Grimes v. New York Presbyterian Hospital

Background

Stephanie Grimes, a former Quality Management Specialist at The New York and Presbyterian Hospital (NYPH), alleged that NYPH deemed her to have voluntarily resigned after she did not receive a COVID-19 vaccination required under a New York State Department of Health mandate. Grimes alleged that she had worked remotely for approximately 15 years, except for attendance at a monthly department meeting, and that NYPH had previously approved a religious exemption under its own policy. After the state mandate barred blanket religious exemptions, NYPH denied Grimes’s request for a religious accommodation and required her to become vaccinated by November 29, 2021. When she did not do so, NYPH removed her access to its system and deemed her voluntarily resigned.

Grimes asserted twelve claims under Title VII of the Civil Rights Act of 1964, the Americans with Disabilities Act (ADA), the Age Discrimination in Employment Act (ADEA), and New York common law. NYPH moved to dismiss all claims under Federal Rule of Civil Procedure 12(b)(6), which tests whether a complaint alleges enough facts to state a legally plausible claim.

Claims Allowed to Proceed

The court denied NYPH’s motion to dismiss Grimes’s Title VII religious-discrimination claim, Claim Ten. The court held that Grimes plausibly alleged that she sincerely held religious beliefs preventing vaccination, needed an accommodation, and was deemed to have resigned after NYPH declined to provide one. Although exempting her from the mandate while requiring covered work would have created an undue hardship, the court held that the allegations did not establish at the pleading stage that allowing her to continue working remotely, with weekly testing, would have caused undue hardship. The court noted that the state mandate could potentially permit an accommodation that removed an employee from the definition of covered personnel.

The court also denied NYPH’s motion to dismiss Grimes’s ADA unlawful-medical-examination claim, Claim Three. Grimes alleged that NYPH asked questions about her medical condition and whether it arose before or after the deadline for medical-exemption applications. The court explained that the ADA generally bars disability-related medical inquiries unless they are job-related and consistent with business necessity. Because NYPH had not yet shown that its inquiries were vital to its business and no broader or more intrusive than necessary, the court concluded that the claim was plausible at this stage.

Claims Dismissed

The court granted NYPH’s motion to dismiss Grimes’s ADA disability-discrimination claim, Claim One, because she did not plausibly allege that NYPH knew or reasonably should have known that she had a disability covered by the ADA before the relevant deadline. Her general inquiries about a possible medical exemption were insufficient, and she did not allege that she provided NYPH with her doctor’s letter or other information describing her condition. The court also granted dismissal of Claim Two, holding that the alleged failure to engage in an interactive accommodation process is not an independent ADA claim and that Grimes’s accommodation allegations were addressed within Claim One.

The court granted dismissal of Claim Seven, the ADEA age-discrimination claim, because Grimes did not plausibly allege that age was the reason she was terminated. Alleging that younger employees replaced her was not enough without additional supporting facts. The court also granted dismissal of Claim Eight, the ADEA retaliation claim, because Grimes did not allege that she opposed an employment practice made unlawful by the ADEA.

The court granted dismissal of Claim Four, the ADA retaliation claim, and Claim Eleven, the Title VII religious-retaliation claim. It concluded that Grimes’s own allegations showed that NYPH had announced the consequences of failing to comply with the vaccination policy before she requested accommodations, so she did not plausibly allege that her protected activity was the cause of her separation. The court granted dismissal of Claim Nine, the Title VII religious-hostile-work-environment claim, because the complaint lacked specific allegations of severe or pervasive harassment motivated by religious hostility. It granted dismissal of Claim Six, the ADEA age-hostile-work-environment claim, because the alleged conduct was not plausibly connected to age.

The court granted dismissal of Claim Five, the ADA medical-information-disclosure claim, because the complaint and attached emails showed that Grimes did not actually disclose the medical information she alleged NYPH had improperly disseminated. Finally, the court granted dismissal of Claim Twelve, the New York intentional-infliction-of-emotional-distress claim. The court held that NYPH’s conduct, as alleged, was intended to comply with the state mandate and was not extreme or outrageous under New York law. The conclusion states that NYPH’s motion to dismiss was denied as to Claims Ten and Three and granted as to all other claims. Judge Mary Kay Vyskocil directed the Clerk to terminate the motion docket entry.