Federal Court Rules Against Christian Employee Fired by Nike

PJI remains committed in its defense of religious freedom after Ninth Circuit upholds Nike's victory in former employee's vaccine mandate lawsuit

PORTLAND, Ore. - Pacific Justice Institute (PJI) is reaffirming its commitment to protecting religious freedom in the workplace following a federal appeals court decision in favor of Nike Inc. in a religious discrimination lawsuit brought by former employee Antoinette Morae.

On Oct. 1, 2026, The U.S. Court of Appeals for the Ninth Circuit affirmed a lower court ruling in Morae v. Nike Inc., concluding that Morae's objection to Nike's COVID-19 vaccination requirement was based on personal and medical concerns rather than a religious belief protected under federal employment law.

PJI attorneys Ray Hacke and Lorna Henry represented Morae in the U.S. District Court for the District of Oregon and before the Ninth Circuit.

Morae worked as a senior administrative assistant in Nike's Global Technology Finance division, performing her duties remotely. In September 2021, Nike implemented a COVID-19 vaccination policy requiring employees to be fully vaccinated by Dec. 1, 2021, unless they received an exemption.

Morae requested a religious accommodation under Nike's policy, citing her Christian faith and her belief that receiving the vaccine would violate her religious convictions.

In her exemption request, Morae explained that she had sought God's guidance through prayer and believed she should not receive the vaccine. She cited biblical teachings, including James 1:5, concerning seeking wisdom from God, and 1 Corinthians 6:19-20, which describes the body as a temple of the Holy Spirit.

Nike denied her request, determining that she had not established a religious belief conflicting with its vaccination policy. The company terminated Morae's employment in January 2022.

Morae filed suit in April 2023, alleging violations of Title VII of the Civil Rights Act of 1964 and Oregon Revised Statute 659A.030, which prohibit employment discrimination based on religion.

Under Title VII, covered employers must reasonably accommodate an employee's sincerely held religious beliefs or practices unless doing so would impose an undue hardship. The U.S. Equal Employment Opportunity Commission explains that these protections can extend to religious beliefs that differ from those commonly followed within an established faith.

In March 2025, the district court granted summary judgment to Nike. The court accepted that Morae had articulated sincerely held religious beliefs but concluded that she had not established a conflict between those beliefs and the company's vaccination requirement.

April 4, 2025, PJI appealed, arguing that the district court improperly evaluated Morae's personal conduct and discounted the religious convictions expressed in her exemption requests.

In its appellate briefs, PJI maintained that Morae's reliance on prayer and Scripture deserved consideration under federal religious accommodation law. The attorneys also argued that factual disputes concerning her beliefs should have prevented the court from granting summary judgment.

The Ninth Circuit disagreed. Relying on its earlier decision in Detwiler v. Mid-Columbia Medical Center, the three-judge panel concluded that Morae's specific objection arose from concerns about the vaccine's novelty and potential medical effects. The court determined that references to prayer and biblical teachings did not establish the required connection between her religious beliefs and her objection to vaccination.

The panel therefore affirmed Nike's victory without reaching the remaining arguments concerning the consistency of Morae's religious practices.

"Ms. Morae explained her objections through Scripture and prayer because she believed receiving the vaccine would violate her Christian convictions," said PJI attorney Lorna Henry, who served as lead counsel. "Religious accommodation protections are important precisely because employees may hold individual convictions that employers do not share or understand."

"Losing this appeal does not diminish the importance of defending employees who seek to follow their faith," said PJI Founder and President Brad Dacus. "Antoinette Morae sought a religious exemption, explained her convictions and ultimately lost her job. We believe employers must take religious accommodation requests seriously, and PJI will continue standing with individuals who believe their rights have been violated."

PJI remains committed to representing individuals facing religious discrimination across the United States. The organization provides legal assistance without charge to clients whose constitutional or statutory rights are threatened.

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Pacific Justice Institute is a nonprofit legal organization dedicated to defending religious freedom, parental rights and other civil liberties. PJI provides legal representation without charge to individuals and organizations whose constitutional rights are threatened.

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Media Contact: Pacific Justice Institute • (916) 857-6900 • [email protected] • PacificJustice.org