Ross Matthew Cataffo, proceeding pro se, appealed a district court order that had accepted a magistrate judge's recommendation to deny relief on his complaint. The case originated in the United States District Court for the Southern District of West Virginia. Under 28 U.S.C. § 636(b)(1)(B), the district court referred the case to a magistrate judge, who recommended denial of relief. Crucially, the magistrate judge advised Cataffo that failing to file timely and specific objections to this recommendation would waive his right to appellate review of the district court's order. Cataffo did not file such objections.
The Fourth Circuit applied the established standard for preserving issues for appeal when a magistrate judge's recommendation is involved. The court cited Martin v. Duffy, 858 F.3d 239, 245 (4th Cir. 2017), Wright v. Collins, 766 F.2d 841, 846-47 (4th Cir. 1985), and Thomas v. Arn, 474 U.S. 140, 154-55 (1985). These authorities mandate that when parties are warned of the consequences of noncompliance, the timely filing of specific objections is necessary to preserve appellate review of the substance of the magistrate judge's recommendation. Because Cataffo failed to file objections after receiving proper notice, the court found he had forfeited his right to appellate review. Consequently, the court could not reach the merits of any underlying constitutional claims.
The appeal is dismissed, leaving the district court's order denying relief in place. Cataffo's motions for appointment of counsel were also denied. The decision reinforces the strict procedural requirement that parties must actively object to magistrate recommendations to avoid forfeiting their right to appeal, even in pro se cases.