Vincent Maiorino v. New York City Department of Sanitation, et al.

CourtDistrict Court, S.D. New York
DecidedOctober 15, 2025
Docket1:25-cv-00097
StatusUnknown

This text of Vincent Maiorino v. New York City Department of Sanitation, et al. (Vincent Maiorino v. New York City Department of Sanitation, et al.) 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
Vincent Maiorino v. New York City Department of Sanitation, et al., (S.D.N.Y. 2025).

Opinion

USDC SDNY DOCUMENT SOUTHERN DISTRICT OF NEW YORK DOC #: nna nese nna nese naan □□□□□□□□□□□□□□□□□□□□□□ KK DATE FILED:_10/15/2025 VINCENT MAIORINO : Plaintiff, : : 25-cv-0097 (LJL) -v- : : OPINION AND ORDER NEW YORK CITY DEPARTMENT : OF SANITATION, et al., : Defendants. : LEWIS J. LIMAN, United States District Judge: Defendants New York City Department of Sanitation (““DSNY”) and City of New York (“the City,” and together with DSNY, the “Defendants”) move, pursuant to Federal Rule of Civil Procedure 12(b)(6), to dismiss Plaintiff Vincent Maiorino’s (“Plaintiff’?) Amended Complaint. For the following reasons, Defendants’ motion to dismiss is granted. BACKGROUND The Court accepts Plaintiff's well-pleaded allegations as true for purposes of this motion.! Plaintiff is a resident and domiciliary of Orange County, New York. He worked as a full- time sanitation worker for DSNY from on or around May 30, 2005 to February 11, 2022. Dkt.

' Defendants argue that Plaintiff's allegations are demonstrably and knowingly false and violate the Federal Rules of Civil Procedure. Dkt. No. 39 at 11; see Dkt. No. 40-6 (containing sworn testimony controverting Plaintiffs allegations). The remedy for such conduct, as Defendants seem to recognize, is a motion under Federal Rule of Civil Procedure 11(b)(3) after the required procedural steps are taken. At the motion to dismiss stage, the Court must accept the factual allegations as long as they are not “wholly conclusory.” Krys v. Pigott, 749 F.3d 117, 128 (2d Cir. 2014).

No. 20 (“Am. Compl.”) ¶¶ 12–13, 25, 63. He identifies as a practicing Roman Catholic. Id. ¶ 29. Defendant DSNY is a municipal corporation and the City is a municipality organized under the laws of the New York. Id. ¶¶ 16–18. In 2020, after the initial outbreak of the COVID-19 pandemic, the Governor of New York

State issued an executive order that closed all “nonessential businesses.” Id. ¶ 38. Plaintiff continued his work because he was considered an “essential worker.” Id. ¶¶ 37–39. On October 20, 2021, the New York City Commissioner of Health and Mental Hygiene issued an Order (the “Vaccine Mandate”) requiring employees of New York City, in order to maintain their employment, to receive a COVID-19 vaccine by October 29, 2021. Id. ¶ 43. Pursuant to the Vaccine Mandate, employees who sought reasonable accommodations, religious or medical, were required to submit requests for such accommodation to their agency’s Equal Employment Opportunity (EEO) Officer no later than October 27, 2021, to avoid being placed on leave without pay (“LWOP”) status. The Mandate further provided that an employee had a right to

appeal if an initial request for accommodation was denied. Id. ¶¶ 45–46. The Department of Citywide Administrative Services (“DCAS”) issued further guidelines on the implementation of the Vaccine Mandate (the “Guidelines”). Id. ¶ 50; see https://www.nyc.gov/assets/dcas/downloads/pdf/guidelines/vaccine-reasonable-accommodation- process.pdf (last visited Oct. 14, 2025).2 The Guidelines stated that “[a] sincerely held religious,

2 The Guidelines are incorporated by reference. See Fishman v. City of New Rochelle, 2023 WL 1438731, at *4 (S.D.N.Y. Feb. 1, 2023) (“A document is incorporated by reference into the complaint where the complaint ‘refers to’ the document.”) (quoting EQT Infrastructure Ltd. V. Smith, 861 F. Supp. 2d 220, 224 n.2 (S.D.N.Y. 2012)). Even if it were not, the Court can also consider documents that are “integral” to the complaint as long as the plaintiff has “actual notice” of the document and “relied upon the documents in framing the complaint.” Id. (quoting McLennon v. City of New York, 171 F. Supp. 3d 69, 89 (E.D.N.Y. 2016)). moral, or ethical belief may be the basis for a religious accommodation” but that requests based solely on personal, political, or philosophical beliefs could not be. Am. Compl. ¶¶ 51–52. If an accommodation was granted, the employee was required to submit a weekly negative test result. Id. ¶ 53. Employees were allowed to continue working and submitting negative test results while their accommodation request and appeal were pending. Id. ¶ 57.

Plaintiff refuses all vaccinations based on his Catholic beliefs. Id. ¶ 31. Plaintiff’s objections to the COVID-19 vaccine in particular arise from the dictates of his own conscience, which his Catholic beliefs require him to abide by. Id. ¶¶ 34–35. He believes that the COVID- 19 vaccine was developed using aborted fetal cell lines and in his view the use of such vaccines is a direct violation of God’s commandments and the sanctity of life. Id. ¶¶ 114–19, 121. On or about November 4, 2021, after the deadline for the submission of reasonable accommodation requests to avoid being placed on LWOP status, Plaintiff submitted a formal request to DSNY for a religious accommodation from the Vaccine Mandate, stating that his religious beliefs conflicted with the immunization requirements. Id. ¶¶ 71–73.3 Plaintiff submitted his request

for a reasonable accommodation in the form of an Affidavit of Vaccine Exemption on Religious Grounds For City Employees (the “Affidavit”), which he downloaded from the internet. Id. ¶68; Dkt. No. 40-1. The form he filled out was not provided by the City or any government entity, and was found by Plaintiff “through independent efforts.” Id. The Affidavit read, in pertinent part:

3 Plaintiff alleges he was never advised of his right to apply for a religious accommodation. Id. ¶ 65. RE: Religious Exemption from Immunization Requirements

ercmanereyinsedl Maher, temo hy afin tt

asserting my rights to an exemption from (Governing Authority Name) of America, I am A i DSN Y —_——____ immunization requirements. _

Dkt. No. 40-1. Plaintiff filled in the blanks with his name and the identity of his employer. Jd. He certified that he qualified for the exemption based on the First Amendment and Title VII of the Civil Rights Act of 1964, 42 U.S.C. § 2000e et seg. Id. He signed the form and had it notarized. Id. On or about November 21, 2021, DSNY denied Plaintiff's initial request for religious exemptions in a letter entitled “Denial of Religious Exemption Appeal Information.” Am. Compl. 4 74; see Dkt. No. 40-2. The letter stated that the information provided by Plaintiff was insufficient to establish a basis for a religious exemption and notified Plaintiff that he would be placed on LWOP Status starting on November 24, 2021, unless he submitted proof of his vaccination. Id. {] 74, 89. It advised that Plaintiff could appeal that decision in two different ways: (1) an appeal to the City of New York Reasonable Accommodation Appeals Panel (“Citywide Panel”), consisting of DCAS, the Law Department, and the City Commission on Human Rights; or (2) an appeal to Scheinman Arbitration and Mediation Services (“SAMS”). Am. Compl. ff] 77-78. Appeals submitted to the Citywide Panel pursuant to Option 1 would be decided by evaluation of only the “documentation submitted to DSNY.” Id. 9.77; Dkt. No. 40-2 (“Employees may choose to appeal to a central City panel consisting of DCAS, Law and the City Commission on Human Rights. Appeals will be decided based on the documentation submitted

to DSNY, and there shall be no live hearing”). Plaintiff appealed DSNY’s denial of his request for a reasonable accommodation via Option 1. Id. ¶ 112.

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