Huang v. Amazon.Com, Inc.

Background

Bai Lin Huang, proceeding without a lawyer, sued Amazon.com, Inc. and JP Morgan Chase. She asserted racial-discrimination claims under 42 U.S.C. § 1981 and intentional-infliction-of-emotional-distress claims under New York law. The claims arose from the alleged closure of her Amazon accounts and an Amazon-Chase credit card.

Chase moved to dismiss under Federal Rule of Civil Procedure 12(b)(6) on August 8, 2022. Amazon filed a similar motion on September 7, 2022. Both defendants argued that Huang’s claims were filed too late and, alternatively, that the complaint did not adequately state a legal claim.

Magistrate Judge’s Report

Magistrate Judge Sarah L. Cave recommended granting the motions. The report recommended dismissing with prejudice Huang’s Section 1981 claims based on the alleged 2018 closure of the Amazon-Chase credit card and her intentional-infliction-of-emotional-distress claims as time-barred. It recommended dismissing without prejudice, with leave to amend, Huang’s Section 1981 claim against Amazon based on the December 2018 closure of her Amazon accounts.

The report advised the parties that they had 14 days to object and that failing to object would waive further review and prevent appellate review. Neither party objected by the February 14, 2023 deadline.

Court’s Analysis and Ruling

Because no timely objection was filed, Judge Jennifer L. Rochon reviewed the report for clear error rather than conducting a full review. The court found that the report’s reasoning was sound and not clearly erroneous, and adopted it in its entirety.

The court GRANTED Defendants’ motions to dismiss. It held that Huang’s Section 1981 claims based on the alleged 2018 closure of the Amazon-Chase credit card and her intentional-infliction-of-emotional-distress claims were DISMISSED WITH PREJUDICE as time-barred. Because those were the only claims against Chase, Chase was dismissed from the case.

The court held that Huang’s Section 1981 claim against Amazon concerning the December 2018 closure of her Amazon accounts was DISMISSED WITHOUT PREJUDICE and with leave to amend. The court permitted an amended complaint by March 8, 2023, limited to that claim and not the claims dismissed with prejudice. The court also stated that the absence of timely objections precluded appellate review and directed the clerk to terminate Chase and the two dismissal motions from the case.