Samaroo v. The Bank of New York Mellon
- Analisa Torres
- 1:21-cv-02441
- U.S. District Court · Southern District of New York
- 3
Samaroo v. The Bank of New York Mellon: Judge Torres overruled Samaroo’s objections, adopted the report, and denied sanctions against him.
Karamchand Samaroo and The Bank of New York Mellon; the ruling denied the bank’s sanctions motion and closed the case.
What happened
In Karamchand Samaroo v. The Bank of New York Mellon, Samaroo, representing himself, claimed that his former employer fired him for protected whistleblowing under the Sarbanes-Oxley Act.
After the court dismissed his complaint and his appeals were unsuccessful, the Bank of New York Mellon asked for sanctions. Magistrate Judge Katharine H. Parker recommended denying that request, and Samaroo objected.
Judge Analisa Torres found that Samaroo’s objections did not specifically address the recommendation, found no clear error, overruled the objections, adopted the recommendation in full, and denied the sanctions motion. The court also declined to order Samaroo to explain why a future filing restriction should not be imposed and closed the case.
The detailed version
- Samaroo v. The Bank of New York Mellon · No. 1:21-cv-02441
- Analisa Torres
- Sept. 25, 2025
Background
Karamchand Samaroo represented himself in an action against his former employer, The Bank of New York Mellon. He alleged that the bank terminated his employment because he engaged in protected whistleblowing activity, violating Section 806 of the Sarbanes-Oxley Act of 2002.
The opinion states that the case had a lengthy and contentious procedural history, including dismissal of Samaroo’s complaint and unsuccessful appeals by Samaroo. The bank then moved for sanctions against him.
Report and Recommendation
The motion was referred to Magistrate Judge Katharine H. Parker. She issued a report and recommendation advising that the sanctions motion be denied. The report also recommended considering an order requiring Samaroo to explain why he should not be barred from filing future cases without paying filing fees against the bank without first obtaining court permission.
Samaroo filed objections. The district court explained that specific objections would receive a fresh review, while general or conclusory objections would be reviewed only for clear error—a clear mistake in the magistrate judge’s reasoning.
Ruling
Judge Analisa Torres determined that Samaroo’s objections raised arguments unrelated to the sanctions motion and did not specifically address the report and recommendation. The court therefore reviewed the report for clear error and found none.
The court overruled Samaroo’s objections, adopted the report and recommendation in full, and denied The Bank of New York Mellon’s motion for sanctions. Although the court described the proposed filing restriction as sensible, it declined to issue an order requiring Samaroo to explain why that restriction should not be imposed. The Clerk was directed to terminate the sanctions motion and close the case.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.