Komatsu v. The City of New York

Background

On November 11, 2020, Plaintiff Towaki Komatsu filed a letter addressed to Judge Gorenstein. He stated that he had no legal obligation to respond to the defendants’ letter about their anticipated motion to compel because, in his view, the letter did not comply with Federal Rule of Civil Procedure 10(b).

On November 13, 2020, Judge Gorenstein denied Komatsu’s application. Judge Gorenstein interpreted Rule 10(b) as applying to “claims and defenses” in “pleadings,” rather than to other documents. Komatsu then filed an objection to that order.

Standard of Review

The district court reviewed the magistrate judge’s ruling under Federal Rule of Civil Procedure 72(a) and 28 U.S.C. § 636(b)(1)(A). Under that standard, the district court could modify or set aside the ruling if it was clearly erroneous or contrary to law. A ruling is clearly erroneous when the reviewing court is firmly convinced that a mistake was made, even though evidence supports the ruling. A ruling is contrary to law when it fails to apply, or misapplies, relevant statutes, case law, or procedural rules. Magistrate judges’ rulings on nondispositive matters—matters that do not finally resolve the case—receive substantial deference.

Ruling

Judge Lorna G. Schofield overruled Plaintiff’s objection to Judge Gorenstein’s November 13, 2020, order. The court held that Judge Gorenstein’s interpretation of Rule 10(b) as applying only to pleadings, such as a complaint or answer, was not clearly erroneous or contrary to law.

The Clerk of Court was directed to mail a copy of the order to the pro se plaintiff. The opinion does not decide the anticipated motion to compel itself.