The Eighth Circuit Court of Appeals affirmed a district court's dismissal of religious discrimination claims brought by Benjamin Zarn against his employer, the Minnesota Department of Human Services (MDHS), in a decision filed Feb. 2, 2026.

Zarn, who has worked as a Forensic Support Specialist at St. Peter Regional Treatment Center since 2018, sued MDHS alleging religious discrimination in violation of Title VII, the Americans with Disabilities Act (ADA), the Minnesota Human Rights Act, and the Minnesota Refusal of Treatment statute.

The case centers on Zarn's employment at the state-run and funded treatment facility, where his primary responsibility involves providing direct care, treatment, support, and leisure activities while ensuring a safe environment for individuals committed to the Commissioner of Department of Human Services in a secure setting.

The dispute appears to involve COVID-19 protocols promulgated by the Minnesota Management and Budget Office (MMB), though the full details of the religious accommodation dispute are not specified in the available court record.

At the district court level, the case faced multiple procedural challenges. The U.S. District Court for the District of Minnesota dismissed Zarn's Minnesota state law claims pursuant to Federal Rule of Civil Procedure 12(b)(1) for lack of subject matter jurisdiction. The court also found that the Minnesota Refusal of Treatment claim failed to state a claim upon which relief may be granted, dismissing it under Federal Rule of Civil Procedure 12(b)(6).

Following these dismissals, the district court granted summary judgment in favor of MDHS on Zarn's federal law claims under Title VII and the ADA. Summary judgment is granted when there are no genuine disputes of material fact and the moving party is entitled to judgment as a matter of law.

Zarn appealed the grant of summary judgment to the Eighth Circuit, which heard the case under its jurisdiction pursuant to 28 U.S.C. § 1291, which provides appellate courts with jurisdiction over appeals from final decisions of district courts.

The three-judge panel consisting of Circuit Judges Loken, Benton, and Shepherd heard oral arguments on Oct. 23, 2025. Circuit Judge Shepherd authored the opinion for the court.

In affirming the lower court's decision, the Eighth Circuit upheld both the dismissal of state law claims and the grant of summary judgment on federal claims. The appeals court found that the district court properly analyzed the various legal claims and correctly applied the relevant legal standards.

The case highlights the challenges employees face when bringing religious discrimination claims against government employers. Title VII of the Civil Rights Act of 1964 prohibits employment discrimination based on religion and requires employers to provide reasonable religious accommodations unless doing so would cause undue hardship.

The ADA similarly prohibits discrimination against qualified individuals with disabilities and requires reasonable accommodations in the workplace. However, both federal statutes have specific requirements and limitations that can make successful claims challenging to pursue.

For state employees like Zarn, the legal landscape can be particularly complex. Federal courts have limited jurisdiction over state law claims and will often dismiss them when they lack supplemental jurisdiction or when state law immunity doctrines apply.

The Minnesota Human Rights Act provides additional protections against discrimination in employment, but federal courts may decline to exercise jurisdiction over such state law claims, particularly when federal claims are dismissed or resolved.

The timing of this case, involving COVID-19 protocols, reflects the numerous workplace disputes that arose during the pandemic as employers implemented health and safety measures that sometimes conflicted with employees' religious beliefs or practices.

Many healthcare and treatment facilities, like the St. Peter Regional Treatment Center where Zarn works, faced particular challenges in balancing religious accommodation requests with public health requirements designed to protect vulnerable populations.

The Eighth Circuit's affirmance means Zarn has exhausted his federal court options unless he seeks review by the Supreme Court, though the high court accepts very few cases for review each year.

This decision adds to the body of case law addressing religious accommodation claims in government employment settings, particularly in healthcare-related contexts during public health emergencies.

The case serves as a reminder that employees seeking religious accommodations must meet specific legal standards and that government employers have various defenses available, including jurisdictional challenges and substantive legal arguments.

For state employees in the Eighth Circuit's jurisdiction, which includes Minnesota, this decision may influence future religious discrimination claims and the strategies attorneys use in bringing such cases.

The affirmance also underscores the importance of carefully crafting complaints to survive jurisdictional challenges and meet the pleading standards required under federal civil procedure rules.