Pantoja v. Enciso

Background

Raphael M. Pantoja, Rachel M. Pantoja, and Rafael M. Pantoja brought the action without lawyers. The claims arose from Rafael’s incarceration at the Metropolitan Detention Center in Brooklyn and Rachel’s interactions with defendant probation officer Javier Enciso. The defendants were Javier Enciso and Herman Quay.

On December 10, 2019, Magistrate Judge Gabriel W. Gorenstein issued a report and recommendation advising the court to grant the defendants’ pending motion to dismiss or, alternatively, for summary judgment. The report warned that objections had to be filed within 14 days and that failing to do so would waive objections and prevent appellate review. On January 6, 2020, the court adopted the report, granted the defendants’ motion, and closed the case.

Plaintiffs’ Objections

The court received a letter from the plaintiffs dated January 6, 2020, objecting to the report, after the objection deadline had passed. The defendants responded on January 23, 2020.

The court held that the plaintiffs waived their objections by failing to file them within the required period. Because of that waiver, the court did not need to consider the objections on their merits. The court nevertheless explained that timely objections would not have changed the result. It stated that each objection either offered entirely new evidence—which courts generally do not consider at this stage—or repeated arguments previously made before the magistrate judge. When a party repeats earlier arguments, the court reviews the report for clear error, meaning an obvious mistake. The court had already reviewed the report and found no clear error.

Ruling

Judge Paul A. Engelmayer reaffirmed the January 6, 2020 opinion, and the case remained closed. The court stated that the parties’ failure to file timely objections waived appellate review. It directed the Clerk of Court to mail a copy of the order to the plaintiffs.