Mumin v. The City of New York

Background

Ayana F. Mumin, described in the opinion as a former New York City Department of Correction captain, brought claims against the City of New York and other defendants. According to the defendants’ submission, Mumin’s employment ended because she did not comply with the City’s vaccination mandate. Her Second Amended Complaint alleges that defendants failed to accommodate her religious beliefs and discriminated against her based on religion and sex under federal, state, and local law, as well as the Fourteenth Amendment. The Second Amended Complaint also added a claim under 42 U.S.C. § 1985.

Motion to Stay Discovery

The defendants asked the court to stay, or pause, discovery until the court resolved their forthcoming motion to dismiss. They argued that discovery would be extensive because Mumin had indicated that she planned to depose several City employees and would likely seek documents and testimony from policy witnesses, fact witnesses, Equal Employment Opportunity Office personnel, high-level managers, and a former Department of Correction commissioner who was named as a defendant. They also argued that the decisions at issue were documented in writing, making the risk of lost evidence minimal, and that Mumin would not suffer substantial prejudice from a pause.

The defendants further argued that their motion to dismiss was strong, citing their defense of similar vaccination-mandate cases and two earlier motions to dismiss in this case. They asserted that Mumin did not challenge the mandate itself but challenged the accommodation process and alleged sex and religious discrimination. The opinion presents these points as the defendants’ arguments; it does not decide whether those arguments ultimately prevail.

Court’s Analysis and Ruling

The court applied the standard that discovery may be stayed for “good cause.” It considered the expected breadth of discovery, the likely prejudice to Mumin, and the strength of the anticipated motion to dismiss. The court found that: (1) discovery would likely be significant given the nature of the claims; (2) a stay would not substantially prejudice Mumin; and (3) the defendants had raised strong arguments supporting dismissal, both in their letter and in their prior motions to dismiss.

The court therefore granted the motion to stay discovery pending resolution of the motion to dismiss. This order paused discovery; it did not resolve the motion to dismiss or decide the merits of Mumin’s claims.