Gandhi v. NYS Unified Court System

CourtDistrict Court, N.D. New York
DecidedSeptember 9, 2025
Docket1:20-cv-00120
StatusUnknown

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

Bluebook
Gandhi v. NYS Unified Court System, (N.D.N.Y. 2025).

Opinion

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF NEW YORK

RAJNI GANDHI,

Plaintiff,

v. 1:20-cv-00120 (AMN/DJS)

NEW YORK STATE UNIFIED COURT SYSTEM et al.,

Defendants.

APPEARANCES: OF COUNSEL:

RAJNI GANDHI 60 Indian Pipe Drive Wynantskill, New York 12198 Plaintiff, pro se

HON. LETITIA JAMES JORGE A. RODRIGUEZ, ESQ. New York State Attorney General LELA M. GRAY, ESQ. The Capitol Albany, New York 12224 Attorneys for Defendant Hon. Anne M. Nardacci, United States District Judge: MEMORANDUM-DECISION AND ORDER I. INTRODUCTION Presently before the Court is a motion by Rajni Gandhi (“Plaintiff”) seeking reconsideration of the Court’s October 16, 2024 Memorandum-Decision and Order, Dkt. No. 152 (“Prior Order”). Dkt. Nos. 157-158 (“Motion”). The New York State Unified Court System (“Defendant”) opposes the Motion. Dkt. No. 159. For the reasons set forth below, the Motion is denied. II. BACKGROUND1 The Court detailed the factual background and procedural history of this action in the Prior Order, and incorporates that detail by reference. Dkt. No. 152. The Court nonetheless provides the following summary for convenience. A. Plaintiff’s Employment and Termination

Plaintiff was employed by Defendant from April 2001 until January 2019. Id. at 3.2 She worked as a Senior Court Office Assistant in the Albany City Court. Id. A significant portion of her responsibilities involved retrieving, refiling, carrying, and moving court case files. Id. at 3-4. In or about April 2017, Plaintiff informed Defendants that she had a physical condition that limited her ability to physically handle files. Id. at 5. Plaintiff submitted documentation from medical professionals stating that she should be restricted from filing. Id. Plaintiff’s co-workers subsequently performed her filing responsibilities. Id. Defendant requested and received additional information from Plaintiff’s physician regarding her continuing physical limitations over time3 and, in late 2018, again requested updated

information from Plaintiff’s physician. Id. at 5-6, 10. In December 2018, Plaintiff’s physician stated that Plaintiff should continue with the work restrictions he had communicated previously, and that “[t]hese work restrictions are permanent restrictions.” Id. at 10 (citations omitted). Defendant then met with Plaintiff to discuss her medical condition. Id. Plaintiff confirmed

1 The parties’ familiarity with the background of this matter is presumed, and only those facts necessary to resolving the Motion are discussed herein. 2 Citations to docket entries utilize the pagination generated by CM/ECF, the Court’s electronic filing system, and not the documents’ internal pagination. 3 In late 2017, the president of Plaintiff’s union warned Plaintiff that she risked termination if she submitted documentation establishing that she was “a file clerk who can’t file.” Id. at 7 n.7 (citations omitted). that due to her physical limitations, she would continue to require the level of assistance provided by her co-workers. Id. Plaintiff asked to be reassigned to a position that did not require filing. Id. Defendant informed Plaintiff that there were no other assignments available for her current position and pay level. Id. Later that month, and after further consultation with Defendant’s Office of Labor Relations

(“Labor Relations”), Defendant’s District Executive for the Third Judicial District (“District Executive”) made a detailed written recommendation to Defendant’s Deputy Chief Administrative Judge for Courts Outside of New York City (“Deputy Chief”). Id. at 11. The District Executive recommended that Defendant terminate Plaintiff as an incapacitated employee under the relevant collective bargaining agreement (“CBA”). Id. In January 2019, the Deputy Chief issued a letter terminating Plaintiff on the grounds that: You have been unable to perform the full duties of your position for over one year, during which time your position has been substantially modified in order to accommodate your physical (medical) limitations/restrictions. The most recent medical documentation that you provided indicates that these work restrictions are permanent, i.e.[,] you are permanently incapacitated from performing the necessary duties of your position.

Id. (citations omitted). B. Plaintiff’s Annual Leave Between 2011 and 2018, Plaintiff requested and received three consecutive weeks of annual leave each February in order to travel to India. Id. at 4. Plaintiff alleges that these trips were for religious purposes. Dkt. No. 10 at 10; see also Dkt. No. 150-2 at 286:8-289:18. In India, Plaintiff testified that she would “attend discourses given by the teacher there[,]” “meditate[,]” and “help. . . . with, you know, the check-in process” at the hostel where she stayed. Dkt. No. 152 at 4 (citation omitted). During September and October 2018, Plaintiff requested approximately seven weeks of annual leave during 2019, including February 4 through March 1, 2019. Id. at 8. In October 2018, after consulting with Labor Relations, Defendant approved all of Plaintiff’s requests, except the nearly four consecutive weeks Plaintiff requested in February and March 2019. Id. Defendant instead approved February 4 until February 13 and explained to Plaintiff that the partial approval was “[d]ue to the operational needs of the court. . . . as we are

short-handed, have one new employee who is still being trained[,] and one starting in a few week[s] who will need to be trained.” Id. at 8-9 (alterations in original) (citations omitted). In November 2018, Plaintiff filed a grievance with Defendant through her union, claiming that the partial approval of her annual leave request violated the CBA because: [Plaintiff] is the highest seniority in her title in the Albany City Criminal Court. She [r]equested [l]eave for February 2019 and was denied some of the dates based on the operating needs. Based on her title and responsibilities, we do not agree that the operating needs warrant her annual leave denial.

Id. at 10 (alterations in original) (citation omitted). In December 2018, Defendant denied Plaintiff’s grievance, in part because the “operational needs of the court due to staffing shortages will not allow for an employee of Albany City Court, Criminal Part, to have over a week of annual leave during February [2019].” Id. at 10-11 (alteration in original) (citation omitted). C. Procedural History In January 2019, Plaintiff administratively appealed her termination.4 Id. at 11-12. The hearing officer for the appeal recommended that Plaintiff’s termination be upheld and found as follows: [I]t is undisputed that: (1) the position of Senior Court Office Assistant entails a significant amount of filing; (2) [Plaintiff]’s doctors advised that she was unable to

4 Plaintiff was represented by counsel for the attendant evidentiary hearing and related briefing. Id. at 12. perform the job duty of filing due to a degenerative spinal condition and that [Plaintiff]’s work restrictions were permanent; (3) [Plaintiff] repeatedly requested assistance with her filing duties; (4) [Plaintiff]’s doctors never requested any accommodations which would allow [Plaintiff] to perform her job duties, other than a lightweight headset;5 and (5) the accommodations provided to [Plaintiff] (that is, filing assistance from her supervisors and co-workers) for the period of November 2017 through January 2019 were a burden on court operations. Given the foregoing, the evidence demonstrated that [Plaintiff] was unable to perform the full duties of her position for a period of over one year and that [Plaintiff]’s work restrictions were permanent. Therefore, in accordance with [the relevant provision] of the CBA, [Plaintiff]’s termination was appropriate.

Id. at 12 (penultimate alteration added) (citation omitted).

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