Nicholas G. Garaufis
How Judge Garaufis rules, drawn from 24 signed orders. Every observation links to the order it came from.
About Judge Garaufis
Nicholas Garaufis is a judge of the United States District Court for the Eastern District of New York. Appointed by President William J. Clinton, Judge Garaufis received a commission on May 25, 2000. Judge Garaufis assumed senior status on October 1, 2014.
Judge Garaufis's practices and standing orders
Rules for cases before Judge Garaufis, as published on the court's website (checked October 8, 2026). Judges revise these often, so confirm the current version on the court's site before you file.
Key rules
Motions
Suggest a briefing schedule for court approval.
“Subject to court approval, the parties are to suggest their own briefing schedule.”
Conferences
Request an appearance adjournment at least 48 hours in advance absent an emergency.
“Requests for adjournment of a court appearance must, absent an emergency, be made at least 48 hours prior to the scheduled appearance.”
Standing orders for every case in this court
Orders the court applies to all of its cases, whichever judge has them, as published on the court's website (checked October 10, 2026).
How Judge Garaufis decides
Patterns drawn from this judge's own signed orders. Every observation links to the order it came from.
What persuades
In an employment-discrimination case, he found that a decisionmaker’s alleged remark at the time of the adverse action was more than a stray remark and supported a triable inference of bias.
“Rodriguez's alleged comment was ‘less a 'stray' remark than an open declaration of bias. It not only reflected a highly discriminatory attitude, but also came at the time of the [adverse employment action] and referred directly to [Plaintiffs] tenure with [Wyckoff] in negative terms.’”
Procedural preferences
In Torres v. United States, he held that proof of mailing alone did not establish receipt of the plaintiff’s FTCA notices of claim and allowed sixty days to submit proof of actual receipt.
“this court agrees that actual proof of receipt is required.”
In a foreclosure case, he found no clear error in an unopposed report and recommendation and adopted it as modified, declining at that time to appoint the plaintiffs’ proposed referee.
“The court finds no clear error, but declines to appoint Susan E. Rizos, Esq. as referee at this time. Accordingly, the court ADOPTS the R&R as modified, and GRANTS Plaintiffs motion for default judgment.”
When denying TD Bank’s interpleader request without prejudice, he treated a months-long delay in seeking the remedy as undermining a real and reasonable fear of multiple liability, alongside unmet deposit, service, and diversity requirements.
“This delay vitiates a finding of real fear of multiple liability.”
Cautions
Retaliation and discrimination claims need a tight causal connection: a long temporal gap between protected activity and the adverse action negates the inference, and a pro se plaintiff must still establish he was 'qualified' for the position to make out a prima facie case.
“A twenty-year span between a protected activity and an alleged adverse employment action is far too removed to constitute the causal connection necessary to state a retaliation claim.”
In a motion for reconsideration, he applied the strict standard against repetitive arguments on issues already considered by the court.
“Courts narrowly construe and strictly apply these principles to avoid ‘repetitive arguments on issues that have already been considered fully by the court.’”
In United States v. Chang, he denied a motion to dismiss a superseding wire-fraud-conspiracy count as untimely because it narrowed the earlier charge. He also declined to revisit a prior venue ruling without a compelling reason.
“Superseding charges that narrow, rather than broaden, are timely, so the removal of the Exchange investors does not affect the timeliness of the Third Superseding Indictment.”
Signed rulings
A grounded sample of orders signed by this judge, with the verbatim dispositive language.
“For the reasons stated above. Defendants' Motions for Summary Judgment( Dkts. 82, 91) are DENIED.”
“the court GRANTS Amazon's motion for summary judgment and DENIES Won's cross-motion for partial summary judgment.”
“For the foregoing reasons, the defendants' motion for summary judgment is GRANTED.”
“the Defendant's motion to dismiss Count One of the Third Superseding Indictment is DENIED.”
“As Plaintiff's amendments would be futile, his motion for reconsideration is therefore DENIED.”
“the court ADOPTS the R&R as modified, and GRANTS Plaintiffs motion for default judgment.”
“Defendants' motion for dismissal of Plaintiff's constitutional tort claims is GRANTED, and Plaintiff's challenges to his deportations from the United States are DENIED.”
“For the foregoing reasons, Defendants' motion to dismiss is GRANfED, and Defendants' motion to sever is DENIED as moot.”
“As Plaintiffs' claims are dismissed, Defendants' motion to sever is denied as moot.”
“the Defendants' motion to dismiss for failure to state a claim upon which relief can be granted pursuant to Rule 12(b)(6) ... which has been converted by this court into a motion for summary judgment pursuant to Rule 56 ... is hereby GRANTED in part and DENIED in part.”
“For the reasons set forth above, the moving Defendants' motion to dismiss is DENIED on all grounds.”
“The court DENIES Defendant Xi Liu's motion to dismiss (Dkt. 128).”
“For the foregoing reasons, Defendants' motion to dismiss is DENIED.”
Caseload & timing
From public federal docket records for this judge.
Median case duration in the sampled dockets: 89 days (N = 15).
- Garaufis is a long-tenured Brooklyn judge who took senior status in 2014 but remained actively assigned civil and criminal cases.
- Recent intake includes securities, False Claims Act, immigration, family-leave, and criminal matters.
- In the terminated-case sample, serial ADA public-accommodation suits, immigration actions, and miscellaneous matters often close within days or months, usually through settlement or dismissal, while contested civil-rights, insurance, and prisoner cases run for years.
- His criminal docket has included the NXIVM prosecution and the Manuel Chang fraud trial.
Pending matters in the official report
Reported by the Administrative Office of the U.S. Courts under the Civil Justice Reform Act, as of March 31, 2026.
| Motions pending more than six months | 0 |
| Bench trials submitted more than six months | 0 |
| Bankruptcy appeals pending more than six months | 0 |
| Social Security appeals pending more than six months | 0 |
| Civil cases pending more than three years | 38 |
| Report | Motions over six months | Cases over three years |
|---|---|---|
| Mar 2026 | 0 | 38 |
| Sep 2025 | 2 | 31 |
| Mar 2025 | 0 | 41 |
| Sep 2024 | 0 | 37 |
| Mar 2024 | 2 | 43 |
| Sep 2023 | 0 | 47 |
| Mar 2023 | 0 | 47 |
| Sep 2022 | 1 | 61 |
| Mar 2022 | 2 | 61 |
| Sep 2021 | 2 | 57 |
| Mar 2021 | 6 | 55 |
| Sep 2020 | 9 | 48 |
A snapshot on that date: matters listed may since have been decided or reassigned. A motion referred to a magistrate judge is counted for both judges. Motions in multidistrict litigation, section 2255 cases and Social Security appeals are not counted, and a very large three-year count is generally a multidistrict docket. Source: Appendix A of the report (PDF); about the report.
How long civil cases take in this court
For the whole of U.S. District Court for the Eastern District of New York, not for Judge Garaufis: median time from filing to disposition of the civil cases the court closed in the 12 months ending September 30, 2025, as reported by the Administrative Office of the U.S. Courts.
| Cases | Median time | |
|---|---|---|
| All civil cases closed | 7,392 | 6.7 months |
| Closed with no court action | 1,485 | 3 months |
| Closed before pretrial | 5,022 | 6.9 months |
| Closed during or after pretrial | 835 | 13.9 months |
| Closed during trial | 50 | 49.6 months |
| 12 months ending | Cases closed | Median time |
|---|---|---|
| Sep 2025 | 7,392 | 6.7 months |
| Sep 2024 | 7,879 | 5.8 months |
| Sep 2023 | 7,746 | 5.1 months |
| Sep 2022 | 7,588 | 6.2 months |
| Sep 2021 | 6,709 | 7.9 months |
| Sep 2020 | 6,062 | 8.6 months |
| Sep 2019 | 6,858 | 8.1 months |
The table leaves out prisoner petitions, land condemnations, deportation reviews, recovery of overpayments and enforcement of judgments, and reports no median for fewer than 10 cases. A district that closed a large multidistrict litigation in the period shows very large counts and long medians for that year. Source: Table C-5, U.S. District Courts (spreadsheet).
Draft for Judge Garaufis with the record in hand
Ezel grounds your drafting and research in this profile: what has persuaded Judge Garaufis, and what has not, cited to the signed orders.
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