Williams v. The City of New York

Background

Monique Williams alleged that NYC Health and Hospitals Corporation, which the opinion calls “H+H,” violated the Americans with Disabilities Act, the New York State Human Rights Law, and the New York City Human Rights Law. She alleged disability discrimination and failure to provide a reasonable accommodation.

Williams worked for H+H from 2018 through 2021 as an Assistant Director of Cost Accounting. Her job was not patient-facing. She alleged that she had anemia throughout her employment and began working remotely full time in March 2020.

After she contracted COVID-19 in August 2021, an H+H doctor allegedly told her to wait at least 90 days before receiving a COVID-19 vaccine. H+H later required its employees to be vaccinated. In November 2021, Williams submitted a letter from her hematologist advising her to delay vaccination because of her blood disorder and requested a temporary accommodation. H+H denied the request, suspended her without pay, and told her that she would be separated if she did not become fully vaccinated. Her hematologist cleared her to receive the vaccine on November 30, 2021, but H+H terminated her on December 1, 2021, for failing to comply with the vaccination requirement. Williams received the first vaccine dose on December 4, 2021, and the second on January 24, 2022.

Motion to Dismiss

H+H moved to dismiss the amended complaint under Rule 12(b)(6), which permits dismissal when a complaint does not state a legally sufficient claim. For this motion, the court accepted Williams’s factual allegations as true but required them to plausibly show that she was entitled to relief.

The court focused on whether Williams adequately alleged that she had a disability under the Americans with Disabilities Act. The statute defines disability to include a physical or mental impairment that substantially limits one or more major life activities, a record of such an impairment, or being regarded as having such an impairment. Major life activities include activities such as walking, sleeping, concentrating, and working, as well as the operation of major bodily functions.

The court held that Williams had not pleaded enough facts to show that her anemia substantially limited any major life activity or major bodily function. Her amended complaint identified anemia and quoted a Mayo Clinic description stating that anemia can cause tiredness, weakness, and shortness of breath, but she did not allege that she personally experienced those effects. She also did not allege facts about the severity, duration, or frequency of her anemia, or whether it had caused medical leave or other limitations. The court rejected the general statement that anemia affects the circulatory or hematological system as insufficient to show a substantial limitation in Williams’s own case.

Because the court found that Williams had not adequately pleaded a disability, it dismissed the federal disability claims without deciding H+H’s other arguments concerning the accommodation and discrimination allegations.

State-Law Claims and Disposition

The court had supplemental jurisdiction—the authority to hear related state-law claims alongside federal claims—over Williams’s New York State and New York City claims. After dismissing all federal claims, however, the court declined to exercise supplemental jurisdiction over those state-law claims. It dismissed those claims without prejudice as well.

The court granted H+H’s motion to dismiss without prejudice. Williams may file an amended complaint no later than 30 days after the opinion and order. If she does not do so, the court will direct the Clerk of Court to close the case. The Clerk was directed to close the motion docket entry.