Gaskin-El v. 1199SEIU National Benefit Fund

Background

Naomi Gaskin-El asked the court to prevent 1199SEIU National Benefit Fund from asserting an undue-hardship defense in her Title VII discrimination case. The defendant submitted a pre-motion letter seeking permission to file a motion for summary judgment, which asks the court to resolve a claim without a trial when the law and undisputed facts require that result.

The opinion states that Gaskin-El alleged a genuine religious belief related to her objection to the COVID-19 vaccine, and that this allegation was sufficient to survive the defendant’s earlier motion to dismiss. The court previously stated that the parties should explore through discovery whether her reason for objecting was genuinely religious.

Rulings

The court denied Gaskin-El’s request to preclude the undue-hardship defense. It held that the Second Circuit does not require a defendant in a Title VII discrimination case to specifically plead that defense. The court stated that any undue-hardship defense offered by the defendant would be evaluated on the merits later.

The court granted the defendant’s request to file a motion for summary judgment. It explained that, at that stage, the court would decide as a matter of law whether Gaskin-El presented a genuine dispute of material fact about the sincerity of her religious beliefs sufficient to warrant a trial. The court rejected Gaskin-El’s request to bypass that inquiry.

Next Step Ordered

The parties were ordered to submit a joint proposed briefing schedule for the defendant’s summary-judgment motion by August 11, 2025, instead of submitting the proposed pretrial order that had previously been due on August 18, 2025. This order did not decide the summary-judgment motion itself.