Patrick Akerlund, et al. v. Atlas Air, Inc.

Title VII forbids an employer to discriminate against an individual “because of such individual’s . . . religion.” 42 U.S.C. § 2000e-2(a)(1). Petitioner James Villella alleged that he “requested a religious exemption to both vaccinating and testing,” that his employer “attempted to get Plaintiff to change, alter, or abandon his religious beliefs,” and that he was removed from flight status “for refusing to test due to his sincerely held religious beliefs.” The Eleventh Circuit affirmed dismissal at the pleading stage. It held that “the plaintiffs do not allege any facts indicating that Atlas Air intended to discriminate against their religious beliefs,” and that petitioners “do not allege any religious objections to masks or tests—only political and logistical ones.” The Question Presented Is: Whether a court may dismiss a Title VII religiousdiscrimination claim at the pleading stage on the ground that an employee’s professed religious objection to a workplace requirement is in fact secular or political, notwithstanding the complaint’s allegation that the objection rested on sincerely held religious belief.