Lewis v. Livingston County Center for Nursing & Rehabilitation
Plaintiff Cindy L. Lewis brought an action against Livingston County Center for Nursing and Rehabilitation (Livingston County CNR) for alleged disability discrimination and retaliation under the Americans with Disabilities Act (ADA) and the New York State Human Rights Law (NYSHRL). Lewis, a former certified nursing assistant, claimed she was terminated for refusing mandated overtime due to a permanent partial disability. Defendant moved to dismiss the complaint, asserting the Livingston County CNR lacked the capacity to be sued and that Lewis failed to serve a notice of claim for her NYSHRL claims. The court granted Lewis's cross-motion to amend the complaint to substitute Livingston County as the defendant. The court dismissed Lewis's NYSHRL claims due to the failure to file a notice of claim but denied the motion to dismiss the ADA discrimination and retaliation claims, concluding that the essential function of overtime work and the reasonableness of the accommodation required factual inquiry.