Nyamoti v. The Mount Sinai Hospital

Background

Enock Nyamoti, representing himself, sued The Mount Sinai Hospital, NYC Health + Hospitals, and the Physician Affiliate Group of New York (PAGNY). He alleged that the defendants sought to compel him to receive a COVID-19 vaccine over his religious objections. Mount Sinai had been terminated as a defendant in the court’s August 8, 2022 Opinion and Order. The pending motion was filed by NYC Health and PAGNY.

Defendants moved for judgment on the pleadings under Federal Rule of Civil Procedure 12(c). That motion asks the court to decide the case based on the completed pleadings. The court explained that the standard is the same as for a motion to dismiss for failure to state a claim under Rule 12(b)(6): the court accepts the complaint’s factual allegations as true but requires enough facts to make a claim for relief plausible. Although Nyamoti did not respond to the motion despite a warning that it would be treated as unopposed, the court independently reviewed whether the motion had a sufficient basis.

Court’s Analysis

The first claim alleged that Defendants violated a temporary restraining order entered by a judge in the Northern District of New York. The court held that the claim failed because the temporary restraining order was no longer in effect and the later preliminary injunction had been vacated on appeal.

Nyamoti also alleged that the vaccine requirement violated the First Amendment’s Free Exercise Clause, which protects religious exercise. The court held that, even accepting the allegations in the Amended Complaint as true, Nyamoti had not stated a plausible claim in light of precedent concerning the constitutionality of COVID-19 vaccine mandates, including mandates without religious exemptions.

The court stated that its August 8, 2022 Opinion and Order had found Nyamoti’s remaining claims under the Supremacy Clause, Title VII, the New York State Human Rights Law, the New York City Human Rights Law, and 42 U.S.C. § 1985(3) waived for lack of development. The court had invited him to submit another amended complaint developing those claims, but he did not do so. The court therefore concluded that he failed to meet the minimum pleading requirements for the remaining claims.

Disposition

For these reasons, Judge J. Paul Oetken granted Defendants’ motion for judgment on the pleadings. The Clerk of Court was directed to close the motion at ECF No. 71 and to close the case. The opinion does not state that the ruling was with or without prejudice.