In Matter of Daniels v. New York City Police Dept., (Sup. Ct. NY County, April 24, 2023), a New York state trial court remanded to the City of New York Reasonable Accommodations Appeals Panel a claim for a religious exemption from the COVID vaccine mandate brought by a NYPD officer assigned to the Emergency Services Unit. The initial determination by the NYPD Equal Employment Opportunity Division was communicated through a pre-printed form with three boxes checked off indicating insufficient documentation and explanation as well as a lack of a history of vaccine refusal. The Appeals Panel merely adopted the EEOD's reasoning. In calling for a fuller explanation, the court said in part:
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 has nothing before it that would enable it to analyze how the pre-printed "reasons" that were checked off on its determination letter related to or defeated the petitioner's request for accommodation. This type of conclusory administrative determination would require the court to speculate as to the thought processes of the person who checked the boxes, and provide its own reasons for those choices, an approach prohibited by longstanding rules of law.
