Compliance with New York’s Health‑Care Vaccine Rule Defeats Title VII Religious-Accommodation Claims Absent a Proposed Duty Change; Short-Term Leave Alone Does Not Plead an ADA Disability

Case: Cagle v. Weill Cornell Medicine, No. 24-2427 (2d Cir. Sept. 30, 2025)

Court: United States Court of Appeals for the Second Circuit (Walker, Carney, Sullivan, JJ.)

Disposition: Summary Order affirming dismissal under Rule 12(b)(6)

Note: As a “Summary Order,” the decision has no precedential effect under Second Circuit Local Rule 32.1.1, though it may be cited in accordance with FRAP 32.1.

Introduction

This appeal arises from the termination of plaintiff-appellant Sharme Cagle, a licensed practical nurse at Weill Cornell Medicine, for failing to get vaccinated against COVID-19 during the period when New York’s Department of Health emergency regulation, 10 N.Y.C.R.R. § 2.61, required vaccination of health-care personnel who could potentially expose patients or other staff. Proceeding pro se, Cagle sued under Title VII of the Civil Rights Act of 1964, alleging religious discrimination via denial of a reasonable accommodation, and under Title I of the Americans with Disabilities Act (ADA), alleging failure to accommodate a disability. The Southern District of New York (Liman, J.) dismissed her complaint. The Second Circuit affirmed.

The core issues on appeal were:

Whether Cagle plausibly alleged that Weill Cornell took an adverse employment action because of her religion by failing to accommodate a religious objection to vaccination.
Whether she plausibly alleged an ADA-qualifying disability to support a failure-to-accommodate claim.

The panel held that Cagle did not allege facts supporting even a minimal inference of religious discrimination, principally because she did not put her employer on notice that she sought a religious accommodation and, even if she had, the employer could not lawfully grant the requested accommodation to remain unvaccinated in her patient-facing role under § 2.61. The ADA claim also failed because a short, six-week medical leave—without details of impairment and substantial limitation—does not plead a disability.

Summary of the Opinion

Applying de novo review of a Rule 12(b)(6) dismissal, the Second Circuit concluded:

Title VII (religious accommodation): Cagle did not plausibly allege that Weill Cornell discriminated against her because of religion. She did not submit a timely religious exemption request or otherwise notify the employer that her objection to vaccination was religious in nature; her email communications objected to alleged “coercion” but did not state a religious basis. Further, even assuming she had requested an accommodation, the hospital could not legally grant a blanket religious exemption from vaccination to “covered personnel” under New York’s emergency rule, § 2.61. While an employer could consider accommodations removing an employee from the rule’s “covered personnel” category (e.g., changing duties), Cagle did not request any such alteration and instead sought to return to her same position, which included patient-facing responsibilities. Because granting her specific request would have violated state law, the complaint could not support an inference of discriminatory motive.
ADA (disability accommodation): Cagle failed to allege that she is disabled within the meaning of the ADA. A bare allegation of a six-week medical leave, without more, does not plausibly plead a physical or mental impairment that substantially limits a major life activity.

The court also noted that Cagle abandoned any challenge to the district court’s dismissal of her Bivens and § 1983 claims and to the denial of leave to file a second amended complaint.

Analysis

Precedents Cited and Their Influence

Twombly / Rule 12(b)(6) standard: Bell Atlantic Corp. v. Twombly, 550 U.S. 544, 570 (2007), frames the plausibility threshold. The court reiterated that complaints must allege “enough facts to state a claim to relief that is plausible on its face.” The decision relies on this pleading gatekeeping to assess whether Cagle’s allegations rise above speculation.
De novo review of dismissals: Bangs v. Smith, 84 F.4th 87, 95 (2d Cir. 2023), confirms the standard of review and the acceptance of well-pleaded facts as true, with inferences drawn in the plaintiff’s favor.
Pro se liberal construction: Sharikov v. Philips Med. Sys. MR, Inc., 103 F.4th 159, 166 (2d Cir. 2024), underscores that courts construe pro se pleadings to raise the strongest claims they suggest. Even with this generous lens, the panel found Cagle’s allegations wanting.
Title VII minimal inference requirement: Vega v. Hempstead Union Free Sch. Dist., 801 F.3d 72, 84–85 (2d Cir. 2015), and Buon v. Spindler, 65 F.4th 64, 79 (2d Cir. 2023), clarify that a plaintiff at the pleading stage need not make out a prima facie case but must provide facts supporting a minimal inference of discriminatory motivation. The court used this forgiving standard yet concluded that the complaint did not clear even this bar.
Failure-to-accommodate elements (religion): Knight v. Conn. Dep’t of Pub. Health, 275 F.3d 156, 167 (2d Cir. 2001), sets out the (traditional) prima facie elements for a Title VII failure-to-accommodate claim: (1) a bona fide religious belief conflicting with an employment requirement; (2) notice to the employer; and (3) discipline for noncompliance. The panel focused on the threshold notice element and found it absent.
COVID-19 health-care vaccine rule and limits on religious exemptions: We The Patriots USA, Inc. v. Hochul, 17 F.4th 266, 292 (2d Cir. 2021), and 17 F.4th 368, 370 (2d Cir. 2021), are pivotal. Those decisions upheld New York’s § 2.61 and emphasized that the rule did not permit religious exemptions for “covered personnel” (those who could expose patients or staff). Critically, they also recognized that employers could explore accommodations that remove an employee from the rule’s scope (e.g., reassignment), but not an accommodation that leaves a covered employee unvaccinated in a covered role. The panel relied directly on these holdings to conclude that Weill Cornell could not lawfully grant the accommodation Cagle sought.
ADA disability definition and duration factors: Woolf v. Strada, 949 F.3d 89, 93 (2d Cir. 2020), defines “disability” as an impairment substantially limiting a major life activity; Capobianco v. City of New York, 422 F.3d 47, 57 (2d Cir. 2005), highlights duration and long-term impact; and Colwell v. Suffolk Cnty. Police Dep’t, 158 F.3d 635, 646 (2d Cir. 1998), cautions that the mere fact of a hospital stay (or, by analogy, a brief leave) is insufficient without individualized allegations of substantial limitation. These authorities undergird the court’s conclusion that a six-week leave, without more, does not plead disability.

Legal Reasoning

1) Title VII Religious-Accommodation Claim

Lack of employer notice of religious conflict. A threshold defect was Cagle’s failure to allege that she told Weill Cornell her vaccination objection was religious. Her August 17, 2021 email merely asked about the exemption process. When informed on August 31 that the deadline had been August 1, she objected that she was being “coerced” into vaccination, but she never stated that her refusal was rooted in religious belief. Without notice, the employer had no duty to consider a religious accommodation, dooming the claim under Knight and the minimal-inference framework from Vega.

No duty to grant an accommodation that would violate law. The panel went further: even if Cagle had timely and expressly sought a religious accommodation, Title VII would not obligate Weill Cornell to provide an accommodation that violates state law. New York’s emergency rule, 10 N.Y.C.R.R. § 2.61, effective August 26, 2021, required vaccination of health-care “personnel” who, if infected, could expose patients or staff. The Second Circuit’s own We The Patriots decisions recognized that the regulation did not permit religious exemptions for such covered personnel. While employers remained free to accommodate by altering job duties or roles so that an employee would fall outside the rule’s coverage, Title VII “does not require … a blanket religious exemption allowing [employees] to continue working at their current positions unvaccinated.”

No proposed duty change. The district court had flagged this precise issue and invited an amended pleading addressing whether Cagle requested a reassignment or alteration of duties that would have removed her from the rule’s coverage. Instead, she sought to return to the same licensed practical nurse position—a role that included patient-facing functions—keeping her within § 2.61’s covered category. Because granting her requested accommodation would have forced the hospital to contravene state law, the complaint could not plausibly imply discriminatory motivation. In short, the “legal impossibility” of the requested accommodation defeats Title VII liability at the pleading stage.

Undue hardship not reached. Although Title VII religious-accommodation claims can involve an “undue hardship” inquiry, the court did not need to reach that question. An accommodation that would require an employer to break the law is not “reasonable” as a matter of law, and thus the claim fails even before one considers burdens or costs.

2) ADA Failure-to-Accommodate Claim

No adequately pleaded disability. To state a Title I ADA claim for failure to accommodate, a plaintiff must first allege she is disabled within the terms of the statute. Cagle alleged only that she took a six-week medical leave, offering no details about the nature of any impairment, the major life activities affected, or the degree and duration of limitation. The panel, citing Woolf, Capobianco, and Colwell, reiterated that short, temporary conditions—without allegations of substantial limitation—do not satisfy the ADA’s disability definition at the pleading stage. Because Cagle did not clear this threshold, the claim properly was dismissed.

3) Abandoned Issues

The court deemed abandoned any challenge to the dismissal of Cagle’s Bivens and § 1983 theories and to the district court’s denial of leave to file a second amended complaint, because she did not raise those issues on appeal.

Impact and Significance

Although this is a non-precedential summary order, it provides clear and practical guidance in a recurrent category of COVID-19-era employment litigation, especially for New York health-care employers and employees:

Religious-accommodation claims and legal constraints: The decision underscores a principle with broad application: Title VII does not require an employer to provide an accommodation that would violate governing law or regulation. When a state regulation like § 2.61 forecloses religious exemptions in defined roles, the only potentially viable accommodation is one that removes the employee from the regulation’s scope (e.g., reassignment away from patient-facing duties). Plaintiffs must plausibly allege they requested such a lawful accommodation; absent that, an inference of discriminatory motivation is implausible.
Pleading “notice” is essential: Employees must clearly communicate the religious nature of their conflict with a workplace requirement. General objections (e.g., “coercion”) unconnected to religious belief are insufficient to trigger the employer’s duty to consider accommodation under Title VII.
ADA threshold remains meaningful: The ADA’s definition of disability—though broadly construed after the ADA Amendments Act—still requires allegations of an impairment that substantially limits one or more major life activities. A short leave, standing alone, typically will not suffice. Plaintiffs should plead the impairment, the affected major life activity, and the nature and duration of limitation. The court’s reliance on pre- and post-ADAAA Second Circuit cases confirms that the “substantial limitation” inquiry remains a gatekeeper at the pleading stage.
Consistency with earlier Second Circuit COVID-19 rulings: The order is squarely aligned with We The Patriots, reinforcing that, during the effective period of § 2.61, covered New York health-care employers could not lawfully grant religious exemptions allowing unvaccinated covered employees to remain in covered roles. That alignment makes this order particularly persuasive for similar disputes arising from the same regulatory period.
Interplay with the evolving undue-hardship standard: After the Supreme Court’s decision in Groff v. DeJoy (not cited here), the Title VII “undue hardship” test is more demanding for employers. But this order illustrates that courts may dispose of claims without reaching undue hardship when the requested accommodation is unlawful. That analytic route is likely to persist regardless of how courts apply Groff in other contexts.
Practical pleading lessons: The district court expressly identified the duty-change accommodation pathway and invited allegations on that point. Plaintiffs who ignore such guidance risk dismissal with prejudice. On appeal, failure to brief issues (e.g., denial of further leave to amend) results in abandonment.

Complex Concepts Simplified

Summary Order: A non-precedential appellate disposition. It may be cited under specific rules but does not bind future panels.
Rule 12(b)(6) / Plausibility: Early-stage dismissal standard requiring enough factual content to make a claim plausible, not merely possible or conclusory.
Minimal inference of discrimination (Title VII pleading): At the complaint stage, a plaintiff need not prove a prima facie case but must allege facts permitting a reasonable inference that the adverse action was motivated, at least in part, by the protected trait (here, religion).
Religious accommodation: Title VII obligates employers to reasonably accommodate an employee’s bona fide religious beliefs that conflict with job requirements—unless doing so would impose an undue hardship or, as here, violate law.
“Covered personnel” under § 2.61: Health-care workers who could expose patients or staff if infected with COVID-19. For these personnel, the New York rule required vaccination and did not recognize religious exemptions. Employers could, however, consider reassignments that place the employee outside the rule’s scope.
ADA “disability”: A physical or mental impairment that substantially limits one or more major life activities, evaluated with attention to the nature, severity, and duration of the limitation. A brief, undocumented leave is generally insufficient to establish such a limitation.
Abandonment on appeal: Issues not argued on appeal are treated as forfeited and will not be considered by the appellate court.

Case Timeline (Key Facts)

August 1, 2021: Employer’s deadline to submit exemption requests (per record).
August 17, 2021: Cagle emails HR asking about the exemption submission process.
August 26, 2021: New York’s § 2.61 becomes effective, requiring vaccination of covered health-care personnel.
August 31, 2021: HR informs Cagle the exemption deadline passed; she will be placed on unpaid leave.
September 2021: Cagle is terminated for failing to get vaccinated.
District Court: Dismisses Title VII and ADA claims; identifies deficiency regarding lack of request for a duty-changing accommodation; denies leave to file a second amended complaint.
September 30, 2025: Second Circuit affirms in a non-precedential summary order.

Conclusion

Cagle v. Weill Cornell Medicine reinforces two central points in pandemic-era employment law disputes, especially in the New York health-care setting:

Title VII: A plaintiff must plausibly allege that the employer knew of a religious conflict and nonetheless failed to provide a lawful accommodation. Where state law barred religious exemptions for covered personnel, an employee’s request to remain unvaccinated in a patient-facing role is not a “reasonable” accommodation the employer can grant. Plaintiffs must instead allege (and request) duty changes that remove them from the regulation’s scope.
ADA: A short, unspecified medical leave does not, without more, plead a disability. A viable claim requires concrete allegations of an impairment and its substantial limitations on major life activities.

While non-precedential, the order aligns with controlling Second Circuit and Supreme Court principles and offers a practical roadmap for pleading and evaluating Title VII religious-accommodation and ADA disability claims arising from COVID-19 vaccine requirements in regulated health-care environments. The overarching takeaway is straightforward: employers are not required to accommodate in ways that contravene law, and plaintiffs must plausibly plead both notice and a lawful accommodation path to survive dismissal.