Parks v. Montefiore Med. Ctr.

CourtCourt of Appeals for the Second Circuit
DecidedJune 22, 2026
Docket25-811-cv
StatusUnpublished

This text of Parks v. Montefiore Med. Ctr. (Parks v. Montefiore Med. Ctr.) is published on Counsel Stack Legal Research, covering Court of Appeals for the Second Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Parks v. Montefiore Med. Ctr., (2d Cir. 2026).

Opinion

25-811-cv Parks v. Montefiore Med. Ctr.

UNITED STATES COURT OF APPEALS FOR THE SECOND CIRCUIT SUMMARY ORDER RULINGS BY SUMMARY ORDER DO NOT HAVE PRECEDENTIAL EFFECT. CITATION TO A SUMMARY ORDER FILED ON OR AFTER JANUARY 1, 2007, IS PERMITTED AND IS GOVERNED BY FEDERAL RULE OF APPELLATE PROCEDURE 32.1 AND THIS COURT’S LOCAL RULE 32.1.1. WHEN CITING A SUMMARY ORDER IN A DOCUMENT FILED WITH THIS COURT, A PARTY MUST CITE EITHER THE FEDERAL APPENDIX OR AN ELECTRONIC DATABASE (WITH THE NOTATION “SUMMARY ORDER”). A PARTY CITING A SUMMARY ORDER MUST SERVE A COPY OF IT ON ANY PARTY NOT REPRESENTED BY COUNSEL.

At a stated term of the United States Court of Appeals for the Second Circuit, held at the Thurgood Marshall United States Courthouse, 40 Foley Square, in the City of New York, on the 22nd day of June, two thousand twenty-six. Present: GERARD E. LYNCH, WILLIAM J. NARDINI, MYRNA PÉREZ, Circuit Judges. _____________________________________ BRYANT E. PARKS,

Plaintiff-Appellant, v. 25-811 MONTEFIORE MEDICAL CENTER,

Defendant-Appellee. _____________________________________

For Plaintiff-Appellant: Bryant E. Parks, pro se, New York, NY

For Defendant-Appellee: Emily Haigh, Joseph E. Field, Littler Mendelson P.C., New York, NY

Appeal from a judgment of the United States District Court for the Southern District of

New York (J. Paul Oetken, District Judge).

UPON DUE CONSIDERATION, IT IS HEREBY ORDERED, ADJUDGED, AND

DECREED that the judgment of the district court is AFFIRMED.

1 Bryant Parks, proceeding pro se, appeals from the district court’s judgment dismissing his

amended complaint and its order denying reconsideration. Parks sued his former employer,

Montefiore Medical Center (“Montefiore”), under Title VII of the Civil Rights Act of 1964, 42

U.S.C. § 2000e et seq., alleging that he was denied an accommodation and fired from his security

guard position after he refused on religious grounds to be vaccinated against COVID-19.

Montefiore moved to dismiss the amended complaint pursuant to Federal Rule of Civil Procedure

12(b)(6), asserting that Parks’s request to continue working would pose an undue hardship by

forcing the hospital to violate a statewide vaccine mandate. The district court granted the motion

to dismiss, concluding that Parks’s request would result in undue hardship and that Parks never

requested any specific accommodation. See Parks v. Montefiore Med. Ctr., No. 23-CV-4945

(JPO), 2025 WL 370830, at *2–3 (S.D.N.Y. Feb. 3, 2025). 1 Parks moved to amend the judgment

pursuant to Federal Rule of Civil Procedure 59(e), and the district court denied the motion. We

assume the parties’ familiarity with the case.

“We review de novo a district court’s dismissal of a complaint pursuant to Rule 12(b)(6),

construing the complaint liberally, accepting all factual allegations in the complaint as true, and

drawing all reasonable inferences in the plaintiff’s favor.” Mazzei v. Money Store, 62 F.4th 88, 92

(2d Cir. 2023). “To survive a motion to dismiss, a complaint must contain sufficient factual matter,

accepted as true, to state a claim to relief that is plausible on its face.” Ashcroft v. Iqbal, 556 U.S.

662, 678 (2009). “The plausibility standard is not akin to a probability requirement, but it asks for

more than a sheer possibility that a defendant has acted unlawfully.” Id.

1 Unless otherwise indicated, in quoting cases, all internal quotation marks, alteration marks, emphases, footnotes, and citations are omitted.

2 “We review the district court’s ruling on a Rule 59(e) motion [to amend the judgment] for

abuse of discretion.” Salamone v. Douglas Marine Corp., 111 F.4th 221, 233 (2d Cir. 2024). “A

court abuses its discretion in ruling on such a motion if its decision either rests on an error of law

or a clearly erroneous finding of fact, or cannot be located within the range of permissible

decisions.” Id.

Because Parks “has been pro se throughout, his pleadings and other filings are interpreted

to raise the strongest claims they suggest.” Sharikov v. Philips Med. Sys. MR, Inc., 103 F.4th 159,

166 (2d Cir. 2024).

The district court properly dismissed Parks’s failure-to-accommodate claim. To make out

a prima facie case of religious discrimination under Title VII, plaintiffs “must show that (1) they

held a bona fide religious belief conflicting with an employment requirement; (2) they informed

their employers of this belief; and (3) they were disciplined for failure to comply with the

conflicting employment requirement.” Baker v. Home Depot, 445 F.3d 541, 546 (2d Cir. 2006).

“Once a prima facie case is established by the employee, the employer must offer him or her a

reasonable accommodation, unless doing so would cause the employer to suffer an undue

hardship.” Id. At the Title VII pleading stage, a plaintiff is not required “to plead facts establishing

a prima facie case,” but must allege a plausible claim. Buon v. Spindler, 65 F.4th 64, 79 (2d Cir.

2023). Because undue hardship is an affirmative defense, it may be raised in a pre-answer motion

to dismiss only if the defense appears on the face of the complaint. See Iowa Pub. Emps.’ Ret.

Sys. v. MF Glob., Ltd., 620 F.3d 137, 145 (2d Cir. 2010) (discussing affirmative defenses

generally).

Even assuming that Parks had pled a plausible claim of discrimination, the district court

properly concluded that granting Parks a religious exemption from the COVID-19 vaccine

3 requirement would have placed an undue hardship on Montefiore. A proposed accommodation

constitutes an “undue hardship” when it poses “a burden [that] is substantial in the overall context

of an employer’s business.” Groff v. DeJoy, 600 U.S. 447, 468 (2023). At the time Parks was

fired, a state vaccine mandate required all “[c]overed entities,” like the hospital, to “continuously

require personnel to be fully vaccinated against COVID-19.” 10 N.Y.C.R.R. § 2.61(a)(1), (c)

(2021). “Personnel” was defined to include employees “who engage in activities such that if they

were infected with COVID-19, they could potentially expose other covered personnel, patients or

residents to the disease.” Id. § 2.61(a)(2). Under this mandate, employers could not provide

religious exemptions to employees who fit § 2.61’s definition of personnel. We the Patriots USA,

Inc. v. Hochul, 17 F.4th 368, 370 (2d Cir. 2021).

We have held that “an accommodation that would require an employer to violate the law

imposes an undue hardship.” Russo v. Patchogue-Medford Sch. Dist., 129 F.4th 182, 186 (2d Cir.

2025). Accordingly, because the vaccine requirement was mandated by state law and Parks does

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Related

Ashcroft v. Iqbal
556 U.S. 662 (Supreme Court, 2009)
Jia Sheng v. MTBank Corporation
848 F.3d 78 (Second Circuit, 2017)
Graves v. Finch Pruyn & Co.
457 F.3d 181 (Second Circuit, 2006)
Mazzei v. the Money Store
62 F.4th 88 (Second Circuit, 2023)
Buon v. Spindler
65 F.4th 64 (Second Circuit, 2023)
Groff v. DeJoy
600 U.S. 447 (Supreme Court, 2023)
Sharikov v. Philips Medical Systems MR, Inc.
103 F.4th 159 (Second Circuit, 2024)
Salamone v. Douglas Marine Corp.
111 F.4th 221 (Second Circuit, 2024)
Russo v. Patchogue-Medford Sch. Dist.
129 F.4th 182 (Second Circuit, 2025)

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Parks v. Montefiore Med. Ctr., Counsel Stack Legal Research, https://law.counselstack.com/opinion/parks-v-montefiore-med-ctr-ca2-2026.