Bobadilla v. New York City Health and Hospitals Corporation

Background

Jatnna Bobadilla worked for the New York City Health and Hospitals Corporation as a Confidential Investigator beginning in 2012 and became an Associate Confidential Investigator in 2014. She is Jewish and alleged that her religious beliefs prevented her from receiving COVID-19 vaccines.

New York required covered healthcare workers to receive an available COVID-19 vaccine unless they received a medical or religious exemption. The state later removed religious exemptions, and a federal healthcare-facility requirement also required covered staff to be vaccinated. Bobadilla requested religious exemptions from the corporation’s vaccination policy. From September 30, 2021, through February 22, 2022, the corporation allowed her to perform her essential job duties remotely.

The corporation later told Bobadilla that she had to receive a booster dose by February 21, 2022. It said employees who did not comply would first be placed on unpaid leave and then terminated. Bobadilla requested a religious exemption from the booster requirement. The corporation placed her on unpaid leave beginning March 1, 2022, and later terminated her employment. An administrative law judge subsequently awarded her unemployment insurance benefits. The corporation did not appeal that decision.

Claims and Motion

Bobadilla sued under Title VII of the Civil Rights Act of 1964, 42 U.S.C. § 1983, the First Amendment’s Free Exercise Clause, the Supremacy Clause, the Fourteenth Amendment’s Due Process Clause, the New York State Human Rights Law, and the New York City Administrative Code. She sought reinstatement, financial losses, damages, an injunction, and attorney’s fees.

The corporation 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. At this stage, the court accepted the complaint’s factual allegations as true and drew reasonable inferences in Bobadilla’s favor, but it did not accept legal conclusions without supporting facts.

Title VII Claims

The court dismissed without prejudice Bobadilla’s Title VII claim that she was terminated because of her religion. Title VII prohibits employment discrimination based on religion. The court found that Bobadilla alleged she was terminated for failing to comply with the vaccination mandate, but did not allege facts creating a plausible inference that her religion was a motivating factor, that the corporation’s stated reason was a cover for discrimination, or that the circumstances showed intentional discrimination.

The court also dismissed without prejudice her Title VII reasonable-accommodation claim. Title VII generally requires an employer to reasonably accommodate an employee’s religious practices unless doing so would impose an undue hardship on the employer. The court noted that the corporation had allowed Bobadilla to work remotely for five months, but concluded that the complaint failed to state a claim because the corporation asserted that allowing an unvaccinated employee to continue working would violate state requirements and create an undue hardship.

Constitutional Claims Under Section 1983

Section 1983 provides a method for seeking relief for certain constitutional violations caused by a state or local government entity or official. The court dismissed without prejudice Bobadilla’s Free Exercise Clause claim. It found that she did not allege facts showing that the vaccination mandate was not neutral or generally applicable. The court therefore applied rational-basis review, which asks whether the mandate was rationally related to a legitimate government interest. It concluded that protecting public health and safety satisfied that standard.

The court dismissed with prejudice Bobadilla’s Supremacy Clause claim. It relied on precedent holding that the mandatory vaccination requirement was not preempted by Title VII and did not violate the Supremacy Clause. The court also stated that the Supremacy Clause does not itself create a federal cause of action. Because amendment would be futile, this claim could not be reasserted in an amended complaint.

The court dismissed without prejudice Bobadilla’s Due Process Clause claim. It concluded that she received a process for requesting a vaccination exemption, was permitted to work remotely until that arrangement created an undue hardship, received an additional 60-day unpaid-leave period, and had notice and an opportunity to respond before her employment ended.

State and City Claims

The court declined to exercise supplemental jurisdiction over Bobadilla’s claims under the New York State Human Rights Law and the New York City Administrative Code because it had dismissed all claims over which it had original federal jurisdiction. Those state and city claims were dismissed without prejudice for lack of subject-matter jurisdiction.

Disposition

The court granted the corporation’s motion to dismiss, and the complaint was dismissed without prejudice. The order separately dismissed the Supremacy Clause claim with prejudice. The court allowed Bobadilla to move for permission to file an amended complaint, together with a proposed amended complaint, within 30 days of the order.