In Sanders v. Kootenai Hospital District, (D ID, Feb. 20, 2026), an Idaho federal district court rejected various claims by Claudia Sanders, a nurse at a crisis center who was fired by her employer, a publicly operated hospital. Sanders duties included triaging patients. According to the court:
Sanders alleges two incidents in which she engaged in constitutionally protected speech or activity that were the cause of her termination. First, she maintains that on January 23, 2022, she “discussed the Holocaust in general terms” with a Jewish patient and provided the patient a copy of Viktor Frankl’s Man’s Search for Meaning, a book written by a psychiatrist who survived the Holocaust.... Second, she contends that she has previously prayed with patients who asked her to pray.
In rejecting Sanders' free speech claims, the court said in part:
The First Amendment does not protect speech made pursuant to a government employee’s official duties....
Sanders admitted that she prayed with patients under the belief that such conduct fell within her job responsibilities....
Sanders’ January 23 discussion on the Holocaust with a patient also was made pursuant to her official duties as a NICC triage nurse.... Because Sanders’ speech owes its existence to her position, she spoke as an employee—not as a citizen. Therefore, the Court concludes that Sanders did not engage in protected speech....
... It is not unreasonable for Kootenai to consider Sanders’ statements about the Holocaust, which implied that it either did not happen or that it was a good thing ... disruptive to its ability to serve the community...
Kootenai was also justified in terminating Sanders for engaging in prayer with patients. The Supreme Court has long recognized that the government has a compelling interest in avoiding the appearance of taking a position on questions of religious belief when the restriction applies to government employees engaging in religious speech while providing state-sponsored services....
... Sanders promoted religious messages while working with patients on Kootenai business, raising a legitimate Establishment Clause concern.....
The court also rejected Sanders' claims of wrongful termination, defamation, infliction of emotional distress, and tarnishing of her reputation.