Cagle v. Weill Cornell Medicine

Background

Sharme Cagle, proceeding without a lawyer, sued Weill Cornell Medicine under Title VII of the Civil Rights Act of 1964 and Title I of the Americans with Disabilities Act. She alleged that Weill Cornell Medicine discriminated against her because of her religious beliefs and practices and terminated her employment as a practical nurse after she did not receive a COVID-19 vaccination.

At the time, a New York Department of Health rule required covered hospitals and other medical entities to require eligible personnel to be fully vaccinated against COVID-19. The rule provided an exception for employees for whom vaccination would be harmful to their health, but it did not provide a religious exemption. Cagle alleged that she sought more time and guidance from Human Resources to submit a religious-exemption request. After receiving a response, she submitted the request, but Weill Cornell Medicine told her that the religious-exemption deadline had passed and that employees had to be vaccinated or resign. Her employment was terminated around September 2, 2021.

Cagle filed the complaint on August 15, 2022, seeking $20 million for lost wages, future earnings, and emotional damages. Weill Cornell Medicine moved to dismiss under Federal Rule of Civil Procedure 12(b)(6), which allows dismissal when a complaint does not state a legally sufficient claim. Cagle did not file a response, so the court treated the motion as unopposed, but it still reviewed whether the complaint was legally sufficient rather than granting the motion solely because Cagle did not respond.

Title VII claim

The court held that Cagle’s religious-discrimination claim was inadequately pleaded. To state a Title VII claim based on an employer’s failure to accommodate religious practices, a plaintiff must allege a genuine religious belief that conflicts with a work requirement, that the employer was informed of the belief, and that the plaintiff was disciplined for failing to follow the requirement.

The court found that Cagle’s statements that she had “religious beliefs” and practiced “non-vaccination” were conclusory. She did not provide factual allegations describing her beliefs or explaining how they conflicted with vaccination. The court also held that, even if Cagle had adequately alleged a religious belief, the complaint showed that the requested accommodation would have required Weill Cornell Medicine to violate the New York vaccination rule. The court concluded that Title VII did not require the employer to provide a blanket religious exemption allowing her to continue working in her position while unvaccinated.

The court rejected Cagle’s reliance on an earlier order that had temporarily blocked enforcement of the New York rule because that order had been vacated by the Second Circuit. The court noted, however, that an employer might be able to accommodate religious objections by assigning an employee to work that did not fall within the rule’s definition of covered “personnel.”

Americans with Disabilities Act claim

The court dismissed Cagle’s disability-discrimination claim because the complaint did not allege that she had a disability under the ADA or that she suffered an adverse employment action because of a disability. The court explained that religious faith is not itself an ADA disability. It also found that Cagle’s allegation that she had taken leave under the Family and Medical Leave Act did not establish a disability, because such leave may be taken for reasons unrelated to a physical or mental impairment.

Intentional infliction of emotional distress

Reading the complaint broadly, the court also considered a claim for intentional infliction of emotional distress under New York law. That claim requires extreme and outrageous conduct, an intent or reckless disregard regarding severe emotional distress, a causal connection, and severe emotional distress.

The court concluded that Cagle did not allege facts showing that Weill Cornell Medicine intended to cause her emotional distress or recklessly disregarded a substantial risk of doing so. Instead, the allegations showed that the employer acted to comply with the law. The court therefore held that Cagle did not state an emotional-distress claim.

Disposition and leave to amend

The court declined Weill Cornell Medicine’s request to dismiss the complaint with prejudice. Because Cagle was proceeding without a lawyer and the court could not rule out the possibility that she could plead facts supporting a valid claim, it granted her an opportunity to amend.

The conclusion states that the motion to dismiss is GRANTED without prejudice. Cagle was required to file any amended complaint within 60 days of the Opinion and Order. The Clerk of Court was directed to close the motion.