UPDATES & ANALYSIS

Iowa Supreme Court considers standards for assessing religious exemptions in special argument session in Spirit Lake

by Samuel Province | September 30, 2026

The Court held oral argument in Andrew Perry v. Dordt University in a special session on September 15 at 7:00 PM in Spirit Lake, Iowa.

Question: Under what circumstances may a court reviewing a religious university’s decision to deny a religious exemption under the Iowa Civil Rights Act determine whether a student’s religious beliefs are genuine?

Andrew Perry, a junior at Dordt University studying nursing, asked for a religious exemption from the hospital’s COVID-19 vaccination requirements. Dordt University uses two criteria when handling such requests: whether the student’s denomination has issued a statement opposing vaccination and whether the student previously obtained a K-12 religious exemption. The committee denied his request about two weeks after his submission. Perry filed suit in Sioux County claiming religious discrimination under the Iowa Civil Rights Act, arguing that conditioning recognition of a religious belief on denominational endorsement favors organized faith, thereby discriminating against those who have the same beliefs who lack the same denominational support.

A key factual dispute concerned what the committee knew. About six months before Perry requested the exemption, he sent an unprompted email to the chair of Dordt’s nursing department stating that he had no problem with the vaccine and that the issue was his parents’ beliefs. Dordt states that there is testimony of Perry discussing being vaccinated without his mother’s knowledge so he could remain in the program, that Perry’s mother threatened to cut off financial support he was dependent on, and that he volunteered at a campus clinic administering that vaccine to classmates. The parties disagree about whether any of that information reached the committee. Dordt claims the committee knew of the email and Perry’s discussions about getting vaccinated without his mother’s knowledge, treating that knowledge as a reason to deny the exemption in addition to the criteria, while noting that the denial letter cited only the criteria. Conversely, Perry responds that Dordt did not have the evidence it provided at trial when it made its decision.

Perry transferred to a university in Florida and completed his nursing degree about two years later than he had originally planned. Following a two-day bench trial, the Sioux County District Court concluded that Perry’s religious belief was not genuine and ruled in favor of Dordt.

Perry argues that neither a university nor a court can tell whether a student has a true religious belief since such determination would be unfair. Those students who are supported by their denomination have an advantage, and courts ought to be careful when judging the sincerity of a belief since inconsistent behavior does not prove that the belief is not protected. Dordt replies that the outcome depends on the standard of review, pointing out that Perry had to prove that his belief was sincere, and that the district court’s decision should be maintained if the evidence is sufficient. Dordt states that the court did not decide whether Perry’s belief was genuine, but only whether he had acted on it. Furthermore, Dordt observes that its defense based on Iowa Code section 216.9(2), which protects religious organizations from discrimination claims, was not undermined, even though the district court had not addressed it, and requests that the case be sent back for consideration if the judgment is reversed.

There is also the matter of damages. Following the submission of the evidence, the Florida hospital where Perry had been trained offered him a job. The district court refused to reopen the record in order to admit the evidence, on the grounds that allowing rebuttal would open “Pandora’s box.” Perry contends that the court’s action was based on policy rather than an exercise of discretion, Dordt pointing out that the document was unauthenticated, consisted of hearsay, and was in the end irrelevant.

Dordt asked that the case be sent to the Court of Appeals and decided without oral argument, but the Court kept the case and scheduled it for a public session.

Tags: Iowa Supreme Court 2025-26