Hoffman v. City College of New York

Background

Tynan Hoffman sued the City University of New York (CUNY) under Section 504 of the Rehabilitation Act, a federal law prohibiting disability discrimination in covered programs and activities. Hoffman had worked as a reference librarian at the City College of New York, which is part of CUNY, and held the academic rank of Instructor.

CUNY’s policy generally allowed an Instructor to serve for five years. During that period, librarian Instructors were expected to complete a second master’s degree or doctorate to become eligible for a tenure-track Assistant Professor position. Hoffman enrolled in a master’s program in international affairs but did not complete the required coursework and thesis within the initial five years.

After Hoffman told his supervisor that he was struggling with depression, CUNY granted him a one-year extension. Hoffman still did not complete the degree requirements during that extension. He then requested a second one-year extension as a disability accommodation and submitted medical information stating that his depression had impaired his academic progress and that treatment was expected to allow him to complete the degree within another year. CUNY denied the request, concluding that it would fundamentally alter the Instructor position and create an undue hardship.

Motion and Magistrate Judge’s Recommendation

CUNY moved for summary judgment. Summary judgment is granted when the evidence shows that no genuine dispute over an important fact exists and the moving party is entitled to judgment under the law. Magistrate Judge Lehrburger recommended denying CUNY’s motion.

The recommendation identified factual disputes about whether obtaining a second master’s degree was an essential function of the librarian Instructor position and, if so, whether completing it within five years was essential. The job description for librarian Instructor did not expressly require a second master’s degree or completion within five years, while the Assistant Professor description expressly referred to an additional master’s degree or doctorate. The earlier one-year extension also supported an inference that the five-year deadline might not be essential.

The recommendation further concluded that Hoffman had presented evidence that a second one-year extension was a facially reasonable accommodation. He had previously received one extension, and Hoffman and his medical providers said that improved control of his depression would allow him to complete the remaining requirements within a year. The recommendation also found that CUNY had not adequately explained the financial, administrative, academic, or operational burdens that a second extension would create.

District Court’s Review

CUNY objected to the recommendation, arguing that the degree deadline was an essential requirement, that the requested extension was unreasonable, and that the extension would impose an undue hardship. The district court determined that CUNY’s objections largely repeated arguments from its summary-judgment briefing. The court therefore reviewed the recommendation for clear error rather than conducting a new review of the disputed issues.

The court agreed with the magistrate judge that the record contained conflicting evidence about the essential functions of the Instructor position. Although CUNY’s policies and several administrators’ declarations described completion of a second master’s degree within five years as a requirement, the librarian Instructor job description did not expressly state that requirement, and CUNY had previously granted Hoffman an extra year. The court held that this created a material factual dispute.

The court also agreed that there was a factual dispute about whether the requested accommodation was reasonable. The proposed accommodation was limited to one additional year, not an indefinite extension or a waiver of the degree requirement. Evidence that CUNY had previously granted an extension and that Hoffman’s symptoms had improved supported the possibility that he could complete the degree in that period.

Finally, the court concluded that CUNY had not shown as a matter of law that the accommodation would impose an undue hardship or fundamentally alter its program. CUNY asserted that the extension would change the temporary nature and standards of the Instructor position, but the court found that it did not sufficiently explain the practical effects, administrative or financial burdens, or any harm to the academic rigor or reputation of the program. The court also declined to give CUNY special deference because the record did not show that it had diligently assessed those considerations.

Disposition

Judge Gardephe adopted Judge Lehrburger’s Report and Recommendation in its entirety, overruled CUNY’s objections, and denied CUNY’s motion for summary judgment. The court directed that the case proceed to trial and scheduled trial for October 21, 2024.