Arbeeny v. Cuomo

CourtDistrict Court, E.D. New York
DecidedJanuary 10, 2025
Docket1:22-cv-02336
StatusUnknown

This text of Arbeeny v. Cuomo (Arbeeny v. Cuomo) is published on Counsel Stack Legal Research, covering District Court, E.D. New York primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Arbeeny v. Cuomo, (E.D.N.Y. 2025).

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF NEW YORK

DANIEL N. ARBEENY, as the Administrator of the Estate of NORMAN ARBEENY (deceased) individually, Plaintiff SEAN S. NEWMAN, as the Administrator of the Estates of MICHAEL J. NEWMAN (deceased) and DOLORES D. NEWMAN (deceased) individually, and on behalf of others Plaintiffs, MEMORANDUM AND ORDER v. 22-cv-02336 (LDH) (LB) ANDREW M. CUOMO, MELISSA DEROSA, HOWARD A. ZUCKER, M.D., GREATER NEW YORK HOSPITAL ASSOCIATION, KENNETH RASKE, NORTHWELL HEALTH, INC., MICHAEL DOWLING, AND JOHN DOES A-Z, Defendants.

LASHANN DEARCY HALL, United States District Judge:

Daniel Arbeeny, as the Administrator of the Estate of Norman Arbeeny and Sean S. Newman, as the Administrator of the Estates of Michael J. Newman and Dolores D. Newman individually, and on behalf of others (“Plaintiffs”), bring the instant action against Andrew M. Cuomo, former Governor of New York, Melissa DeRosa, former Chief of Staff to Governor Cuomo, Dr. Howard A. Zucker, former Commissioner of the New York State Department of Health (“NYSDOH”) (collectively, the “State Defendants”), Greater New York Hospital Association (“GNYHA”), Kenneth Raske, President and Chief Executive Officer of GNYHA (together, “GNYHA Defendants”), Northwell Health, Inc. (“Northwell”), Michael Dowling, President and Chief Executive Officer of Northwell (together, “Northwell Defendants”) (together with GNYHA Defendants, the “Hospital Defendants”), and John Does A-Z, asserting claims pursuant to 42 U.S.C. § 1983 and 42 U.S.C. § 1985 for deprivation of their constitutional rights and rights under the Federal Nursing Home Reform Act (“FNHRA”). Plaintiffs also assert a wrongful death claim under New York Estate Powers & Trust Law (“NYEPT”) § 5-4.1. Defendants each move pursuant to Rule 12(b)(6) of the Federal Rules of Civil Procedure to dismiss the complaint in its entirety. BACKGROUND

In March 2020, when a rise in COVID-19-related hospitalizations began to put a strain on New York State’s healthcare infrastructure, state officials determined that there was an “urgent need” to expand hospital capacity to meet the demand for patients with COVID-19 requiring acute care. (See Glavin Decl. Supp. Cuomo’s Mot. Dismiss (“Glavin Decl.”), Ex. 1 (“NH Advisory”) at 1, ECF No. 68-1.)1 Governor Cuomo directed hospitals to immediately increase bed capacity by at least 50%. (Second Am. Compl. (“SAC”) ¶ 52.) Kenneth Raske and Micheal Dowling, on behalf of GNYHA and Northwell respectively, spoke with Cuomo and his team on multiple occasions. (Id. ¶ 49.) During those discussions, they urged Cuomo to issue policy on transfers of patients to nursing homes. (Id. ¶ 52.) Among other things, Raske and Dowling indicated such policy was necessary because the hospitals couldn’t afford to house recovered nursing-home

residents long-term and models showed they soon “could be swamped.” (Id. ¶ 52–53.) On March 25, 2020, the NYSDOH issued an advisory to nursing homes (the “NH Advisory”) directing that “[n]o resident shall be denied re-admission or admission to the [nursing home] solely based on a confirmed or suspected diagnosis of COVID-19” and that nursing homes were “prohibited from requiring a hospitalized resident who is determined medically stable, under the advisory, to be tested for COVID-19 prior to admission or readmission.” (NH Advisory at 1.)

1 In rendering its decision on the motions to dismiss, the Court has considered the NH Advisory, the ACF Advisory, and the NYSDOH Report, which were all attached to Defendant Cuomo’s motion to dismiss and were incorporated by reference in the complaint. On a motion to dismiss, the Court “may consider documents that ‘are attached to the complaint,’ ‘incorporated in it by reference,’ ‘integral’ to the complaint, or the proper subject of judicial notice.” United States v. Strock, 982 F.3d 51, 63 (2d Cir. 2020) (quoting Roth v. Jennings, 489 F.3d 499, 509 (2d Cir. 2007)). Hospital discharge planners were to confirm that a resident was determined to be “medically stable for return” by a hospital physician and provide “[c]omprehensive discharge instructions” to the nursing homes prior to the transfer. (Id.) Nursing homes were expected to maintain standard precautions and make “environmental cleaning” a priority. (Id.) On April 7, 2020, the NYSDOH

issued a similar advisory to adult care facilities (the “ACF Advisory”), prohibiting such facilities from denying admission and readmission to COVID-19-recovered residents. (Glavin Decl., Ex. 2 (“ACF Advisory”) at 1, ECF No. 68-2.) The ACF Advisory further directed that “[a]ny denial of admission or re-admission must be based on the ACF’s inability to provide the level of care required for the prospective resident, pursuant to the hospital’s discharge instructions.” (Id.) According to the second amended complaint, as a result of the NH Advisory and the ACF Advisory (together, the “2020 Advisories”), over 9,000 COVID-19-positive residents were admitted to nursing homes and adult care facilities, and over 15,000 of their residents died from COVID-19. (SAC ¶¶ 75–76.)2 The 2020 Advisories were withdrawn on May 10, 2020. (Id. ¶ 75.) Plaintiffs are the children of decedents Norman Arbeeny, Michael J. Newman, and Dolores

D. Newman (collectively, the “Decedents”). (SAC ¶¶ 1, 4, 7.) The Decedents were residents of nursing homes and adult care facilities in the State of New York who died between March and April 2020 after contracting COVID-19 and after the NYSDOH issued the 2020 Advisories. (Id. ¶¶ 1–2, 4–5, 7–8, 50.)

2 On July 6, 2020, the NYSDOH issued a report, later revised on February 11, 2021, assessing the factors associated with COVID-19 infections and fatalities in nursing homes during the pandemic. (Glavin Decl., Ex. 3 (“NYSDOH Report”) at 1, ECF No. 68-3.) The revised report concluded that approximately 6,326 COVID-19-positive residents were admitted to nursing homes and adult care facilities between March 25, 2020 and May 8, 2020, that there had been 6,432 COVID-19 fatalities in nursing homes as of June 26, 2020, and that the data did not support “[a] causal link between the admission policy and infections/fatalities.” (Id. at 4–5, 7.) The report instead attributed these infections and fatalities to COVID-19 transmission from nursing home employees, with the rate of employee infections corresponding to the spread of COVID-19 throughout the most impacted regions in the state. (Id. at 3.) Some state officials and media outlets reported that Cuomo, DeRosa, and the NYSDOH made a concerted effort to downplay the number of COVID-19 deaths in nursing homes and adult care facilities and failed to report “at least 4,100” additional fatalities from April 2020 to February 2021. (SAC ¶¶ 130–39.) Norman Arbeeny, aged 89, was admitted to Cobble Hill Health Center (“CHHC”), a nursing home in Brooklyn, New York on March 20, 2020. (Id. ¶¶ 20–23.) At some point before his release from CHHC on April 8, 2020, Mr. Arbeeny developed a low-grade fever. (Id. ¶¶ 25– 26.) Upon Mr. Arbeeny’s discharge from CHHC, Mr. Arbeeny was placed under 24-hour at-home

nursing care. (Id. ¶ 27.) Mr. Arbeeny’s symptoms began to worsen, and he was tested for COVID- 19 on April 20, 2020. (Id. ¶ 29.) Mr. Arbeeny died the next day, on April 21, 2020. (Id. ¶ 30.) Later that day, test results indicated that Mr. Arbeeny was positive for COVID-19. (Id. ¶ 31.) Michael J. Newman, aged 84, was admitted to Grandell Rehabilitation and Nursing Center (“GRNC”), a nursing home in Long Beach, New York, on February 7, 2020. (Id.

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