Vangas v. Montefiore Medical Center
823 F.3d 174
| 2d Cir. | 2016Background
- Mirelle Vangas, a utilization management analyst employed by Montefiore Medical Center (MMC), took FMLA leave for cancer in March 2010 and was terminated on August 30, 2010 after exhausting leave and not being medically cleared to return.
- In early August Vangas asked to work from home; by late August she experienced new, worsening symptoms and on August 29 notified her supervisor she would not return the next day and could not give a return date.
- Vangas sued MMC and two supervisors under the New York State Human Rights Law (NYSHRL) and New York City Human Rights Law (NYCHRL) for failure to accommodate her disability; she and her husband also sued under COBRA for improper notice of continuation coverage.
- At trial a jury found for Vangas on the NYSHRL claim and awarded damages; the district court denied defendants’ renewed JMOL and new-trial motions but reduced damages by remittitur.
- The Second Circuit reversed as to the NYSHRL, holding Vangas requested indefinite leave (not a reasonable accommodation) and was not able to perform essential functions at termination; it affirmed dismissal of the NYCHRL claim for lack of NYC impact and affirmed dismissal of the COBRA claims.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether MMC refused a reasonable accommodation in violation of NYSHRL | Vangas: MMC refused to accommodate (including work-from-home) and failed to engage in interactive process | MMC: At termination Vangas was not medically cleared and requested indefinite leave, which is not a reasonable accommodation | Reversed for defendants: no JMOL for plaintiff because she needed indefinite leave and could not perform essential functions at that time; termination did not violate NYSHRL |
| Relevance/feasibility of earlier work-from-home request | Vangas: prior request to work remotely shows accommodation was possible | MMC: even if requested earlier, Vangas’s later health decline made any accommodation impossible at termination | Held: earlier request immaterial—by termination date she could not perform job even remotely, so no actionable denial of accommodation |
| Applicability of NYCHRL to nonresident worker (impact test) | Vangas: protections apply because her work (phone contacts with NYC patients) affected NYC residents | MMC: Vangas worked, was supervised, and was terminated in Yonkers; her NYC contacts were too tangential | Affirmed for defendants: dismissal proper—plaintiff’s termination had no impact in NYC under Hoffman impact test |
| Sufficiency of COBRA notice when town name was abbreviated | Vangas: incorrect addressing meant notices were not properly delivered | MMC: notices were mailed to last known address, zip code was correct, and procedures showing transmission to administrator were followed | Affirmed for defendants: mailing was reasonably calculated to reach recipients; COBRA requirements satisfied |
Key Cases Cited
- Noll v. Int’l Bus. Machs. Corp., 787 F.3d 89 (2d Cir.) (discusses NYSHRL elements and accommodation analysis)
- Jacobsen v. N.Y.C. Health & Hosp. Corp., 11 N.E.3d 159 (N.Y.) (NYSHRL interpreted with focus on employee’s accommodation request)
- Romanello v. Intesa Sanpaolo, S.p.A., 998 N.E.2d 1050 (N.Y.) (indefinite leave is not a reasonable accommodation)
- Graves v. Finch Pruyn & Co., 457 F.3d 181 (2d Cir.) (finite, specific short extensions may be reasonable depending on context)
- Hoffman v. Parade Publ’ns, 933 N.E.2d 744 (N.Y.) (NYCHRL impact test for nonresidents)
- Stampf v. Long Island R.R. Co., 761 F.3d 192 (2d Cir.) (standard of review for JMOL)
- Crotty v. Dakotacare Admin. Servs., Inc., 455 F.3d 828 (8th Cir.) (COBRA notice sufficient if reasonably calculated to reach recipient)