Delsonya Wilkins-Bailey v. Essity Professional Hygiene North America, LLC
Split Score
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Case Summary
Disposition
Reversed in Part
The Fourth Circuit reversed the district court’s grant of summary judgment on the employee’s Title VII religious-accommodation claim, holding that Wilkins-Bailey’s "body-is-a-temple" objection to a COVID-19 vaccine was religious in nature, but affirmed dismissal of her race-discrimination claims. The panel remanded for the district court to consider whether accommodating her would impose an undue hardship on Essity.
Circuit Split Identified
Legal Issue
Whether generalized "body-is-a-temple" or similar beliefs that leave vaccination to individual discernment qualify as a ‘religious belief’ under Title VII’s failure-to-accommodate framework for COVID-19 vaccine mandates.
Circuit Positions
Generalized body-is-a-temple (or comparable) belief is religious in nature; minimal nexus needed between belief and vaccine refusal—claim survives to undue-hardship stage.
Plaintiff must show a specific religious injunction directly forbidding vaccination; broad or discretionary beliefs are insufficient—claim fails at prima facie stage.
Conflict Summary
Several circuits (including the Fourth in this opinion) hold that a broad religious conviction that one must keep the body as God’s temple, even if mixed with secular motives, is sufficiently ‘religious in nature’ and plausibly connected to refusing vaccination, therefore satisfying the prima-facie element of a Title VII accommodation claim. Other circuits require a tighter nexus, reasoning that such generalized tenets merely express personal preference unless the claimant shows the religion specifically forbids the vaccine, and thus reject similar claims at summary judgment or earlier.