For nearly a decade, a public Google document titled “The Church and the End Time,” written by the Jail Administrator for the Muscatine County Sheriff’s Office in Iowa, Dean Naylor, sat online. Therein, Naylor detailed his post-tribulation Rapture beliefs, predicting an impending world war that he asserted Muslim people would perpetrate against Christians and Jews. He described Muslims as “pawns to the devil” and the “gay lifestyle” as an “abomination.” For years, these views, also expressed in YouTube videos on his public channel, were part of his online presence.
In early April 2020, a reporter emailed Sheriff C.J. Ryan to ask if he was aware of the “lengthy treatise” and the videos. The reporter soon published an article in the newspaper Iowa Capital Dispatch, under a headline that read “Iowa jail official: Muslims are ‘pawns of the devil’ aiming to kill Christians.” The article quoted Naylor’s commentary at length.
The publication triggered immediate reactions. A community member, the Mayor of Iowa City, and the Johnson County Board of Supervisors expressed concern about the civil liberties of detainees. More critically for the jail’s operations, the Johnson County Sheriff and a representative from the United States Marshals Service (USMS) called Sheriff Ryan to discuss whether they would “continue to house [overflow] inmates” at the Muscatine County Jail. The jail relied on contracts with these entities to house overflow detainees, a significant source of revenue.
The County placed Naylor on administrative leave and fired him on May 1, 2020. The termination letter stated his “continued employment was contrary to good order and discipline at the jail” and that he “lacked credibility to function effectively in a management role.”
Naylor sued the County under Title VII, alleging he was fired because of his religion. The federal district court granted summary judgment to Muscatine County and Naylor appealed.
On August 19, 2025, a three-judge panel of the United States Court of Appeals for the Eighth Circuit reversed the lower court’s decision, ruling that the case could proceed to trial. The Court found that the County had failed to prove, as a matter of undisputed law, that accommodating Naylor’s religious expression by keeping him employed would have imposed an “undue hardship” on its operations.
The County had argued it would suffer two primary hardships if Naylor remained jail administrator. First, it claimed the publicity had harmed the jail’s public image, creating an appearance of bias that undermined its ability to operate. The district court had agreed, citing the need for jails to maintain an “appearance of neutrality.”
The Eighth Circuit, however, found the evidence of reputational damage insufficient for summary judgment. The Court noted that while there was evidence of public concern, “the record nonetheless lacks sufficient evidence of an actual negative impact on the jail’s public image.” The only public concern cited was “a single community member’s email,” while other disapproval came from public officials or news articles “whose reach or impact is unknown.” “Absent more definitive evidence of reputational harm, and with an unclearly articulated theory of how such harm would constitute a hardship, the County’s evidence does not warrant summary judgment.” The County had not shown that the public image harm was anything more than hypothetical, failing to provide evidence of “other types of hardship stemming from public-image harm, in the form of protest or otherwise, that would threaten the jail’s ability to function.”
Second, the County argued that retaining Naylor would imperil its business relationships with USMS and Johnson County, who had threatened to cancel their overflow contracts. The appellate court acknowledged this was a stronger argument, noting “a reasonable jury could find this evidence sufficient to establish an undue hardship.” Yet, it found the evidence “insufficient to support the grant of summary judgment.”
The Court pointed out that the loss of these contracts was still speculative. Officials had only had conversations about whether USMS would terminate its contract, and Johnson County warned only that it “may” have to do the same. This did not show a sufficiently “real” chance the contracts would be canceled. Furthermore, the County provided scant evidence of the claimed financial impact. Naylor’s own testimony about losing “millions” was inexact, made years after he worked on the budget, and did not isolate the value of the specific contracts in jeopardy. The court highlighted that in April 2020, the jail housed only four overflow detainees from Johnson County in its 255-person facility, leaving a factual dispute about whether losing these clients would impose a hardship “substantial… in relation to the conduct of the jail’s particular business.”
Naylor v. County of Muscatine, 151 F.4th 973 (8th Cir. 2025).