Ridings: Religious-Exemption Letter Was Part of the Pleading Record

Ridings v. PeaceHealth, No. 24-7282, D.C. No. 6:23-cv-01514-MK (D. Or.) (9th Cir. Sept. 24, 2026), reversed the Rule 12(b)(6) dismissal of federal and Oregon religious-accommodation claims. Circuit Judges Daniel P. Collins and Kenneth K. Lee sat with District Judge Sidney A. Fitzwater of the Northern District of Texas, sitting by designation; Judge Lee wrote the opinion. The Ninth Circuit reviewed the Rule 12(b)(6) dismissal de novo and the denial of leave to amend for abuse of discretion, with futility reviewed de novo. The panel held that the district court should have considered the employee’s religious-exemption letter under the incorporation-by-reference doctrine because the complaint referenced it, the claim necessarily relied on it, and authenticity was not disputed. Considering the letter, the court found a plausible religious conflict and remanded. It did not decide the ultimate merits or whether an accommodation would impose undue hardship.

The complaint referenced the request but did not attach it

Karly Ridings worked as a registered nurse for PeaceHealth in Oregon. After PeaceHealth adopted a COVID-19 vaccination requirement, Ridings sent a letter requesting a religious exemption. She asserted two grounds: A body-as-temple concern about perceived risks during pregnancy and a Christian objection to using products she believed were derived from fetal cells connected to abortion. She suggested alternatives including non-patient work and protective measures. PeaceHealth placed her on indefinite unpaid leave without benefits.

Ridings sued under Title VII and Oregon law, including Or. Rev. Stat. sections 659A.030 and 659A.033. Her complaint referred to the religious-exemption request and briefly described her religious rationale, but it did not attach the letter or recite its contents in detail. Ridings attached the letter to her opposition to PeaceHealth’s dismissal motion and requested leave to amend if the pleading was deficient. A federal magistrate judge recommended denying the motion to dismiss, but District Judge Ann L. Aiken rejected that recommendation on PeaceHealth’s objection, dismissed the claims “without prejudice,” and entered judgment without leave to amend.

The letter was incorporated by reference

A court ordinarily evaluates a dismissal motion from the complaint and attached documents. The incorporation-by-reference doctrine permits consideration of a document when the claim necessarily depends on its existence and authenticity is not disputed. The Ninth Circuit concluded that Ridings’ letter met that standard.

A religious-accommodation plaintiff must allege, among other things, that an employment duty conflicted with a sincere religious belief or practice and that the employee informed the employer of the belief and conflict. Because the request letter communicated the asserted basis for the accommodation, the claim necessarily depended on it. The complaint expressly referenced the request, and PeaceHealth did not dispute authenticity. The panel therefore treated the letter as part of the pleading record.

The court also held in the alternative that entering judgment without leave to amend was an abuse of discretion. The letter and Ridings’ request to amend showed that additional allegations could cure any perceived deficiency.

The fetal-cell objection crossed the plausibility threshold

After considering the letter, the panel held that Ridings plausibly alleged a religious conflict. Her stated objection to receiving a product she associated with fetal cells from abortion was tied specifically to her Christian beliefs and supported in the request by scriptural references. At the pleading stage, that alleged nexus between the objection and religion was enough.

The court cautioned against evaluating whether a religious conviction is reasonable or shared by every member of a faith. The inquiry was whether the pleaded belief, taken as alleged, supplied a religious rather than purely secular basis for the conflict.

Ridings distinguished Detwiler’s secular objection

PeaceHealth relied on Detwiler v. Mid-Columbia Medical Center, 156 F.4th 886 (9th Cir. 2025), which requires enough facts to show that an objection is religious rather than purely secular. Detwiler involved an objection to nasal testing framed around a personal conclusion that the test was physically harmful, followed by a general assertion that religion forbade bodily harm.

Detwiler expressly created a circuit split by rejecting as too permissive the standards applied by the Sixth, Seventh, and Eighth Circuits in Lucky, Passarella, and Ringhofer. Ridings applied the Ninth Circuit’s more demanding pleading framework while finding the specific allegation sufficient.

The Ridings panel did not read Detwiler to authorize courts to assess the sincerity or reasonableness of a religious belief. It distinguished Ridings’ specific assertion that her faith opposed participation in the use of fetal cells connected to abortion. That alleged belief directly supplied the basis for her vaccination objection. The court did not decide whether her separate body-as-temple concern would independently state a claim.

The panel also noted that Detwiler itself, in footnote 2, had distinguished Keene v. City & County of San Francisco, No. 22-16567, 2023 WL 3451687 (9th Cir. May 15, 2023) (unpublished), observing that the Keene plaintiffs had pleaded a specific Christian-faith objection to fetal cells used in developing available vaccines. The Ridings panel treated that comparison as confirmation that Ridings’ materially similar allegation satisfied the plausibility threshold.

The decision did not resolve accommodation or undue hardship

The posture was a motion to dismiss. The panel decided only that the referenced letter belonged in the pleading record and that its specific religious objection made the claim plausible. It did not determine sincerity after discovery, whether PeaceHealth offered a reasonable accommodation, whether the unpaid leave satisfied Title VII, or whether another accommodation would cause undue hardship under the governing standard.

The panel analyzed the Title VII and Oregon claims together because Ninth Circuit authority applies the same framework to Oregon’s parallel statute. That procedural choice does not convert the decision into a nationwide rule about every state-law accommodation claim.

What the decision means for pleading and record preservation

Ridings illustrates why the actual request letter can be central to a failure-to-accommodate claim. Preserve the complete request, supporting materials, delivery record, employer response, proposed alternatives, leave notices, benefits communications, and later correspondence. A complaint should accurately describe the asserted belief, the specific policy conflict, the notice given to the employer, and the employment consequence.

The decision is not a reason to overstate or retrofit an accommodation request. Incorporation by reference can expose the whole document, including language that cuts against a claim. Pleadings and public summaries should distinguish a specific asserted religious conflict from medical, political, or personal objections and should not promise that surviving dismissal establishes liability.

Review Mishra X’s employment practice, analysis of Groff’s undue-hardship standard, and Case Library for related general information. The complete published opinion and later authority should be checked before relying on this analysis.