Riley v. New York City Health & Hospitals Corporation

Background

Paulette Riley, a Christian registered nurse, worked at North Central Bronx Hospital, which was managed by New York City Health and Hospitals Corporation. She alleged that she worked during the COVID-19 pandemic while following the hospital’s safety precautions but did not receive a COVID-19 vaccination. After New York State adopted a rule requiring covered healthcare personnel to be vaccinated unless medically exempt, the hospital corporation issued its own vaccination mandate.

Riley requested a religious exemption and accommodation. The hospital corporation denied the request, granted her unpaid leave from September 27 through November 26, 2021, and later told her that no additional leave could be granted. Riley alleged that she was fired on November 29, 2021. She claimed that the hospital corporation should have allowed her to continue working as a nurse while unvaccinated and following the precautions she had previously used. She also alleged that other nurses and first responders had received religious accommodations, although she did not identify them.

Riley asserted claims under Title VII of the Civil Rights Act, 42 U.S.C. § 1983, the First and Fourteenth Amendments, the New York State Human Rights Law, and the New York City Human Rights Law. The hospital corporation moved to dismiss for failure to state a claim under Federal Rule of Civil Procedure 12(b)(6).

Title VII claim

Title VII requires an employer to reasonably accommodate an employee’s religious practice unless the accommodation would create an undue hardship. The court found that Riley’s allegations—that she was Christian, sought a religious accommodation, and was fired for refusing vaccination—plausibly established an initial religious-discrimination claim at the motion-to-dismiss stage.

The court nevertheless dismissed the accommodation claim. It reasoned that Riley sought to continue working as a patient-facing nurse while unvaccinated. The state vaccination rule required covered healthcare personnel to be fully vaccinated unless they received a medical exemption. Because Title VII does not require an employer to violate the law, the requested accommodation would have imposed an undue hardship by requiring the hospital corporation to violate the state rule. The court noted that an accommodation might have been possible if Riley had sought work removing her from the rule’s definition of covered personnel, but she did not seek that type of accommodation.

The court did not dismiss the Title VII claim based on failure to exhaust administrative remedies. It stated that non-exhaustion was not clear from the complaint and that the defendant’s attached Equal Employment Opportunity Commission document could not be considered on this motion.

Constitutional claims

Riley brought constitutional claims through Section 1983, which allows claims against local government entities for violations caused by a government policy or custom. The court treated the hospital corporation as a local government entity for these claims.

For the religious-freedom claim, the court concluded that Riley had not plausibly alleged that the vaccination mandate was nonneutral or not generally applicable. The complaint did not allege that the mandate specifically targeted religious practices, and the absence of a religious exception alone did not make the mandate unconstitutional. Because the mandate was subject to rational-basis review and was rationally related to protecting public health and safety, the court dismissed the free-exercise claim without prejudice.

The court also stated that Riley abandoned her Equal Protection Clause claim by failing to respond to the defendant’s argument that the claim was insufficient. The opinion separately referred to Riley’s First Amendment claims but did not identify an additional, separate First Amendment claim beyond the free-exercise claim.

State and city claims

Riley also asserted religious-discrimination claims under the New York State Human Rights Law and the New York City Human Rights Law. After dismissing all federal claims, the court declined to exercise supplemental jurisdiction, meaning authority to hear related state-law claims in the same case. The court dismissed the state and city claims without prejudice.

Disposition

Judge John G. Koeltl granted the defendant’s motion to dismiss, and the complaint was dismissed without prejudice. The court denied as moot the defendant’s motion under Rule 26(c) to stay discovery while the dismissal motion was pending. The court stated that Riley could move for permission to file another amended complaint with a proposed complaint within thirty days if she believed the defects could be corrected.