U.S. Court of Appeals for the Second Circuit

Smith v. Roswell Park Cancer Institute Corporation

September 4, 2026

Summary

The Second Circuit affirmed the district court's dismissal of Smith's claims under the ADA and the New York State Human Rights Law, finding that she failed to plausibly allege a disability discrimination, termination, or retaliation claim. The court held that her alleged medical condition did not qualify for a vaccine exemption and that her termination was consistent with a lawful vaccine mandate.