MEMORANDUM DECISION AND ORDER I. INTRODUCTION Plaintiff Casey Downey commenced this action by filing a complaint asserting claims pursuant to the Americans with Disabilities Act (“ADA”), 42 U.S.C. §12101 et seq., and the New York State Human Rights Law (“NYSHRL”), N.Y. Exec. Law §290, et seq. Dkt. No. 1 (“Complaint”). On March 15, 2024, Defendant New York State Office for People with Developmental Disabilities filed a motion to dismiss the Complaint. Dkt. No. 6-1 (“Motion”). Plaintiff responded with a cross-motion to amend the Complaint, Dkt. No. 11-1 (“Cross- Motion”), and Defendant filed a reply, Dkt. No. 13 (“Reply”). For the reasons that follow, Defendant’s Motion is granted, and Plaintiff’s Cross-Motion is denied. II. BACKGROUND A. The Complaint Plaintiff alleges the following in the Complaint. Defendant hired Plaintiff as a “Standards Compliance Analyst” and later promoted her to a “Project Manager” position. Compl. 12. Plaintiff is “diagnosed with and suffers from Reactive Hypoglycemia and pre-diabetes.” Id. 13. As a result of this diagnosis, Plaintiff is at an “increased risk [of] severe illness if she contracts Covid-19 and/or similar diseases.” Id. The diagnosis also requires Plaintiff “to attend [to] occasional unpredictable medical episodes.” Id. In March 2020, due to the COVID-19 pandemic, Defendant reassigned Plaintiff to another unit and informed her that she could perform her work remotely. See id. 15. A year later, Plaintiff received an “Employee of the Year” award from Defendant. Id. 16. On January 3, 2022, almost two years after the onset of the COVID-19 pandemic, Plaintiff “applied for a reasonable accommodation to telecommute full-time due to her obesity and pre-diabetes diagnosis.” Id. 17. Her application was initially denied due to incomplete medical information, but Plaintiff reapplied on January 13, 2022. See id.
18-19. Plaintiff followed up multiple times in the following weeks, and she received a response on February 22, 2022, approving her for full-time telework “pending a formal review.” Id.
