Jones v. Weill Cornell Medicine

Background

Corrine Jones had worked for Weill Cornell Medicine as a mammography technician for more than 20 years. On June 10, 2021, the defendant adopted a mandatory COVID-19 vaccination policy requiring employees to be vaccinated by September 1, 2021. The policy included medical and religious exemptions. Employees who did not comply could not return to work and would be placed on unpaid leave.

Jones alleged that she requested a medical accommodation on July 28, 2021. She submitted a letter from her internist stating that the COVID-19 vaccine could harm her health because she had previously experienced an adverse reaction resembling symptoms of Guillain-Barré Syndrome, a rare autoimmune disorder. Jones alleged that Weill Cornell Medicine denied the accommodation on August 12, 2021, even though she was qualified to perform her job and could have used protective equipment such as a mask. The opinion states that the defendant terminated her employment on October 1, 2022.

Jones did not respond to the motion to dismiss. The court nevertheless independently reviewed her amended complaint.

Claims and Legal Standard

Weill Cornell Medicine moved to dismiss under Federal Rule of Civil Procedure 12(b)(6), which permits dismissal when a complaint does not state a legally sufficient claim for relief. At this stage, the court accepts well-supported factual allegations as true and draws reasonable inferences for the plaintiff, but the complaint must contain enough facts to make the claim plausible rather than merely possible.

Jones asserted disability-discrimination and retaliation claims under the Americans with Disabilities Act (ADA), along with related claims under the New York State Human Rights Law and the New York City Human Rights Law.

Court’s Analysis

The court held that Jones did not plausibly allege that she was disabled under the ADA. To allege an ADA disability, a plaintiff must identify a physical or mental impairment, identify a major life activity affected by that impairment, and provide facts showing that the impairment substantially limited that activity. The court found that Jones had only alleged a prior adverse reaction to a flu vaccine, without details about the reaction’s frequency, severity, or duration.

The court also found that Jones’s allegations concerning Guillain-Barré Syndrome were contradicted by the physician’s letter, which described only past symptoms resembling the disorder. The court therefore concluded that the allegations were insufficient to support an ADA disability-discrimination claim.

The court separately dismissed the ADA retaliation claim. It explained that such a claim requires a protected activity, the employer’s knowledge of that activity, an adverse action, and facts showing that the adverse action would not have occurred without the protected activity. The court found that Jones’s allegations showed she was fired because she did not comply with the company-wide vaccination policy, not because she engaged in protected activity.

After dismissing the federal ADA claims, the court declined to exercise supplemental jurisdiction—the authority to hear related state-law claims—over Jones’s NYSHRL and NYCHRL claims. The court dismissed the amended complaint in its entirety. It also stated that granting leave to amend would not be productive because neither the original complaint nor the amended complaint suggested a legally cognizable claim for relief. The Clerk was directed to terminate the motion and close the case.

Disposition

Judge Alvin K. Hellerstein granted Weill Cornell Medicine’s motion to dismiss and dismissed the case. The opinion does not use the phrase “with prejudice” or “without prejudice.”