Forjan v. The U.S. Environmental Protection Agency, 3:19-cv-01209

Pro se plaintiff Dave J. Forjan sued the U.S. Environmental Protection Agency and three EPA officials in a civil-rights action.
Magistrate Judge Miroslav Lovric denied Forjan’s motion to proceed in forma pauperis (IFP) without prejudice and issued a Report-Recommendation (R&R) recommending sua sponte dismissal of the Complaint under 28 U.S.C. § 1915(e)(2)(B) for failure to state a claim and frivolousness.
Forjan appealed the IFP denial and filed objections to the R&R; he also moved for a temporary restraining order, preliminary injunction, and permanent injunction.
The district court reviewed the magistrate judge’s IFP Order and R&R, finding Forjan’s appeal and objections non‑specific and thus not showing clear error or law contrary to the magistrate’s rulings.
The district court affirmed the IFP denial, accepted and adopted the R&R, and sua sponte dismissed the Complaint under § 1915(e)(2)(B).
Forjan’s injunctive motions were denied both as moot (because the underlying claims were dismissed) and alternatively as procedurally improper and unsupported by a showing of cause.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the magistrate judge's Order denying IFP was clearly erroneous or contrary to law	Forjan asserted the IFP denial was incorrect	Magistrate's factual/financial finding and procedural ruling were proper	Affirmed — no clear error or contrary-to-law shown
Whether the R&R should be rejected based on Forjan's objections	Forjan objected to the R&R generally	Objections were non‑specific and insufficient to preserve de novo review	R&R entitled to clear‑error review and survives; alternatively survives de novo review
Whether the Complaint should be sua sponte dismissed under 28 U.S.C. § 1915(e)(2)(B)	Forjan contended his claims had merit	Dismissal appropriate for failure to state a claim / frivolousness	Complaint sua sponte dismissed under § 1915(e)(2)(B)
Whether injunctive relief (TRO, preliminary, permanent) should issue	Forjan sought injunctive relief related to dismissed claims	Motions are moot given dismissal, and procedurally improper and unsupported	Denied as moot and, alternatively, procedurally improper and unsupported

Mario v. P&C Food Markets, Inc., 313 F.3d 758 (2d Cir. 2002) (objections to magistrate report must be specific to preserve a claim for review)
Brown v. Peters, 175 F.3d 1007 (2d Cir. 1999) (affirming district-court practice requiring specific objections to R&R)