UPDATES & ANALYSIS

Iowa Supreme Court rules that courts may decide whether a religious belief is sincerely held under the Iowa Civil Rights Act.

by Samuel Province | November 11, 2026

In its unanimous October 23, 2026, opinion in Perry v. Dordt University, the Iowa Supreme Court affirmed the dismissal of a former nursing student’s religious discrimination claim under the Iowa Civil Rights Act (ICRA). On September 15, the case was submitted on appeal from the Sioux County District Court. The Court considered whether a court can examine the sincerity of a plaintiff’s religious belief, holding that a court may, if it only asks whether the belief is honestly held and not its validity.

Andrew Perry, a nursing student at Dordt University, was required to get vaccinated as part of his clinical rotations in 2022. His mother was adamantly against the vaccine and had threatened to cut him off financially. In 2021, Perry volunteered to be one of the people administering the vaccine and emailed the nursing chair to say he personally didn’t have any problem with the vaccine at all; the issue was purely with his parents’ beliefs and concerns. Prior to requesting a religious exemption, his parents had actually written to Dordt in support of one. Perry then went on to request a religious exemption on the grounds that his body is a temple of God and that he must not knowingly put something risky into it. Dordt declined his request because he did not provide the required documentation of a published position from his denomination or a prior K-12 religious exemption.

Perry sued Dordt for religious discrimination under the ICRA. After a bench trial, the district court found that Perry was not credible. It cited his email, his history of vaping and binge drinking, contradictions between his trial and deposition testimony, and his deposition admission that he likely would have been vaccinated if his mother approved.

On appeal, Perry argued that courts cannot scrutinize whether a person’s religious beliefs are sincere, and that the district court should not have relied on his vaping and drinking because Dordt did not know about it when it denied his request. Additionally, he argued that Dordt discriminated against him by requiring him to provide published statements from his denomination showing their position on vaccination, along with K-12 records.

The Court explained that Perry was required to show that he held a bona fide belief that compliance would violate a religious belief or practice, that he provided notice of the conflict to Dordt, and that he was penalized for not complying. It explained that, while Perry’s statement that his “body is a temple” can be assumed to be religious, the question of sincerity is a question of fact that depends on credibility, not the truth or validity of the belief. The Court upheld the district court’s determination that Perry’s objection was based on financial and family reasons, rather than religious ones. Because Perry could not prove a sincere belief, the Court did not resolve whether Dordt’s documentation requirements were proper.

Tags: Iowa Supreme Court 2026-27