correctness of vaccine objections.
• It did not reach the request to reopen the record for additional damages evidence.

7. Potential Impact

For students and other claimants

The decision confirms that identifying a religious rationale does not conclusively establish a discrimination claim. Contemporaneous communications, testimony, and conduct may be examined to determine whether the asserted conflict is genuine.

At the same time, claimants need not demonstrate theological sophistication, denominational agreement, or faultless observance. A newly developed belief is not automatically disqualified, and this opinion does not establish that mixed practical and religious motivations necessarily defeat sincerity.

For educational institutions

Institutions may contest sincerity in litigation, but should not read this judgment as permission to impose rigid denominational or historical-observance requirements. The legality of Dordt’s documentation policy was specifically left undecided.

The opinion also distinguishes an institution’s original decision from the court’s later determination of an essential claim element. Success on the latter does not establish that every feature of the former was lawful.

For trial and appellate courts

The decision encourages detailed, individualized findings that identify credibility evidence without judging religious doctrine. A court should explain why conduct bears on honesty rather than merely labeling it inconsistent with an idealized believer’s behavior.

On appeal, substantial-evidence review gives well-supported trial findings considerable durability. Legal limits remain independently reviewable, but competing factual interpretations alone will not justify reversal.

For religious-discrimination law generally

The opinion reinforces a balance between protecting unconventional or imperfectly practiced faith and preventing insincere assertions from automatically securing legal protection. Although its binding holding concerns an ICRA educational claim, its reasoning draws on broader religious-liberty jurisprudence and may inform analogous disputes.

8. Complex Concepts Simplified

Prima facie case

The essential starting elements a claimant must prove before the claim can succeed. Here, failure to establish a sincere religious conflict was fatal.

Bona fide religious belief

A genuinely held religious belief, rather than a religious explanation the claimant does not actually believe.

Religiousness versus sincerity

Religiousness concerns the nature of the belief in the individual’s understanding. Sincerity concerns whether the individual honestly holds it.

Preponderance of the evidence

The claimant must show that the required proposition is more likely true than not.

Substantial evidence

Enough evidence for a reasonable factfinder to reach the finding made. Other reasonable interpretations may still exist.

Review for errors at law

Appellate examination of whether the lower court applied the correct legal rules.

Orthodoxy

Conformity with a religious organization’s accepted teachings. Such conformity is not a prerequisite to protected personal belief.

Sincerity versus perfect performance

A person may honestly hold a religious belief while sometimes violating it. Conduct can inform credibility, but imperfection alone does not resolve sincerity.

9. Conclusion

Andrew Perry v. Dordt University affirms that sincere religious belief is a necessary component of the ICRA claim presented here. Courts may test that sincerity through evidence, but cannot judge religious truth, require doctrinal conformity, or insist on flawless observance.

Perry’s claim failed because substantial evidence supported the finding that his asserted religious objection was not genuine. The judgment does not validate Dordt’s documentation requirements or reject religious vaccine objections generally. Its broader significance lies in maintaining the boundary between legitimate credibility assessment and impermissible theological judgment.