In Matter of Quagliata v New York City Police Department, (NY County Sup. Ct., March 17, 2023), a New York state trial court remanded a case in which an administrative Panel refused to grant an NYPD police officer a religious exemption from New York City's COVID vaccine mandate. The court said in part:
Inasmuch as the Panel’s determination sets forth absolutely no rationale whatsoever for its conclusions, other than to incorporate the conclusory reasons articulated by the NYPD EEOD, the Panel’s determination is facially arbitrary and capricious, and may be annulled on that ground alone....
Even were the court directly to review the NYPD EEOD’s initial determination, it nonetheless would be constrained to conclude that the initial determination also was arbitrary and capricious. The NYPD EEOD’s determination is a prime example of a determination that sets forth only the most perfunctory discussion of reasons for administrative action....
The court’s conclusion in this regard should not be construed as a ruling that, had the petitioner’s stated reasons for his request for an exemption, and his discussion of religious doctrine, properly been analyzed..., the petitioner’s contentions would have constituted a proper basis for an exemption...
With respect to ... violation of his First Amendment right to free exercise of religion and discrimination in employment..., the petitioner has not established either that the City’s vaccine mandate or the termination of his own employment were premised upon religion, as he has not demonstrated that his conclusions about sin, the use of embryonic stem cells in the development and improvement of various vaccinations and medications, and the alleged proscription of desecrating the human body via any genetic manipulation that mRNA vaccinations might generate, are established Catholic doctrine, or merely his personal interpretation of his obligations as a practicing Catholic.
