St. Hillaire v. Montefiore Medical Center

Background

Donna St. Hillaire, proceeding without a lawyer and without paying the filing fee, sued Montefiore Medical Center. She alleged that Montefiore, her former employer, discriminated against her because of her Apostolic Pentecostal Christian beliefs, violating Title VII of the Civil Rights Act of 1964 and the First Amendment.

St. Hillaire began working as a registered nurse at Montefiore’s hospital complex in May 2013. After becoming a Patient Safety Manager, she declined the influenza vaccine based on her religious beliefs. In September 2021, she told her supervisor that she did not intend to receive a COVID-19 vaccine and requested a religious accommodation or exemption. While Montefiore reviewed the request, it required weekly testing, placed her on unpaid leave, and gave her an opportunity to submit additional supporting materials. Montefiore terminated her employment on October 30, 2021. St. Hillaire also alleged that Montefiore had provided medical accommodations and at least two religious accommodations to other patient-facing employees.

Montefiore moved to dismiss under Rule 12(b)(6), which allows dismissal when a complaint does not state a legally sufficient claim.

Title VII claim

The court explained that Title VII generally requires an employer to reasonably accommodate an employee’s genuine religious practice unless the accommodation would create an undue hardship for the employer. But St. Hillaire requested only a religious exemption from New York’s COVID-19 vaccination mandate. The court relied on Second Circuit decisions holding that the mandate barred religious exemptions, although an employer could potentially accommodate an employee by moving the employee out of the mandate’s definition of covered personnel.

St. Hillaire did not allege that she requested an arrangement removing her from the mandate’s coverage. Because she was a registered nurse covered by the mandate, the court concluded that granting the requested exemption would have violated New York law and imposed an undue hardship on Montefiore.

The court also addressed St. Hillaire’s apparent claim that Montefiore treated other employees differently. It held that her allegation that at least two patient-care employees received religious accommodations did not include facts plausibly showing that Montefiore treated her differently because of her religion. The court therefore dismissed the Title VII claim.

First Amendment claim

The court dismissed the First Amendment claim because Montefiore was a private party rather than a government actor. The court explained that the Constitution regulates government conduct, not conduct by private parties, and that St. Hillaire could not use the constitutional claim against Montefiore.

State and local claims

Reading the complaint liberally because St. Hillaire was proceeding without a lawyer, the court construed it as also asserting claims under the New York State Human Rights Law and the New York City Human Rights Law. After dismissing the Title VII and First Amendment claims—the only claims supporting the court’s original federal jurisdiction—the court declined to exercise supplemental jurisdiction over the state and local claims.

The court dismissed those state and local claims without prejudice to refiling in the proper forum.

Disposition

Judge Philip M. Halpern granted Montefiore’s motion to dismiss. The court dismissed the Title VII and First Amendment claims with prejudice because amendment would be futile. It dismissed any state and local law claims without prejudice to refiling in the proper forum, directed the clerk to terminate the motion and close the case, and directed that a copy of the opinion and order be mailed to St. Hillaire.