Mora v. New York State Unified Court System

Background

Frank Mora, whom the opinion identifies as a duly appointed City Court Judge for the City of Poughkeepsie, sued the New York State Unified Court System’s Office of Court Administration (OCA) and several individual defendants. He alleged violations of Title VII of the Civil Rights Act of 1964 and the First and Fourteenth Amendments arising from OCA’s COVID-19 vaccine requirement and its denial of his request for a religious exemption.

Under the policy, OCA judges and employees had to provide proof of vaccination or obtain a medical or religious exemption. Mora submitted a religious-exemption request and an affidavit describing his Catholic beliefs and opposition to vaccination. After the Vaccine Exemption Committee requested additional information, Mora submitted a supplemental response. The committee denied the request and directed him to provide proof of a first vaccine dose. Mora alleged that officials then restricted his courthouse access, reassigned some of his duties, and referred him to the New York State Commission on Judicial Conduct. He also alleged that other employees received religious exemptions and that the defendants treated him differently.

The vaccine requirement was repealed effective February 17, 2023, and Mora’s restrictions on courthouse access were lifted. He sought damages and other relief, including an order reversing the exemption denial and requiring an exemption from future vaccine mandates. The defendants moved to dismiss under Rules 12(b)(1), which addresses the court’s subject-matter jurisdiction, and 12(b)(6), which addresses whether a complaint plausibly states a legal claim.

Rulings on Requested Relief and Claims Against OCA

The court dismissed Mora’s request for injunctive relief. Because the vaccine requirement had been repealed and Mora had been restored to his full in-person duties, the court found no ongoing violation requiring prospective relief. The court also found that Mora’s concern that the prior denial might affect him during a future public-health emergency was speculative.

The court dismissed Mora’s Section 1983 claim for damages against OCA because the New York State Unified Court System is an arm of the State and protected by Eleventh Amendment sovereign immunity. The court concluded that New York had not waived that immunity and Congress had not removed it through Section 1983.

The court also dismissed Mora’s Title VII claim against OCA. Title VII’s definition of “employee” excludes certain appointed policymaking officials. Relying on the Supreme Court’s treatment of appointed state judges as policymaking officials, the court concluded that Mora was not an “employee” covered by Title VII because he was an appointed judge who exercised discretion concerning matters of public importance.

Claims Against the Individual Defendants

Mora sued the individual defendants under Section 1983 in their personal capacities. The court declined to dismiss the claims against the Vaccine Exemption Committee members for lack of personal involvement at the pleading stage, reasoning that the allegations allowed a reasonable inference that any or all of them might have participated in reviewing and denying Mora’s request. The court nevertheless dismissed the constitutional claims for failure to state a claim.

For the First Amendment free-exercise claims, the court held that the vaccine policy, as Mora alleged it was applied, was neutral and generally applicable. The policy applied to court-system judges and employees and did not single out religious objectors. The exemption process was viewed as permitting officials to assess whether claimed beliefs were sincerely held and religious in nature, not as favoring secular conduct or particular religions. The court therefore applied rational-basis review and concluded that the policy was rationally related to the legitimate interest in increasing vaccination rates and protecting people interacting with the court system. The free-exercise claims were dismissed.

The court dismissed Mora’s First Amendment retaliation claim against Lawrence Marks. Even assuming that Mora’s exemption application or related complaints were protected activity and that they caused the referral, the court held that the referral to the Commission on Judicial Conduct was not sufficiently adverse because the commission had not completed its investigation or imposed discipline.

The court dismissed the Fourteenth Amendment equal-protection claim against the Vaccine Exemption Committee members. Mora had not plausibly alleged that the people who received exemptions were similarly situated, or that his denial resulted from religious discrimination or another impermissible motive. The court also stated that because the free-exercise challenge failed and the policy survived rational-basis review, an equal-protection claim based on the same conduct likewise failed.

Disposition

Judge Vincent L. Briccetti granted the motions to dismiss. The Clerk was directed to terminate the motions and close the case. The opinion does not state that the dismissals were with or without prejudice.