Selected items posted on the Internet during the week ending August 21, 2026 and reported by NYPPL pro bono which may be of interest to readers

New York Health Policy Monitor Published by I.H. Michaels, LLC, an independent health policy and data analytics practice is informational and does not constitute legal or policy advice. For questions, pricing for organizations, or data services inquiries, contact: info@ihmichaelsllc.com

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Appellate Division finds employment agreement did not provide for certain health insurance premium payment claimed by retiree

Plaintiff, the school district's former District Superintendent, and the School District [District] had entered into an employment agreement pursuant to which Plaintiff was hired as the District's superintendent. 

As relevant in the instant litigation, the employment agreement provided that Plaintiff and her qualified dependents "shall be eligible, during retirement, for continuing health, dental and vision insurance coverages under the plan(s) available through the District" and that the District "will pay one hundred percent (100%) of the premiums of such coverage."

Upon her retirement in 2017, Plaintiff obtained retiree health insurance through the District's plan. Several years later, Plaintiff applied for Medicare Part B—an insurance plan not available through the District—and paid premiums for that coverage. Plaintiff then asked District for reimbursement for the Medicare premiums she had paid. 

The District denied Plaintiff's request on the ground that the District's plan did not allow individuals who received 100% of the retiree health coverage paid for by the District to receive reimbursement for Medicare Part B premiums. 

Claiming "breach of contract", Plaintiff commenced the instant action seeking reimbursement of Medicare premiums paid by Plaintiff and a declaration that the District was required to pay such premiums for her and her qualified dependents'. Supreme Court granted District's motion for summary judgment dismissing the complaint and  Plaintiff appealed.

The Appellate Division said that the District met its initial burden on the motion inasmuch as it had submitted the employment agreement, Plaintiff's deposition testimony, the District's policy documents, and its health plan documents ... all of which established that the employment agreement did not require the District to reimburse Plaintiff for the premiums for Medicare Part B, which was not an insurance plan offered by the District. 

The Appellate Division's decision noted that the agreement provided that Plaintiff was entitled to "continuing health, dental and vision insurance coverages under the plan(s) available through the District" but Plaintiff sought "reimbursement for premiums under a Medicare plan not provided through the District". 

Accordingly, the Appellate Division held that Plaintiff was not entitled to reimbursement of the premiums for the Medicare Part B coverage Plaintiff had purchased.

Click HERE to access the Appellate Division's decision posted on the Internet.

Claimant denied unemployment insurance benefits after failing to obtain the COVID-19 vaccine

The Workers' Compensation Benefits Appeals Board's found that Claimant for unemployment insurance benefits was disqualified from receiving such insurance benefits "because she voluntarily left her employment without good  cause" by failing to obtain the COVID-19 vaccine as required by her employer, the New York State Unified Court System.

The text of the Appellate Division's ruling sustaining the decision of the Workers' Compensation Appeals Board is set out below:

In the Matter of the Claim of Roxalana T. Jordan, Appellant. 

Commissioner of Labor, Respondent.

Decided and Entered: July 9, 2026

CV-24-0840

Calendar Date: May 27, 2026

Before: Aarons, J.P., Pritzker, Ceresia, Fisher And Mcshan, JJ.

Roxalana T. Jordan, Brooklyn, appellant pro se.

Letitia James, Attorney General, New York City (Dennis A. Rambaud of counsel), for respondent.

Aarons, J.P.

Appeal from a decision of the Unemployment Insurance Appeal Board, filed October 12, 2023, which ruled, among other things, that claimant was disqualified from receiving unemployment insurance benefits because she voluntarily left her employment without good  cause.

In September 2021, claimant was notified by her employer, the Unified Court System, that all judges and nonjudicial personnel were required to obtain a COVID-19 vaccine by September 27, 2021 in order to continue employment, unless otherwise approved for an exemption due to a medical reason or sincerely held religious belief. Claimant submitted a written religious exemption request seeking to be exempt from the vaccination requirement, which request the employer denied. Claimant thereafter submitted a medical exemption request, which request was also denied. In addition, claimant submitted an amended religious exemption request, which was not considered by the employer. Claimant's employment was ultimately terminated for failure to obtain the COVID-19 vaccine, prompting her to apply for unemployment insurance benefits.

The Department of Labor, as is relevant here, issued an initial determination finding that claimant was disqualified from receiving unemployment insurance benefits because she voluntarily left her employment without good cause. Following various hearings, an Administrative Law Judge sustained that determination, and that decision was affirmed by the Unemployment Insurance Appeal Board in a decision filed October 12, 2023. Claimant appeals.

We affirm. "Whether a claimant has good cause to leave employment, and whether their conduct is motivated by a sincerely held religious belief, are factual issues for the Board to resolve, and its determination will be upheld if supported by substantial evidence" (Matter of Gardner [Commissioner of Labor], 238 AD3d 1464, 1465-1466 [3d Dept 2025] [citations omitted]; see Matter of Palmieri [Commissioner of Labor], 243 AD3d 970, 971-972 [3d Dept 2025]; Matter of Salloum [Commissioner of Labor], 238 AD3d 1394, 1396 [3d Dept 2025]; see also Frazee v Illinois Dept. of Employment Sec., 489 US 829, 833 [1989]). In her initial written religious exemption request, claimant stated, "In God We Trust. My religious beliefs and practices do[ ] not require or mandate or force[ ] the use of legal or illegal drugs." At the hearing, claimant explained that her religion — one she declined to disclose — believes in "self-autonomy of the body" and not being forced to take illegal or legal drugs. Claimant acknowledged, however, that her religion does not prohibit her from being vaccinated but, rather, it is her choice whether to be vaccinated. Claimant further testified that she amended her religious exemption request once her initial request was denied, asserting a generalized concern about the content of the vaccine. No further information about her religious beliefs or tenets of her undisclosed religion was provided.

Regarding her request for a medical exemption, claimant failed to provide any requisite documentation from any medical health professional, asserting only that the COVID-19 vaccine is contraindicated and ill-advised based upon "recent conversations with [her] medical professionals" given her "current heath condition and status" — a medical condition she deemed unnecessary to disclose. Given the vague and generalized information in support of her religious and medical exemption requests, and deferring to the Board's credibility assessments, the record supports the Board's findings that claimant did not establish that her refusal to comply with the employer's COVID-19 vaccine mandate was rooted in a sincerely held religious belief but, rather, was based on personal and secular reasons (see Matter of Tandian [Commissioner of Labor], 239 AD3d 1105, 1106-1107 [3d Dept 2025], lv denied 44 NY3d 910 [2026]; Matter of Gardner [Commissioner of Labor], 238 AD3d at 1466; Matter of Ocasio [City Sch. Dist. of the City of N.Y.-Commissioner of Labor], 237 AD3d 1412, 1415-1416 [3d Dept 2025], lv denied 44 NY3d 906 [2025]) and, further, that there was insufficient medical information to assess the basis or validity for the requested medical exemption (see Matter of Smith [Roswell Park Cancer Inst. Corp.-Commissioner of Labor], 227 AD3d 1344, 1346-1347 [3d Dept 2024]). Accordingly, substantial evidence supports the Board's decision that claimant voluntarily left her employment without good cause (see Matter of Des Abbayes [Commissioner of Labor], 239 AD3d 1199, 1200-1201 [3d Dept 2025]; Matter of Cosma [Memorial Sloan Kettering Cancer Ctr.-Commissioner of Labor], 236 AD3d 1121, 1123-1124 [3d Dept 2025]). Claimant's remaining contentions are either not properly raised in this proceeding or are without merit.

Pritzker, Ceresia, Fisher and McShan, JJ., concur.

ORDERED that the decision is affirmed, without costs.