Dougherty v. City of New York

2025 NY Slip Op 30080(U)
CourtNew York Supreme Court, New York County
DecidedJanuary 7, 2025
DocketIndex No. 155088/2023
StatusUnpublished

This text of 2025 NY Slip Op 30080(U) (Dougherty v. City of New York) is published on Counsel Stack Legal Research, covering New York Supreme Court, New York County primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Dougherty v. City of New York, 2025 NY Slip Op 30080(U) (N.Y. Super. Ct. 2025).

Opinion

Dougherty v City of New York 2025 NY Slip Op 30080(U) January 7, 2025 Supreme Court, New York County Docket Number: Index No. 155088/2023 Judge: J. Machelle Sweeting Cases posted with a "30000" identifier, i.e., 2013 NY Slip Op 30001(U), are republished from various New York State and local government sources, including the New York State Unified Court System's eCourts Service. This opinion is uncorrected and not selected for official publication. INDEX NO. 155088/2023 NYSCEF DOC. NO. 54 RECEIVED NYSCEF: 01/08/2025

SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK: PART 62 -----------------------------------------------------------------------------------X TIMOTHY DOUGHERTY, INDEX NO. 155088/2023

Plaintiff, 08/04/2023, MOTION DATE 08/10/2023 -v- THE CITY OF NEW YORK, THE NEW YORK CITY MOTION SEQ. NO. 002 003 POLICE DEPARTMENT, MICHAEL MELOCOWSKY, JOHN DOES 1-10 DECISION + ORDER ON Defendants. MOTION -----------------------------------------------------------------------------------X

The following e-filed documents, listed by NYSCEF document number (Motion 002) 21, 22, 23, 24, 25, 26, 27, 28, 30, 33, 34, 35, 36, 37, 38, 39, 40, 41, 47, 49 were read on this motion to/for DISMISSAL .

The following e-filed documents, listed by NYSCEF document number (Motion 003) 12, 13, 14, 15, 16, 17, 18, 29, 31, 42, 43, 44, 45, 46, 48, 50, 51 were read on this motion to/for DISMISS .

Motion Sequence Numbers 002 and 003 are consolidated herein for disposition.

Plaintiff, a Catholic New York City police officer, commenced this action against

defendants the City of New York, the New York City Police Department (“NYPD”) and NYPD

employee Michael Melocowsky (“Melocowsky”) (collectively “defendants”) alleging that they

discriminated against plaintiff by denying his request for a religious accommodation from the

City’s Covid-19 vaccine mandate. Defendants move to dismiss, pursuant to Civil Practice Law

and Rules (“CPLR”) 3211[a][7]) for failure to state a claim, and plaintiff cross-moves to amend

the complaint.

155088/2023 DOUGHERTY, TIMOTHY vs. THE CITY OF NEW YORK ET AL Page 1 of 7 Motion No. 002 003

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BACKGROUND

The following facts are taken from the complaint (NYSCEF Doc. No. 14) and accepted as

true for purposes of this motion (Tax Equity Now N.Y. LLC v NYC, 42 NY3d 1, 12 [2024]). Plaintiff

has been a New York City police officer since 2015 (id., ¶¶13-14). During that time, he has never

been penalized, suspended or found to be insubordinate and the NYPD never requested that

plaintiff obtain a vaccine or mentioned that there was a vaccine requirement (id., ¶¶ 15-16).

However, at some point in 2021, the NYPD stated that he needed to be vaccinated against

Covid-19 (id., ¶ 17). In response, on or around October 26, 2021, plaintiff applied for a religious

accommodation, explaining that he was a devout Catholic, and pursuant to the tenants of his faith,

he believed he was created in God’s image (id., ¶ 17, 20, 21). The NYPD denied the request on

June 30, 2022 (id., ¶ 29). Plaintiff asserts that this denial was predetermined because of his faith

(id., ¶ 30). He alleges that defendant Melocowsky instructed the department that there was no need

to engage in cooperative dialogue with anyone and did not do so with petitioner (id., ¶¶ 25, 31).

Plaintiff further claims that the NYPD never conducted a study regarding pandemic safety issues

and had no information regarding the safety implications of weekly testing when it issued the

denial (id., ¶¶ 22-23). And while many other workers were routinely allowed to work if they wore

masks or took weekly tests, petitioner was never offered these accommodations despite being

willing to accept them (id., ¶¶ 26-27).

As a result of the NYPD’s policy, plaintiff was told that he would be abruptly terminated

if he refused to take the Covld-19 vaccine (id., ¶ 32). Plaintiff contends that he was forced to take

the vaccine in violation of his religious beliefs due to the threat of losing his job, his health

insurance and his livelihood (id., ¶ 1). In the complaint, plaintiff alleges: (1) violations of the

New York State Human Rights Law, New York Executive Law § 296 (“SHRL”); (2) violations of

155088/2023 DOUGHERTY, TIMOTHY vs. THE CITY OF NEW YORK ET AL Page 2 of 7 Motion No. 002 003

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the New York City Human Rights Law, New York City Administrative Code § 8- 107 (“CHRL”);

(3) violations of the free exercise clause of the New York State Constitution; (4) intentional

infliction of emotional distress; and (5) aiding and abetting as against defendant Melocowsky. In

addition to attorney’s fees, plaintiff seeks punitive damages.

Plaintiff filed a notice of claim on September 20, 2022, and commenced this action on June

7, 2023, by filing a summons and complaint. In moving to dismiss, defendants argue that: (1) the

action should have been brought as an Article 78 and is time-barred; (2) the NYPD is not a suable

entity; (3) plaintiff cannot sue individual defendants under the SHRL; (4) the complaint fails to

assert actionable personal involvement by Melocowsky; (5) there is no claim for employment

discrimination under the New York State Constitution; and (6) plaintiff fails to allege he suffered

any cognizable harm.

DISCUSSION

Plaintiff’s arguments are identical to those rejected in other recent actions challenging

New York’s vaccine mandate and must be dismissed as well. Although defendants’ statute of

limitations defense is by itself sufficient to resolve this case, all of plaintiff’s other contentions

are briefly discussed here for the sake of completeness.

Statute of Limitations

CPLR 217(1) provides that “a proceeding against a body or officer must be commenced

within four months after the determination to be reviewed becomes final and binding upon the

petitioner.” This action was not brought until nearly a year after plaintiff was notified that his

request for a religious accommodation had been denied. Accordingly, the action is untimely

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(Farca v Bd. of Educ. of City Sch. Dist. of NYC, 220 AD3d 567, 567 [1st Dept 2023], lv denied,

41 NY3d 909 [2024]). See also, Campagna v NYPD, 218 NYS3d 331 (Mem), 2024 N.Y. Slip

Op. 05046 [1st Dept 2024]; Almodovar v City of New York, 2024 WL 1819065, *2 [Sup Ct, NY

Co 2024]; Goolsby v NYC, 83 Misc 3d 445 [Sup Ct, NY Co 2024]; Nieves v NYPD, 2024 WL

4373366, *2 (Sup Ct, Kings Co]; Farah v NYC, 2024 WL 3545728, *3-4 [Sup Ct, Kings Co

2024].

NYPD as a Suable Entity

Pursuant to Chapter 17, Section 396 of the New York City Charter, “[a]ll actions and

proceedings for the recovery of penalties for the violation of any law shall be brought in the

name of the City of New York and not in that of any agency, except where otherwise provided

by law.” City agencies are thus not subject to suit (see Komatsu v NYC Hum. Res. Admin.,

195 AD3d 417, 417 [1st Dept 2021]) and the NYPD is no exception (Carpenter v NYCHA, 146

A.D.3d 674, 44 [1st Dept 2017]; Hunold v NYC, 2024 WL 4140057. *6-7 [Sup Ct, NY Co

2024]). The Court does not find persuasive plaintiff’s argument that the CHRL’s definition of an

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