Smith v. St. Joseph's Medical Center

Background

Chantal Smith, proceeding without a lawyer and without prepaying filing fees, sued St. Joseph’s Medical Center (SJMC), her former employer, and Margaret Cusumano, identified as the head of SJMC’s nursing department. Smith asserted claims under Title VII of the Civil Rights Act of 1964 for discrimination based on race, color, religion, and sex, as well as pattern-or-practice discrimination, retaliation, and harassment or a hostile work environment.

Smith’s claims arose from her refusal to receive a COVID-19 vaccine required by a New York State Department of Health mandate. She requested a religious accommodation, and SJMC initially allowed her to continue working while the legality of the mandate was under judicial review. After a Second Circuit decision determined that SJMC could not grant a religious exemption, SJMC placed Smith on unpaid administrative leave and later treated her as having voluntarily resigned because she had not complied with the mandate. Smith also alleged that she had reported SJMC to government-related entities concerning her sister’s treatment and had written up supervisors and Cusumano regarding an unspecified policy.

Summary-judgment ruling

The defendants moved for summary judgment. Smith did not oppose the motion, even after receiving an extension of time. The court independently reviewed the record because Smith was representing herself.

The court granted summary judgment on Smith’s Title VII religious-discrimination claim. Even assuming Smith established the initial requirements for a discrimination claim, the court held that defendants gave a legitimate, nondiscriminatory reason for the adverse employment action: Smith’s failure to comply with the vaccination mandate. The court found no evidence from which a reasonable jury could conclude that this reason was a pretext for religious discrimination. The court also granted summary judgment on any race-, color-, or sex-discrimination claims because the allegations and evidence concerned only religion.

The court granted summary judgment on the pattern-or-practice claim because Smith presented no specific discriminatory incidents, statistics, or other evidence showing that discrimination was SJMC’s regular practice. It granted summary judgment on the retaliation claim because Smith did not provide facts showing when or why she made her complaints, whether defendants knew of protected activity, or a causal connection between those complaints and the employment action. It also granted summary judgment on the harassment or hostile-work-environment claim because Smith offered no factual allegations or evidence showing a workplace permeated by sufficiently severe or pervasive discriminatory conduct.

Disposition and effect

The court granted the motion for summary judgment. It did not decide whether Cusumano could be individually liable because it resolved all claims in defendants’ favor; it noted that individuals are not subject to liability under Title VII. The Clerk was instructed to terminate the motion and close the case.

The court also certified under 28 U.S.C. § 1915(a)(3) that any appeal would not be taken in good faith and denied permission to appeal without prepaying filing fees. Judge Vincent L. Briccetti signed the opinion and order on May 7, 2024.