Cooney v. City of N.Y. Dept. of Sanitation
Plaintiff Robert Cooney appealed an order granting summary judgment to defendants, City of New York Department of Sanitation (DSNY), in a case alleging discriminatory medical disqualification for a sanitation worker position due to psoriasis. The Appellate Division, First Department, affirmed the lower court's decision, concluding that DSNY's finding was not discriminatory under New York State and City Human Rights Laws. Defendants demonstrated that no reasonable accommodation would enable Cooney to perform the job duties safely and effectively. DSNY engaged in an interactive dialogue, and its medical director rejected proposed accommodations, explaining that the plaintiff's chronic psoriasis would be exacerbated by the work environment, rendering treatment ineffective and making him vulnerable to infection. The court found that defendants were entitled to rely on their medical director's opinion, despite a conflicting opinion from plaintiff's treating physician.