In Troogstad v. City of Chicago, (7th Cir., Dec. 9, 2025), the U.S. 7th Circuit Court of Appeals upheld the dismissal of free exercise claims by a Chicago Fire Department employee who was denied a religious exemption from the city's Covid-19 vaccine mandate. The court said in part:
Troogstad alleges “the gene-altering aspect of mRNA vaccinations violates his beliefs as a Christian.” But he failed to allege facts about how taking the vaccine violated his religious beliefs. He misses that step....
.... While the pleading of a violation of the Free Exercise Clause need not be overly exacting, in numerous rounds of pleading ... Troogstad did not move beyond conclusory statements. A complaint need not provide detailed factual allegations; mere conclusions generally will not suffice.... Troogstad’s failure to allege facts about how his religious beliefs as a Christian conflict with the vaccine requirement—after numerous opportunities to satisfy this pleading standard—dooms his Free Exercise claim.
For the same reason, the court upheld the dismissal of plaintiff's claim under the Illinois Religious Freedom Restoration Act.
