Samuels v. Barnard College
- Paul Engelmayer
- 1:23-cv-06181
- U.S. District Court · Southern District of New York
- 3
In Samuels v. Barnard College, Judge Engelmayer partly granted and partly denied Barnard’s motion to dismiss Samuels’s claims.
Justin Samuels and Barnard College. Samuels’s discrimination and Title VI retaliation claims were subject to the granted portion of Barnard’s motion, while his Title IX, New York State Human Rights Law, and New York City Human Rights Law retaliation claims were allowed to proceed past this motion. The case was directed toward an initial pretrial conference.
What happened
In Samuels v. Barnard College, Justin Samuels, representing himself, sued Barnard College over alleged gender discrimination and retaliation under several federal, state, and city laws. Barnard asked the court to dismiss Samuels’s Second Amended Complaint.
The court adopted Magistrate Judge Sarah L. Cave’s recommendation. It granted Barnard’s motion as to Samuels’s discrimination claims and his retaliation claim under Title VI, and denied the motion as to his retaliation claims under Title IX, the New York State Human Rights Law, and the New York City Human Rights Law. It also denied Samuels permission to amend his pleadings and denied Barnard’s request to restrict future filings against Barnard and related people without prior court approval.
Judge Paul Engelmayer found no clear error in the recommendation because neither party objected. He directed the parties to schedule an initial pretrial conference and ordered the clerk to close all pending motions.
The detailed version
- Samuels v. Barnard College · No. 1:23-cv-06181
- Paul Engelmayer
- Jan. 3, 2025
Background
Justin Samuels, representing himself, sued Barnard College. He asserted gender-discrimination and retaliation claims under Title VI of the Civil Rights Act of 1964, Title IX of the Education Amendments of 1972, 42 U.S.C. § 1981, the New York State Human Rights Law, and the New York City Human Rights Law.
Barnard moved under Federal Rule of Civil Procedure 12(b)(6), which allows dismissal when a complaint does not adequately state a legal claim. The pending motion concerned Samuels’s Second Amended Complaint. Magistrate Judge Sarah L. Cave issued a Report and Recommendation advising that the court grant the motion as to Samuels’s discrimination claims and his Title VI retaliation claim, but deny it as to his retaliation claims under Title IX, the New York State Human Rights Law, and the New York City Human Rights Law. She also recommended denying Samuels leave to amend and denying Barnard’s request to require prior court approval before Samuels could file additional claims against Barnard, its employees, and its attorneys.
District Court’s Review
Neither party objected to the Report and Recommendation. The district court therefore reviewed it for clear error, meaning an obvious mistake apparent from the record. The court found no such error and adopted the recommendation in its entirety.
Disposition
The court granted in part and denied in part Barnard’s motion to dismiss the Second Amended Complaint. Specifically, the court granted the motion as to Samuels’s discrimination claims and Title VI retaliation claim, and denied the motion as to his retaliation claims under Title IX, the New York State Human Rights Law, and the New York City Human Rights Law. The court also denied Samuels leave to amend his pleadings and denied Barnard’s application for an order restricting future filings. The court directed the parties to contact Judge Cave’s chambers to schedule an initial pretrial conference and directed the clerk to close all pending motions. The opinion also states that the parties’ failure to object waived appellate review of the Report and Recommendation.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.