Shahid-Ikhlas v. The New York And Presbyterian Hospital, Inc.

Background

Hakimah Shahid-Ikhlas sued The New York And Presbyterian Hospital, Inc. The opinion states that she sought an exemption from the New York State Department of Health’s vaccine mandate for healthcare workers. Her complaint asserted a claim under Title VII and claims under the New York State Human Rights Law and the New York City Human Rights Law.

Report and Recommendation

Magistrate Judge Aaron recommended granting the hospital’s motion to dismiss. The recommendation concluded that the complaint failed to state a Title VII claim because accommodating Shahid-Ikhlas’s request would have caused the hospital undue hardship as a matter of law. Because the Title VII claim was the only claim giving the federal court original jurisdiction, the recommendation also advised the court to decline supplemental jurisdiction—meaning authority to hear related state-law claims—over the remaining claims.

Court’s Review and Ruling

No party submitted an objection within the fourteen-day objection period. The court therefore reviewed the recommendation for clear error, meaning an obvious mistake in the record, and found none. It accepted and adopted the recommendation in its entirety.

Judge Gregory H. Woods granted the hospital’s motion to dismiss as to the Title VII claim and declined to exercise supplemental jurisdiction over the remaining state-law claims. The court did not grant leave to amend because Shahid-Ikhlas had not requested permission to amend. The Clerk was directed to enter judgment for the hospital and close the case. The opinion does not state that the dismissal was with or without prejudice.