The Fourth Circuit Court of Appeals reinstated a fired worker’s Title VII religious failure-to-accommodate lawsuit against Essity Professional Hygiene North America. The court held that an employee’s belief that her body is a temple protected by God’s law constitutes a religious belief, even when arrived at through personal prayer, discernment, and mixed with secular safety concerns. Writing for the majority, the panel clarified that Title VII does not require strict adherence to a centralized catechism or flawless deposition testimony to survive summary judgment. However, the court affirmed the dismissal of her racial discrimination claims under McDonnell Douglas burden-shifting, concluding she failed to show the employer’s misclassification of her request was a pretext for racial bias. A partial dissent argued the majority set an impermissibly low evidentiary bar, warning that protecting unilateral “discernment” will trigger limitless exemption requests.
Case Info: Caption: Wilkins-Bailey v. Essity Professional Hygiene North America, LLC Date: August 31, 2026 (Amended September 1, 2026) Decision: Fourth Circuit Court of Appeals, No. 25-1992
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