Komatsu v. The City of New York
- Lorna Schofield
- 1:18-cv-03698
- U.S. District Court · Southern District of New York
- 2
In Komatsu v. City of New York, Judge Schofield overruled Komatsu’s objections and upheld Judge Gorenstein’s discretionary discovery extension.
Towaki Komatsu and the other parties to the action were affected by the ruling continuing the discovery deadline to March 1, 2021.
What happened
In Komatsu v. The City of New York, Judge Gorenstein extended the discovery deadline to March 1, 2021. Towaki Komatsu, who represented himself, objected in two letters.
The court reviewed the objections under the standard for correcting a magistrate judge’s ruling on a routine matter. It would change the ruling only if it was clearly mistaken, contrary to law, or an abuse of discretion.
Judge Lorna G. Schofield overruled Komatsu’s objections and ruled that Judge Gorenstein acted within his discretion in extending the discovery deadline. The Clerk was directed to mail the order to Komatsu.
The detailed version
- Komatsu v. The City of New York · No. 1:18-cv-03698
- Lorna Schofield
- Dec. 10, 2020
Background
On November 24, 2020, Judge Gorenstein extended the discovery deadline in this action to March 1, 2021. Towaki Komatsu filed letters on November 28 and December 4 objecting to that extension. The order identifies Komatsu as proceeding without a lawyer.
Legal standard
The court treated the challenge as an objection to a magistrate judge’s ruling on a nondispositive matter—one that does not finally decide a claim or defense. Under Federal Rule of Civil Procedure 72(a) and 28 U.S.C. § 636(b)(1)(A), a district court may modify or set aside such a ruling if it is clearly erroneous or contrary to law. The court explained that a ruling is clearly erroneous when the reviewing court is firmly convinced that a mistake occurred, and that a ruling is contrary to law when it fails to apply or misapplies relevant law or procedural rules. The court also stated that a magistrate judge’s schedule modification is reviewed for abuse of discretion.
Ruling
The court ORDERED that Komatsu’s objections to Judge Gorenstein’s November 24, 2020, order were overruled. Judge Schofield ruled that Judge Gorenstein acted within his discretion when he extended the discovery deadline. The Clerk of Court was directed to mail a copy of the order to Komatsu.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.