Shyamal Ghosh v. New York City Housing Authority

Whether, consistent with Thomas v. Am, 474 U.S. 140 (1985), a court of appeals may refuse to excuse a pro se litigant’s failure to object to a magistrate judge’s report and recommendation under the nonjurisdictional forfeiture rule when the record reflects health-related and communication difficulties affecting compliance with court deadlines.

Whether a court of appeals may treat the failure to object to a magistrate judge’s report and recommendation as a complete bar to appellate merits review of a pro se litigant’s federal employment­ discrimination claims, where those claims were dismissed at the pleading stage before any factual record was developed through discovery. -i-