Plaintiff, an employee of Princeton University, was terminated from her position as a budget analyst based on her refusal to adhere to the University’s COVID policies. Plaintiff filed a complaint in the New Jersey Federal District Court claiming religious discrimination and retaliation motivated her termination in violation of Title VII of the Civil Rights Act of 1964 and the New Jersey Law Against Discrimination. The Court held that Plaintiff did not establish a sincerely held religious belief so there could be no religious discrimination and no retaliation.

Plaintiff was exempt from vaccinations but was not exempt from mask requirements, asymptomatic COVID testing, and contact tracing. Plaintiff sought an exemption claiming “her body is a temple, she decries and does all that she can to abolish any and all abuse against life and Mankind and she decries the suppression of knowledge, wisdom, philosophy, or data which would help Mankind.” She asserted that the mask requirements would “degrade and humiliate her on a daily basis as it would force her to participate in something that is against her beliefs.” The asymptomatic testing would be “disrespectful to her body” because it would “forcibly provide her DNA through the saliva testing to be utilized by other individuals or entities without her knowledge or consent.”

The court evaluated the existence of sincerely held religious belief, which is the standard by which to evaluate a claim of religious discrimination, based on a three-part definition:

• First, a religion addresses fundamental and ultimate questions having to do with deep and imponderable matters.
• Second, a religion is comprehensive in nature; it consists of a belief system as opposed to an isolated teaching.
• Third, a religion can often be recognized by the presence of certain formal and external signs.

The Court concluded that Plaintiff was alleging a collection of general moral commandments and that such a personal moral code did not address any “fundamental and ultimate questions,” she was not thinking about “deep and imponderable matters,” nor did her views constitute a “comprehensive system of beliefs.” Plaintiff did not connect her beliefs to any formal and external signs which traditionally manifest in formal services, ceremonial functions, the existence of clergy, structure and organization, efforts of propagation, observation of holidays, and other similar associations with traditional religions. Rather, Plaintiff was espousing a personal and medical belief not grounded in religion so she was not the victim of religious discrimination or retaliation.