Corrales v. Montefiore Medical Center

Background

Alba L. Corrales sued Montefiore Medical Center, alleging violations of Title VII of the Civil Rights Act of 1964, New York State Executive Law, and the New York City Administrative Code. Corrales alleged that she had a sincerely held religious objection to COVID-19 vaccination, that Montefiore denied her request for a religious exemption, and that Montefiore then placed her on unpaid leave and terminated her employment after she continued to refuse vaccination.

Montefiore required its employees to comply with the New York State Department of Health’s COVID-19 vaccination rule, known as Section 2.61. That rule required covered entities to ensure that covered personnel were fully vaccinated, although it provided medical exemptions and did not provide religious exemptions. Montefiore nevertheless created a process for employees to request religious exemptions. Corrales submitted such a request, supporting statements, and additional information, but Montefiore denied it.

Motion to dismiss

Montefiore moved to dismiss the amended complaint under Federal Rule of Civil Procedure 12(b)(6), which permits dismissal when a complaint does not state a legally sufficient claim. Montefiore argued that it was required to comply with Section 2.61 and that accommodating Corrales’s request would cause undue hardship because it would require Montefiore to violate state law and would expose staff and visitors to COVID-19 risks.

The court rejected Montefiore’s argument that the new allegations in the amended complaint should be disregarded. Because those allegations appeared on the face of the amended complaint, the court considered them. The court also explained that an amended complaint replaces the original complaint, while declining to treat the contents of external documents as true when those documents were not attached to or incorporated into the complaint.

Court’s analysis

The court held that Corrales alleged enough facts to make a preliminary case for religious discrimination under Title VII and the New York State Human Rights Law. She alleged a genuine religious belief conflicting with vaccination, notice to Montefiore of that belief, and discipline for refusing to comply with the vaccination requirement. The court applied the same basic framework to the New York City Human Rights Law, while recognizing that the city law must be analyzed separately and is broader than federal and state law in some respects.

The court then addressed whether Montefiore could provide the requested accommodation without undue hardship. Corrales sought a blanket exemption that would have allowed her to remain in her regular employment while unvaccinated. The court determined that she did not seek an alternative accommodation, such as telework, that would have removed her from the scope of Section 2.61.

Relying on Second Circuit precedent, the court ruled that Section 2.61 barred a blanket religious exemption allowing covered personnel to continue working in their current positions while unvaccinated. Granting Corrales’s requested exemption would therefore have required Montefiore to violate binding state law and would have caused undue hardship under the applicable statutes.

Disposition

The court dismissed Corrales’s Title VII and New York State Human Rights Law claims without prejudice. It also dismissed her New York City Human Rights Law claim without prejudice. The court granted Montefiore’s motion to dismiss without prejudice and stated that Corrales could move to file a new pleading with a proposed amended complaint. The Clerk was directed to close the case and any open motions.