Leo v. Siemens Medical Solutions USA, Inc.

Background

Samuel Leo sued his former employer, Siemens Medical Solutions USA, Inc. (SMS), and other defendants. The opinion states that Leo worked for SMS as a field service engineer from November 2007 until September 2024. After the case was removed from New York state court, defendants moved to dismiss the First Amended Complaint. New counsel appeared for Leo, and Leo moved under Rule 15(a)(2) of the Federal Rules of Civil Procedure for permission to file a Second Amended Complaint.

The proposed Second Amended Complaint would replace the existing claims with one claim against SMS, under its proper name, for religious discrimination under the New York State Human Rights Law. The proposed complaint alleges that SMS adopted a mandatory COVID-19 vaccination policy in August 2021. The policy required covered employees to be fully vaccinated by October 15, 2021, subject to disciplinary action including termination, and allowed exemptions based on a qualifying medical condition or a sincerely held religious belief.

Leo alleges that he told SMS about his religious belief and requested a religious exemption. He says SMS did not respond by the vaccination deadline, restricted him from activities such as training classes, and later denied the religious-exemption request on February 2, 2022. Leo then requested a medical exemption, which SMS approved on March 30, 2022. The proposed complaint alleges that Leo took short-term disability leave, was deprived of regular employment and income, and suffered more than $75,000 in damages.

Legal Standard

Rule 15(a)(2) generally directs courts to freely allow amendments when justice requires. A court may deny permission for reasons such as futility, bad faith, undue delay, or unfair prejudice. An amendment is futile if the proposed claim could not survive a motion to dismiss for failure to state a claim under Rule 12(b)(6). At this stage, the court accepts well-pleaded factual allegations as true and asks whether they plausibly support relief.

Court’s Analysis

SMS argued that the amendment was futile for four reasons.

1. Federal labor-law preemption. SMS argued that Section 301 of the Labor Management Relations Act displaced the state-law claim and subjected it to a six-month limitations period. The court rejected that argument. A state discrimination claim is not displaced when proving discrimination does not require interpreting a collective-bargaining agreement. The proposed complaint did not refer to such an agreement, and SMS did not explain how any defense would require interpreting it.

2. Timeliness and relation back. The court recognized that the New York State Human Rights Law generally has a three-year limitations period and that period had expired before Leo sought permission to amend. But the court held that the proposed claim related back to the original complaint under Rule 15(c)(1)(B). The original complaint described the same alleged religious-exemption policy for COVID-19 vaccination requirements and expressly referred to religious freedoms protected by New York’s Human Rights Law. The court therefore found that defendants had adequate notice of the factual basis for the proposed claim and concluded that it was timely.

3. New York health regulation. SMS argued that a New York State Department of Health emergency regulation barred the requested religious accommodation because the regulation prohibited religious exemptions for covered entities. The court could not resolve that issue on the motion to amend. The proposed complaint described SMS as a medical-technology company rather than a medical-care provider, so it did not appear to be a covered entity. The parties nevertheless disputed whether Leo was contract staff who could potentially expose covered personnel, patients, or residents to COVID-19. The court held that this factual dispute was not a basis to deny amendment.

4. Adverse employment action. SMS argued that Leo had not alleged an adverse employment action because he ultimately received a medical accommodation. The court held that the proposed complaint met the applicable minimum requirement of alleging some disadvantageous change in an employment term or condition. Leo alleged that SMS’s handling of his religious-accommodation request kept him from certain employment activities, caused him to take short-term disability leave, deprived him of regular employment and income, and caused compensable damages.

The court also found no bad faith, undue delay, or undue prejudice. It noted that Leo’s new counsel promptly sought amendment and that the proposed complaint simplified the case to one claim against an already-named defendant that had notice of the alleged discrimination.

Disposition

The court granted Leo leave to file the Second Amended Complaint by June 12, 2025. The court denied as moot the motions to dismiss the First Amended Complaint. The Clerk was directed to terminate the identified docket entries, terminate the current defendants, and add Siemens Medical Solutions USA, Inc. as the defendant. The opinion allowed the proposed claim to be pleaded; it did not decide the ultimate merits of that claim.