Chamberlain v. Splashlight, LLC

Background

Lucas C. Chamberlain, representing himself, sued Splashlight, LLC, Michaela Krebs, Bijou Summers, and Does 1–20. He alleged sex discrimination under Title VII of the Civil Rights Act of 1964, the New York State Human Rights Law, and the New York City Human Rights Law. Defendants filed two motions asking the court to dismiss the complaint.

The court referred the motions to Magistrate Judge Cave for a report and recommendation. Chamberlain did not respond to the motions, even after receiving additional time and a warning that the court could rule on an unopposed motion. Magistrate Judge Cave later recommended granting the motions, and Chamberlain did not object to that recommendation.

Court’s analysis

Because no party objected, the court reviewed the report and recommendation for clear error on the face of the record. The court found no clear error and agreed that Chamberlain had not pleaded enough facts to allege employment discrimination, retaliation, or sexual harassment under Title VII, the New York State Human Rights Law, or the New York City Human Rights Law.

Ruling

Judge Valerie Caproni adopted the report and recommendation in full. The court granted defendants’ motions to dismiss and dismissed the complaint with prejudice and without leave to amend. The court also stated that Chamberlain’s failure to object waived appellate review, certified that any appeal would not be taken in good faith, and denied permission to appeal without paying filing fees. The clerk was directed to terminate the motions and close the case.