Williams v. The City of New York
- Lewis Liman
- 1:24-cv-05467
- U.S. District Court · Southern District of New York
- 3
In Williams v. The City of New York, Judge Liman granted the City's request to pause discovery while the motion to dismiss is pending.
The plaintiff and the City of New York are affected: discovery in the case is paused while the court considers the City's motion to dismiss the second amended complaint.
What happened
In Williams v. The City of New York, the plaintiff alleges that the City failed to accommodate her anemia by denying her a medical exemption from New York's healthcare-facility COVID-19 mandate. The case had a discovery deadline of September 12, 2025.
The City asked the court to pause discovery while it considered the City's motion to dismiss the second amended complaint. The City argued that the complaint did not adequately allege a disability, that the plaintiff was not qualified for the requested exemption, and that the requested accommodation would have created an undue hardship or violated the law.
Judge Lewis J. Liman granted the request to stay discovery. The order pauses discovery while the court decides the motion to dismiss; it does not decide that motion or the underlying discrimination claims.
The detailed version
- Williams v. The City of New York · No. 1:24-cv-05467
- Lewis Liman
- Aug. 4, 2025
Background
The plaintiff filed this action on July 19, 2024. After the City filed earlier motions to dismiss, the plaintiff filed amended complaints. On May 7, 2025, the court granted the City's motion to dismiss the amended complaint. The plaintiff then filed a second amended complaint on June 4, 2025.
The second amended complaint alleges that the City failed to accommodate the plaintiff's anemia when it declined to grant her a medical exemption from the New York State healthcare-facility COVID-19 mandate. The plaintiff asserts claims under federal, state, and City discrimination laws.
The court's June 13, 2025 amended case-management order required fact discovery and expert discovery, including depositions, to be completed by September 12, 2025.
Motion and arguments
On July 25, 2025, the City moved to dismiss the second amended complaint in its entirety under Federal Rule of Civil Procedure 12(b)(6), which concerns whether a complaint states a legally sufficient claim. The City argued that the plaintiff did not plausibly allege that she had a disability; was not qualified to perform her job because the complaint did not show that she fell within the mandate's medical exemption; that the requested accommodation would have imposed an undue hardship and violated the law; that she failed to provide enough medical documentation for the interactive process; and that she did not allege an adverse employment action caused by a disability.
The City also requested a stay of discovery, meaning a temporary pause in the exchange of information and related proceedings, until the court decided the motion to dismiss. The City argued that the motion was completely dispositive of the second amended complaint and that discovery would unnecessarily consume time, money, and resources if the motion resolved the case. The plaintiff did not consent to the request.
Ruling
Judge Lewis J. Liman granted the request for a stay of discovery. The order therefore pauses discovery while the court considers the City's motion to dismiss. The opinion does not state that the court granted or denied the motion to dismiss, and it does not resolve the plaintiff's discrimination claims.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.