In Naylor v. County of Muscatine, Iowa, (8th Cir., Aug. 19, 2025), the U.S. 8th Circuit Court of Appeals reversed a trial court's dismissal of a Title VII religious discrimination lawsuit brought by a county jail administrator who was fired because of his online postings. The court said in part:
At the district court, Muscatine County argued it would suffer two types of undue hardship if it continued to employ Naylor as jail administrator. First, the County argued that keeping Naylor on would cause the jail undue hardship because the publicity surrounding his online commentary—which included disparaging views of Muslims and “the gay lifestyle”—had harmed its public image....
We assume, but need not decide, that public image effects can present issues for an organization sufficient to rise to the level of an undue hardship under Title VII. Here, the County has simply not provided sufficient evidence to warrant summary judgment on this ground....
As a second, related type of undue hardship, Muscatine County argued to the district court that retaining Naylor as the jail administrator would imperil its business relationships. The district court agreed, relying on evidence that two outside entities—USMS and Johnson County—considered ending their agreements to send their overflow detainees to the jail as a result of Naylor’s online commentary, and that the loss of these relationships would cause a significant financial burden to Muscatine County. While a reasonable jury could find this evidence sufficient to establish an undue hardship, the evidence is insufficient to support the grant of summary judgment.
