Kauffman v. New York Presbyterian Hospital
- Analisa Torres
- 1:23-cv-04964
- U.S. District Court · Southern District of New York
- 1
In Kauffman v. New York Presbyterian Hospital, Judge Torres granted NYPH’s motion, dismissed Title VII with prejudice, dismissed state claims without prejudice, and denied amendment.
Kevin Kauffman and New York Presbyterian Hospital; the order ended the case by dismissing Kauffman’s Title VII claim with prejudice and his state and city claims without prejudice.
What happened
In Kauffman v. New York Presbyterian Hospital, Kevin Kauffman sued his former employer after it denied his request for a religious exemption from its mandatory COVID-19 vaccination policy and terminated him. He represented himself and brought religious-discrimination claims under federal, New York State, and New York City law.
New York Presbyterian Hospital moved to dismiss Kauffman’s amended complaint for failing to state a claim. A magistrate judge recommended dismissing the federal Title VII claim with prejudice, declining supplemental jurisdiction over the state and city claims, and denying another opportunity to amend. Kauffman did not object to that recommendation.
Judge Analisa Torres found no clear error and adopted the recommendation in full. She granted the hospital’s motion to dismiss, dismissed the Title VII claim with prejudice, dismissed the New York State and New York City claims without prejudice, and denied leave to amend. The court closed the case.
The detailed version
- Kauffman v. New York Presbyterian Hospital · No. 1:23-cv-04964
- Analisa Torres
- Jan. 8, 2025
Background
Kevin Kauffman, proceeding without a lawyer, sued his former employer, New York Presbyterian Hospital (NYPH). According to the opinion, NYPH denied Kauffman a religious exemption from its mandatory COVID-19 vaccine policy and terminated him. Kauffman asserted religious-discrimination claims under Title VII of the Civil Rights Act of 1964, the New York State Human Rights Law, and the New York City Human Rights Law.
Procedural History
The court had previously dismissed Kauffman’s initial complaint without prejudice. Kauffman then filed an amended complaint containing largely the same allegations. NYPH moved to dismiss the amended complaint under Federal Rule of Civil Procedure 12(b)(6), which permits dismissal for failure to state a legally sufficient claim.
The motion was referred to Magistrate Judge Robert W. Lehrburger. He recommended dismissing the Title VII claim with prejudice for failure to state a claim, declining supplemental jurisdiction over the New York State and New York City claims, and denying leave to amend. Kauffman was notified of his right to object but filed no objections before the deadline. Because there were no objections, Judge Torres reviewed the recommendation for clear error.
Ruling
Judge Torres found no clear error in the magistrate judge’s recommendation and adopted it in its entirety. The court granted NYPH’s motion to dismiss. It dismissed Kauffman’s Title VII claim with prejudice, dismissed his New York State and New York City claims without prejudice, and denied leave to amend. The clerk was directed to terminate the motion, close the case, and mail Kauffman a copy of the order.
Read the full 1-page opinion on CourtListener, the free public archive maintained by the Free Law Project.