Samuels v. Barnard College
- Paul Engelmayer
- 1:23-cv-06181
- U.S. District Court · Southern District of New York
- 4
In Samuels v. Barnard College, Judge Engelmayer adopted the recommendation and entered summary judgment for Barnard.
Barnard College prevailed on the remaining Title IX, New York State Human Rights Law, and New York City Human Rights Law retaliation claims. Samuels’s case was closed after summary judgment was entered for Barnard.
What happened
Justin Samuels, representing himself, sued Barnard College over alleged gender discrimination and retaliation under several federal, state, and city laws. The court had previously dismissed his discrimination claims and his federal Title VI retaliation claim, leaving retaliation claims under Title IX and New York laws.
Barnard asked for judgment on the pleadings regarding the remaining claims and submitted materials outside the pleadings. Because Samuels also submitted evidence, the court treated the request as a motion for summary judgment and gave him notice of the consequences. A magistrate judge recommended granting Barnard summary judgment.
Neither side objected to the recommendation. Judge Engelmayer found no clear error, adopted the recommendation in its entirety, entered summary judgment for Barnard, terminated the pending motions, and closed the case.
The detailed version
- Samuels v. Barnard College · No. 1:23-cv-06181
- Paul Engelmayer
- May 30, 2025
Background
Justin Samuels filed this action against Barnard College while representing himself. His Second Amended Complaint 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.
On January 3, 2025, the court granted Barnard’s earlier motion to dismiss in substantial part. It dismissed Samuels’s discrimination claims and his Title VI retaliation claim, but allowed his retaliation claims under Title IX, the New York State Human Rights Law, and the New York City Human Rights Law to continue. Barnard then filed an answer and moved for judgment on the pleadings under Federal Rule of Civil Procedure 12(c) as to those surviving claims.
Conversion to Summary Judgment
Barnard’s motion relied on written materials outside the pleadings. Barnard gave Samuels notice that the court could treat the motion as one for summary judgment under Rule 56 and explained that he could not rely only on the allegations in his complaint. Samuels opposed the motion and submitted documentary evidence. Barnard then asked the court to convert the motion to summary judgment.
The court had referred the motion to Magistrate Judge Sarah L. Cave. Judge Cave issued a Report and Recommendation advising the court to treat Barnard’s Rule 12(c) motion as a summary-judgment motion and grant summary judgment to Barnard. The report stated that the parties had 14 days to object. Neither party objected.
Court’s Review and Ruling
Because there were no objections, Judge Engelmayer reviewed the report for clear error, meaning an obvious mistake on the face of the record. He found none and adopted Judge Cave’s recommendation in its entirety. The court also stated that the parties’ failure to object waived appellate review of the report’s conclusions.
The court entered summary judgment in favor of Barnard. It directed the Clerk of Court to mail Samuels a copy of the decision, terminate all pending motions, and close the case.
Read the full 4-page opinion on CourtListener, the free public archive maintained by the Free Law Project.