Conway v. Healthfirst Inc.

CourtDistrict Court, S.D. New York
DecidedSeptember 30, 2022
Docket1:21-cv-06512
StatusUnknown

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

Bluebook
Conway v. Healthfirst Inc., (S.D.N.Y. 2022).

Opinion

UNITED STATES DISTRICT COURT EDLOECC#T: RONICALLY FILED SOUTHERN DISTRICT OF NEW YORK DATE FILED: 09/30/2022

PATRICK CONWAY,

Plaintiff, No. 21-CV-6512 (RA)

v. MEMORANDUM

OPINION & ORDER HEALTHFIRST INC. and CHRISTOPHER

SMITH

Defendants.

RONNIE ABRAMS, United States District Judge: Plaintiff Patrick Conway, a registered nurse, brings this action against Healthfirst, Inc., a healthcare management company, and Christopher Smith, Healthfirst’s Director of Talent, asserting claims under the Americans with Disabilities Act (“ADA”), 42 U.S.C. § 12101 et seq., the Rehabilitation Act, 29 U.S.C. § 701 et seq., and the New York City Human Rights Law (“NYCHRL”) in connection with his efforts to obtain a position at Healthfirst. Now before the Court is Defendants’ motion to dismiss Plaintiff’s second amended complaint. For the reasons that follow, the motion is granted. Plaintiff is, however, granted leave to file an amended complaint. BACKGROUND1 Plaintiff Patrick Conway is a 43-year-old male registered nurse. He “has long held a valid Nursing License and (the equivalent of an) Associate’s Degree.” Id. ¶ 64. He also received a law degree, and after graduation, was seeking employment in healthcare management where he could potentially use the skills that he has learned both from nursing and law school. Id. ¶ 2. Conway

1 The following facts are drawn from Plaintiff’s second amended complaint and the exhibits attached thereto. “suffers from various disabilities,” including “a heart arrythmia, . . . Post-Traumatic Stress Disorder and anxiety because of a confluence of events that occurred around the diagnosis of his heart condition.” Id. ¶¶ 1, 10. Defendant Healthfirst is a healthcare management company. Healthfirst employees began

recruiting Conway to apply for open positions at the company “beginning as early as February 2018.” Id. ¶ 82. Specifically, he was recruited by Marissa McCredie, “a senior employee” at Healthfirst, along with two other Healthfirst employees, “Glickman and Tubens.” Id. ¶¶ 2, 42, 62. In one conversation that he had with a Healthfirst employee “early on,” the employee “told him that Healthfirst prefers to hire females because they ask for less money.” Id. n.7. “In another conversation, someone in the hiring process told plaintiff that Healthfirst preferred to hire nursing assessors right[] out of school ‘because they are less likely to complain about traveling.’” Id. During his communications with the Healthfirst recruiters, Conway “inquired about accommodations.” Id. ¶¶ 14, 77. “In his inquiry about accommodations, Mr. Conway corresponded with McCredie and Tubens, who “instructed him to contact ‘Careers and Human

Resources of Healthfirst.’ The correspondence included several emails and calls to and from McCredie, asking about possible work accommodations and steps to initiate the process.” Id. ¶ 77; see also id. ¶ 86. Specifically, Plaintiff alleges that he “required remote work.” Id. ¶ 11. Plaintiff has asserted that he “can drive a car but would rather not,” that he “must see doctors occasionally and take time off for appointments,” and “can work in person, but the less, the better.” Id. ¶¶ 11–12 (emphasis in original). At some point after he initially inquired about needing an accommodation for any potential position he hoped to obtain, Conway applied for “multiple jobs” with Healthfirst. Id. ¶ 21. He does not allege the exact number of positions for which he applied. Some time later, Conway received email responses to at least some of the positions that he applied for notifying him that, “Based on the required qualifications for this role, we are unable to select you for an interview.” Id. ¶ 64. Plaintiff alleges that “[t]he Job Descriptions show the minimum requirements were an Associate’s Degree in Nursing from an accredited program and a New York nursing license”—

both of which he possessed. Id. ¶ 93. “Mr. Conway had had both (or their equivalent since 2012, seven years before the application).” Id. In May of 2019, Conway contacted Healthfirst and spoke with McCredie on the phone. Id. ¶ 43; Ex. B. During this conversation, Plaintiff “asked her why Healthfirst deemed him not [to have] ‘minimum qualifications.’” Compl. ¶ 75. McCredie explained that there are a “number of reasons why [] anyone could be rejected from the position,” but that she had no personal knowledge of why he was rejected. Ex. B. at 1. After Conway explained some of the types of positions he might be interested in, McCredie informed him that she was “not the right person for him” to speak with, and that she would explain his situation to her director, Christopher Smith. Id. at 5. Following their call, McCredie sent an email to Conway that stated “As per our call, I just

checked, and there are still 12 open telecommute positions.” Compl. ¶ 99. She added that she was “sorry about all this,” and that the rejections based on the required qualifications for the roles “definitely seems like a miscommunication.” Ex. B at 5. Later that day, Plaintiff spoke on the phone with Christopher Smith, Healthfirst’s “Director of Talent.” Compl. ¶ 39. During this call, Conway reiterated his concerns that he was not granted any interviews after being recruited by Healthfirst and requesting that he receive an accommodation, and that the reason given was that he did not possess the “required qualifications” for the roles. Ex. D at 13. Smith responded that there were several possibilities as to why he may have received that email, including that the positions were actually filled or that an employee could have “just checked the wrong box.” Id. at 11, 13. Smith offered to look into the problem for him, and then suggested several open positions at Healthfirst, including telecommuting roles, that Conway may be a good fit for. Id. at 14–17. Following this interaction, Conway filed a complaint with the EEOC, to which Healthfirst

responded with its own position statement. Compl. ¶ 31. He alleges that, during the EEOC proceedings, Healthfirst “lie[d] about what Plaintiff did or said to Healthfirst as an applicant,” and made “many ad hominem—and otherwise churlish—attacks against him.” Id. ¶ 70. During the EEOC proceedings, Healthfirst asserted that the email responses that Conway received in response to his applications were autogenerated, and that he was “less qualified than other candidates.” Id. ¶ 71. In his complaint, Conway asserts that the emails were indeed autogenerated, and alleges that Healthfirst’s “bots targeted [his] resume for rejection,” id. ¶ 78, and that his applications were subjected to “automated resume review.” Id. ¶ 87. Plaintiff brings claims against Healthfirst and Smith for retaliation in violation of the ADA, the Rehabilitation Act, and the NYCHRL; failure to accommodate pursuant to the ADA and the

Rehabilitation Act; as well as sex discrimination, age discrimination, and discrimination based on profession pursuant to the NYCHRL. Now before the Court is Defendants’ motion to dismiss Plaintiff’s second amended complaint. The motion is granted. LEGAL STANDARD To survive a motion to dismiss under Federal Rule of Civil Procedure 12(b)(6), a complaint must plead “enough facts to state a claim to relief that is plausible on its face.” Bell Atl. Corp. v. Twombly, 550 U.S. 544, 570 (2007).2 “A claim has facial plausibility when the plaintiff pleads factual content that allows the court to draw the reasonable inference that the defendant is liable

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