IA Supreme Court Affirms Dismissal of Nursing Student’s COVID Vaccine Religious Discrimination Claim

Today, the Iowa Supreme Court unanimously affirmed the dismissal of a former nursing student’s religious discrimination claim against his university, which had denied his request for a religious exemption from a COVID-19 vaccine requirement. Andrew Perry v. Dordt University, No. 25-1608 (Iowa Oct. 23, 2026). Evidence at trial confirmed that it was the student’s parents, not the student, who opposed the vaccine. This evidence was fatal to the student’s claim that his accommodation request was based on his own religious beliefs.

The student, Andrew Perry, is a former undergraduate nursing student at Dordt University in Sioux Center, Iowa. The nursing program required students to complete clinical rotations at partner health care facilities. Beginning in May 2021, one of those facility partners notified Dordt that the COVID-19 vaccine would be mandatory for all students participating in clinical rotations at its facilities.

The day after Dordt’s announcement, Perry’s mother emailed the nursing department chair about what she described as the vaccine’s medical dangers and said she did not want her son to take it. Perry asked his parents about getting vaccinated so he could continue his schooling, but his mother threatened to cut off all financial support if he did. Perry then emailed the department chair: “I personally do not have a problem with the vaccine. The main issue revolves around my parents’ beliefs and concerns.”

Months later, Perry asked Dordt what he would need to claim a religious exemption. Perry’s request asserted that his body is a temple of God and that he could not knowingly put something into it that held only risk. Dordt denied his requested accommodation. Perry eventually left for another nursing program and sued Dordt under the Iowa Civil Rights Act. After a bench trial, the district court dismissed his claim.

To establish a religious accommodation claim, a plaintiff must show they hold a “bona fide religious belief” that conflicts with an employment requirement (or, in this case, an educational requirement). This question—whether a belief is “religious” in nature—is a “difficult and delicate task” for courts. So instead of evaluating whether a particular relief is truly “religious” in nature, courts often resolve this inquiry by focusing on whether the belief is “sincerely held” by the individual. In Perry’s case, the court decided it was not.

Critical to the court’s holding was that Perry admitted that he personally did not have a problem with the vaccine. Instead, he sought an exemption based on the wishes of his parents, not based on his own religious beliefs. The court noted that despite Perry’s claim that his religion required him to believe his body is a “temple of God,” he willingly introduced other substances into his body, including vaping tobacco and alcohol, that contradicted this asserted belief. These facts contributed the court’s finding that Perry’s asserted belief was not “sincerely held.”

Despite this outcome, employers and schools should handle religious accommodation requests carefully. Perry turned on a detailed trial record and a credibility finding that received deference on appeal. Notably, the EEOC has identified religious discrimination as an enforcement priority under the Trump administration.

Nyemaster Goode’s Labor and Employment attorneys are available to consult with you regarding your employees’ or students’ requests for religious accommodations.