Plaintiff was terminated from her position with New York State Unified Court System [Employer] as the result of her failure to comply with Employer's COVID-19 vaccination requirement after Employer denied her request for a religious exemption.
Employee than sued Employer alleging Employer violated Title VII of the Civil Rights Act of 1964 by failing to accommodate her religion beliefs.
The United States District Court for the Eastern District of New York granted partial summary judgment for Plaintiff, holding that there was no genuine dispute that the Plaintiff had made out a prima facie case of religious discrimination—resting in large part on statements made by the Employer during discovery—and that the Employer did not demonstrate that granting an accommodation would constitute an undue hardship.
Employer appealed, contending that the Federal District Court failed to modify the prima facie test for failure-to-accommodate religion claims in light of EEOC v Abercrombie & Fitch Stores, Inc., 575 U.S. 768.
The Second Circuit said that it agreed that Abercrombie abrogated the Second Circuit's earlier Title VII precedents. However, because the Federal District Court "improperly deemed statements in the discovery record to be judicial admissions" the Second Circuit vacated the District Court's decision and remanded the matter "for further proceedings" consistent with its instant opinion.
Click HERE to access the opinion of Circuit Court of Appeals, Second Circuit, posted on the Internet.