The panel reversed the district court’s Fed. R. Civ. P. 12(b)(6) dismissal of Karly Ridings’s employment discrimination action against PeaceHealth, alleging a failure to accommodate her religious beliefs under Title VII and Oregon state law, and remanded for further proceedings.

Ridings, a registered nurse, sent a letter to PeaceHealth requesting a religious exemption from a mandatory vaccination policy on two religious grounds.

In response, PeaceHealth placed her on indefinite leave without benefits or pay. In her complaint, Ridings briefly explained her rationale for declining the vaccine, but she did not attach the letter. PeaceHealth moved to dismiss for failure to plead the first element of a failure-to-accommodate religious discrimination claim, that PeaceHealth’s vaccination policy conflicted with Ridings’s bona fide religious beliefs. In her opposition to the motion to dismiss, Ridings requested leave to amend the complaint if the court found the pleading to be insufficient. She also attached a copy of the religious exemption letter that she had tendered to PeaceHealth.

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The panel held that under the incorporation-by-reference doctrine, the district court should have considered the contents of Ridings’s letter because it was central to her claim. The panel held that, considering the letter, Ridings easily satisfied the plausibility threshold for a prima facie Title VII religious discrimination claim, which requires a plaintiff to show that an employment duty conflicted with her sincere religious beliefs or practice and also that she informed her employer of the belief and conflict.

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https://cdn.ca9.uscourts.gov/datastore/opinions/2026/09/24/24-7282.pdf