Thursday, October 30, 2025

Broad Religious Statements Did Not Support Title VII Discrimination Claim

 In Castaneda v. State of California Department of Motor Vehicles(ED CA, Oct. 28, 2025), a DMV employee brought several federal and state claims challenging her firing. She had raised religious objections to the Covid vaccine and also objected to the alternative of testing by DMV's third-party contractor instead of her own doctor. Dismissing, with leave to amend, plaintiff's Title VII religious discrimination claim, a California federal magistrate judge said in part:

... Plaintiff does not explain the religious basis for her objection to the vaccine, beyond saying that “her body is sacred and God-given” and she cannot be compelled to have her DNA “harvested” and “tested on” because it is “the code of life given by God.”... The Ninth Circuit recently held that “[i]nvocations of broad, religious tenets cannot, on their own, convert a secular preference into a religious conviction” for purposes of a discrimination claim....  To allow Plaintiff’s claim simply because she invokes the concepts of bodily autonomy and God in the same sentence “would destroy the pleading standard for religious discrimination claims, allowing complainants to invoke magic words and survive a dismissal without stating a prima facie case.” ...