Samuels v. Barnard College
- Paul Engelmayer
- 1:23-cv-06181
- U.S. District Court · Southern District of New York
- 2
In Samuels v. Barnard College, Judge Cave denied Justin Samuels’s request for a bench trial while Barnard’s dismissal motion remained pending.
Justin Samuels’s request for a bench trial was denied; Barnard College’s motion to dismiss remained pending.
What happened
In Samuels v. Barnard College, pro se plaintiff Justin Samuels asked for a bench trial while Barnard College’s motion to dismiss his Second Amended Complaint was pending.
The court denied the request because the motion to dismiss asks whether the complaint adequately states claims, not whether evidence proves those claims at trial. The court said a bench trial was therefore inappropriate at that stage.
The court also said it would consider Samuels’s request for oral argument and schedule argument if appropriate. The order was issued by United States Magistrate Judge Sarah L. Cave.
The detailed version
- Samuels v. Barnard College · No. 1:23-cv-06181
- Paul Engelmayer
- Apr. 16, 2024
Background
Justin Samuels, who represented himself, asked the court to hold a bench trial in connection with Barnard College’s pending motion to dismiss. The motion challenges whether the claims in Samuels’s Second Amended Complaint are legally sufficient.
Court’s analysis
The court explained that a motion to dismiss under Federal Rule of Civil Procedure 12(b)(6) addresses whether the complaint contains enough factual allegations to support a possible right to relief. A bench trial would instead evaluate whether the evidence supports liability. Because the pending motion concerned the sufficiency of the complaint rather than the sufficiency of trial evidence, the court found a bench trial inappropriate at that stage.
Ruling
Judge Sarah L. Cave denied Samuels’s request for a bench trial. The court stated that it would consider Samuels’s request for oral argument on the motion to dismiss and would schedule oral argument if the court deemed it appropriate.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.