2 Opinion of the Court 25-12445 Karen D. Lamb, proceeding pro se, sued her former em- ployer, JG Management Services, Inc. ("JGM"), bringing claims un- der Title VII for employment discrimination and retaliation. While the case was pending, the magistrate judge denied motions in which Lamb sought his recusal and requested that the court sanc- tion JGM. The district court ultimately dismissed Lamb's amended complaint, concluding that she failed to state a claim for relief. On appeal, Lamb challenges the dismissal of her amended complaint as well as the magistrate judge's orders denying the recusal and sanctions motions. After careful consideration, we af- firm.
I.
Lamb, a Black woman, worked at JGM as a senior support engineer.1She was one of three employees on the support team, which worked to resolve "simple and complex issues reported by customers in a timely manner." Doc. 8 at 10.2Although each mem- ber of the team worked remotely, they consulted with each other through online messages, phone calls, and video conferences. Lamb says that beginning in December 2021, she was har- assed by another member of the support team, Paul Raulerson. She says that in online messages and meetings, Raulerson, a white
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25-12445 Opinion of the Court 3 male, made "personal attacks on [her] character, skills, ability[,] and desire to provide quality resolutions to customers." Id. According to Lamb, the problems began when Raulerson disagreed with how she handled a customer's request for assis- tance. Raulerson told Lamb that "he felt disrespected" by how she had handled the incident and stated that she was not a "team player." Id. After this incident, Lamb says that Raulerson's mes- sages and comments at meetings "escalated to unwelcome harass- ment and consistent disruptions" as he tried to harm her "reputa- tion with false and negative" comments about her work. Id. at 10-
11.
Lamb reported Raulerson's conduct to Larry Rondot, the manager of the support team, and asked him to address it. On mul- tiple occasions, Rondot directed Raulerson "to cease his unprofes- sional conduct." Id. at 11. Rondot agreed to be present "on calls/ meetings between [Lamb] and Raulerson whenever possible to help monitor Raulerson's behavior when the two needed to discuss customer issues." Id. at 12. Still, Lamb says that Raulerson's harass- ing conduct continued.
In May 2022, Rondot and two JGM executives met with Lamb and Raulerson. At the meeting, they discussed Lamb and Raulerson's different "troubleshooting styles" and reminded the two to be "professional." Id. at 13. At the meeting, Lamb requested
"a proper resolution to the [h]arassment issue" but was told that it was a "non-issue and would not be discussed further." Id.
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4 Opinion of the Court 25-12445 A few months later, in October, Lamb had difficulty com- pleting a project that was one of her performance goals for the year. She told Rondot that she needed a virtual server to complete the project. Although Rondot agreed to help, he never obtained a vir- tual server for her, and she was unable to complete the project. At her year-end evaluation in December, Rondot gave Lamb a low performance rating because she had not completed the pro- ject. About ten days later, Lamb and Rondot met again. This time two other company executives attended the meeting. They told Lamb that she was terminated, citing "poor performance and the issue [she] had with" Raulerson. Id. at 15.
After her termination, Lamb filed a charge of discrimination with the Equal Employment Opportunity Commission ("EEOC"). The EEOC gave her a right-to-sue letter.
Lamb, proceeding pro se, filed a lawsuit against JGM in fed- eral court. In her initial complaint, she brought three Title VII claims. First, she brought a claim for a hostile work environment, alleging that Raulerson had harassed her. Second, she brought a retaliation claim, alleging that she was terminated because she complained about the harassment. Third, she brought a race dis- crimination claim arising out of her termination. JGM filed a mo- tion to dismiss, arguing that the complaint failed to state a claim for relief.
A magistrate judge concluded that the complaint "failed to state a plausible claim for relief on any of the claims asserted."
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25-12445 Opinion of the Court 5 Doc. 7 at 1-2. As to the hostile work environment claim, he ex- plained that the complaint alleged only that "Raulerson engaged in 'personal attacks' and 'unprofessional conduct'" without showing that the "allegedly offensive or unprofessional statements were based on [Lamb's] race." Id. at 11. The magistrate judge deter- mined that the complaint's "conclusory and non-specific reference to Raulerson making 'personal attacks' and 'unprofessional con- duct'" failed to plausibly allege that any harassment was severe or pervasive. Id. at 12. He thus concluded that the complaint failed to state a claim for a hostile work environment.
The magistrate judge also determined that the complaint failed to state a claim for retaliation. Although Lamb alleged that she lodged complaints about Raulerson, the magistrate judge stated that "not all complaints about workplace incivility are pro- tected under Title VII." Id. at 13. To state a claim for retaliation, the magistrate judge explained, Lamb had to allege facts showing that "she specifically opposed race-based harassment or other acts of discrimination, and that there was an objectively reasonable ba- sis to conclude that the conduct she was complaining about was illegal under Title VII." Id. at 13-14. He determined that the
"largely conclusory facts in [the] complaint [were] not sufficient to establish these elements." Id. at 14.
The magistrate judge also concluded that the complaint failed to state a claim that Lamb was terminated because of her race. He explained that the complaint "was absent of facts that sug-
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6 Opinion of the Court 25-12445 gest[ed] . . . disparate treatment on grounds of race." Id. at 11. Be- cause Lamb failed to "provide non-conclusory, factual allegations to allow a plausible inference of race-based discrimination," the magistrate judge determined that she failed to state a claim. Id. at
12.
The magistrate judge then explained that because Lamb was proceeding pro se, she was entitled to an opportunity to amend the complaint to cure the deficiencies. He gave her an opportunity to file an amended complaint.3
Lamb filed an amended complaint. She asserted that she was discriminated against based on her race and sex.4She repeatedly alleged that she was subject to "[h]arassment" and a "hostile work environment." Doc. 8 at 13.
She also added allegations that before Raulerson began to harass her, he expressed "stereotyped views of non-white races."
Id. at 11. She alleged that Raulerson had said that "East Indian peo- ple . . . are lazy" and "don't want to work." Id. (citation modified). He also made comments about not "driving into the office for fear or concern about driving through bad neighborhoods." Id. And she reported that Raulerson announced he was a "misogynist." Id.
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25-12445 Opinion of the Court 7 In the amended complaint, Lamb asserted that JGM termi- nated her for poor performance without placing her on a perfor- mance improvement plan or warning her. She alleged that a deter- mination that her performance was poor was a "highly invalid as- sessment of [her] and her work ethic." Id. at 16. In the amended complaint, Lamb again raised three claims under Title VII. She alleged that she was subjected to a hostile work environment, terminated in retaliation for reporting harass- ment, and terminated because of her race or sex. She alleged that she was subjected to "pervasive" harassment from Raulerson. Id. at
18. And she asserted that she engaged in protected conduct when she reported Raulerson's conduct to Rondot and at the May 2022 meeting with Rondot and company executives.
JGM moved to dismiss the amended complaint. It again ar- gued that Lamb had failed to state a claim for relief. While the motion to dismiss was pending, Lamb filed a mo- tion seeking the magistrate judge's recusal on the ground that he had erroneously entered the order directing her to file an amended complaint. She argued that the magistrate judge lacked authority to enter the order because she had not consented to his hearing the case.
The magistrate judge denied the motion for recusal. He acknowledged that in general "unanimous consent of the parties is required for a Magistrate Judge to preside over a civil case, conduct trials, resolve dispositive motions, and enter judgment." Doc. 11 at 1 (citing 28 U.S.C. § 636(c)(1)). But he explained that, even without
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8 Opinion of the Court 25-12445 the parties' consent, a district court could refer a civil case to a mag- istrate judge for the magistrate judge to "resolve non-dispositive pretrial matters" and to "issue recommended rulings (also known as a 'Report and Recommendation') on dispositive issues." Id. (cit- ing 28 U.S.C. § 636(b)).
The magistrate judge then explained that pursuant to a standing order in the Northern District of Georgia, Lamb's case had been referred to him to resolve non-dispositive matters and is- sue reports and recommendations on dispositive matters. Because the case had been properly assigned to him, the magistrate judge denied the motion for recusal.
While the motion to dismiss the amended complaint re- mained pending, Lamb sought sanctions against JGM under Fed- eral Rule of Civil Procedure 11. She asserted that JGM had told an EEOC investigator that she was terminated for poor performance and that the company had previously counseled her about her per- formance. But Lamb alleged in her amended complaint that the company had not provided her with any counseling related to poor performance. She urged the district court to sanction JGM for tell- ing the EEOC that she had "documented poor performance."
Doc. 14 at 3.
The magistrate judge issued a report and recommendation that the district court grant the motion to dismiss the amended complaint. He concluded that the amended complaint failed to
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25-12445 Opinion of the Court 9 state a claim: for a hostile work environment, that Lamb was ter- minated in retaliation for engaging in protected conduct, or that she was terminated because of her race or sex. Along with recommending that the district court grant JGM's motion to dismiss the amended complaint, the magistrate judge denied Lamb's motion for sanctions. He explained that she was seeking sanctions against JGM "for allegedly making false or misleading statements to the EEOC." Doc. 16 at 25. The magistrate judge noted that Lamb was "not complain[ing] of any pleadings submitted before this Court" and denied the motion for sanctions. Id. at 26.
Lamb objected to the magistrate judge's recommendation that the court dismiss the amended complaint. She also argued that the magistrate judge erred in denying her motions to recuse and for sanctions.
In a thorough order, the district court adopted the magis- trate judge's recommendation and dismissed the amended com- plaint. It also rejected Lamb's challenges to the magistrate judge's orders on the motions to recuse and for sanctions. The court began with the magistrate judge's orders on Lamb's motions. As to the motion to recuse, the court determined that Lamb's challenge to the magistrate judge's order was untimely because she filed it more than 14 days after the magistrate judge issued the order denying the motion for sanctions. But even if Lamb had filed a timely challenge, the court concluded that the magistrate judge's decision denying the motion for recusal was not
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10 Opinion of the Court 25-12445
"clearly erroneous or contrary to law" because he was authorized
"to handle pretrial matters in civil cases." Doc. 20 at 5. The court also rejected Lamb's challenge to the decision denying the motion for sanctions. The court agreed with the mag- istrate judge that sanctions were not warranted because Lamb had not alleged that JGM "made false statements in its pleadings to this Court." Id. at 6.
The court then addressed the motion to dismiss the amended complaint. After de novo review, it determined that the amended complaint failed to state a claim.
For the hostile work environment claim, the court explained that to state a claim, Lamb had to allege that the harassment she faced was "sufficiently severe or pervasive," meaning that it was both "subjectively and objectively hostile." Id. at 9 (citation modi- fied). The court focused on whether the amended complaint's alle- gations established that the harassment was "objectively hostile."
Id. It credited Lamb's assertion that Raulerson engaged in harass- ment "almost daily." Id. at 10. But it noted that the amended com- plaint failed to "provide[] details about what the harassment or crit- icism was." Id. The court explained that the only allegation about the harassment was that it consisted of "personal attacks on [Lamb's] character, skills, ability, and desire to provide quality [ser- vice] to customers." Id. (citation modified). Given the lack of detail, the court concluded that the amended complaint "wholly fail[ed] to allege repeated instances of intimidation, insult[,] or ridicule that
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25-12445 Opinion of the Court 11 together amount to a particularly severe or pervasive harassment."
Id. (citation modified).
Next, the court considered whether Lamb had stated a claim for retaliation. It explained that to state a retaliation claim, Lamb had to allege that, among other things, she had "engaged in statu- torily protected expression"—that is, that she "complain[ed] about a practice made unlawful by Title VII, i.e., discrimination based on race, color, religion, sex, or national origin." Id. at 11-12 (citation modified). Because there was no indication in the amended com- plaint that Lamb told JGM that Raulerson was harassing her based on her race or gender, the court concluded that the amended com- plaint failed to state a retaliation claim.
Finally, the court turned to Lamb's discrimination claim arising from her termination. It explained that to state a claim for race or sex discrimination, Lamb had to "allege facts that support a reasonable inference that . . . the reason for [her termination] was intentional discrimination." Id. at 13. Although Lamb had asserted that Raulerson's actions were motivated by race or gender, the court determined that there were no allegations that supported an inference that JGM was "motivated by race and gender." Id. at 14. Because the allegations in the amended complaint, even when viewed in the light most favorable to Lamb, "fail[ed] to suggest in- tentional discrimination," the court concluded that the amended complaint failed to state a race or sex discrimination claim for wrongful termination. Id.
Lamb appeals.
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12 Opinion of the Court 25-12445
II.
"We review the district court's grant of a motion to dismiss for failure to state a claim de novo, accepting the allegations in the complaint as true and construing them in the light most favorable to the plaintiff." Hunt v. Aimco Props., L.P., 814 F.3d 1213, 1221 (11th Cir. 2016). To survive a motion to dismiss under Federal Rule of Civil Procedure 12(b)(6), a complaint must include "enough facts to state a claim to relief that is plausible on its face." Bell Atl. Corp. v. Twombly, 550 U.S. 544, 570 (2007). The complaint's allegations must amount to "more than labels and conclusions, and a formu- laic recitation of the elements of a cause of action will not do." Id. at 555.
"A claim has facial plausibility when the plaintiff pleads fac- tual content that allows the court to draw the reasonable inference that the defendant is liable for the misconduct alleged." Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009). "[W]hen determining whether the complaint crosses the line between possibility and plausibility of entitlement to relief, courts may infer from the factual allegations in the complaint obvious alternative explanations, which suggest lawful conduct rather than the unlawful conduct the plaintiff would ask the court to infer." Doe v. Samford Univ., 29 F.4th 675, 686 (11th Cir. 2022) (citation modified); see Twombly, 550 U.S. at 554 (holding that allegations of wrongdoing were not plausible because the facts alleged were "consistent with [liability], but just as much in line with a wide swath of" lawful conduct).
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25-12445 Opinion of the Court 13 We review for abuse of discretion a decision denying a mo- tion for recusal. See Gwynn v. Walker, 532 F.3d 1304, 1308 (11th Cir. 2008). We also review for abuse of discretion an order denying a motion for sanctions. See Didie v. Howes, 988 F.2d 1097, 1103 (11th Cir. 1993). "The abuse of discretion standard allows a range of choice for the district court, so long as that choice does not consti- tute a clear error of judgment." Savoia-McHugh v. Glass, 95 F.4th 1337, 1342 (11th Cir. 2024) (citation modified). "A district court abuses its discretion if it applies an incorrect legal standard, applies the law in an unreasonable or incorrect manner, follows improper procedures in making a determination, or makes findings of fact that are clearly erroneous." Id. (citation modified). Pro se filings are liberally construed. Campbell v. Air Jam. Ltd.,
760 F.3d 1165, 1168 (11th Cir. 2014).
III.
On appeal, Lamb raises several challenges to the district court's orders. She argues that the district court erred in granting the motion to dismiss her amended complaint and challenges the denial of her motion seeking the magistrate judge's recusal and her motion for sanctions. We address each issue in turn.
A.
Title VII of the Civil Rights Act makes it unlawful for a pri- vate employer to "discharge any individual . . . because of such in- dividual's race . . . [or] sex." 42 U.S.C. § 2000e-2(a)(1). It also pro- hibits an employer from "discriminat[ing] against any individual with respect to [the] compensation, terms, conditions, or privileges
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14 Opinion of the Court 25-12445 of employment, because of such individual's race . . . [or] sex." Id. And it bars an employer from "discriminat[ing] against" an em- ployee because she "opposed any practice made an unlawful em- ployment practice" under Title VII. Id. § 2000e-3(a). In this case, Lamb raised three Title VII claims against JGM. She claimed that her employer was liable because (1) she was sub- jected to a hostile work environment, (2) she was terminated in re- taliation for reporting the harassment, and (3) she was terminated because of her race or sex. We consider each claim in turn.
1.
We begin with whether the amended complaint stated a claim for a hostile work environment. We have recognized that Title VII protects an employee from a hostile work environment— that is, mistreatment based on a protected characteristic that is so severe or pervasive that it can be said to alter the terms, conditions, or privileges of employment. Monaghan v. Worldpay US, Inc.,
955 F.3d 855, 861 (11th Cir. 2020); see McCann v. Tillman, 526 F.3d 1370, 1378 (11th Cir. 2008) (explaining that Title VII protects an employee from a "hostile work environment," which "involves re- peated conduct, such as discriminatory intimidation, ridicule, and insult" with the claim "based on the cumulative effect of individual acts" (citation modified)).
To state a hostile work environment claim under Title VII, a plaintiff must allege that: (1) she "belongs to a protected group,"
(2) she "was subjected to unwelcome harassment," (3) "the harass- ment was based on [her] membership in the protected group,"
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25-12445 Opinion of the Court 15
(4) the harassment was "severe or pervasive enough to alter the terms and conditions of employment and create a hostile or abu- sive working environment," and (5) her "employer is responsible for that environment under a theory of either vicarious or direct liability." Edwards v. Prime, Inc., 602 F.3d 1276, 1300 (11th Cir. 2010). To show that harassment was sufficiently "severe or perva- sive," an employee must establish that her work environment was
"both subjectively and objectively hostile." Fernandez v. Trees, Inc.,
961 F.3d 1148, 1153 (11th Cir. 2020). In determining whether har- assment was objectively hostile, courts consider: (1) "the frequency of the conduct"; (2) "the severity of the conduct"; (3) "whether the conduct [was] physically threatening or humiliating, or a mere of- fensive utterance"; and (4) "whether the conduct unreasonably in- terfere[d] with the employee's job performance." Id. (citation mod- ified).
We conclude that the amended complaint failed to state a claim for relief. It is true that the amended complaint alleged that Lamb faced a "hostile work environment" with "pervasive" harass- ment. Doc. 8 at 18. But, without more, these conclusory state- ments are insufficient to state a claim for relief. See Iqbal, 556 U.S. at 678 ("Threadbare recitals of the elements of a cause of action, supported by mere conclusory statements, do not suffice."). In- stead, we must look at whether the amended complaint "con- tain[ed] sufficient factual matter, accepted as true, to state a claim to relief that is plausible on its face." Id. (citation modified).
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16 Opinion of the Court 25-12445 We agree with the district court that the amended complaint lacked sufficient factual matter to state a plausible claim that any harassment was sufficiently severe or pervasive. Although Lamb asserted that the harassment was frequent and occurred almost daily, the amended complaint contained limited information about what the harassment involved. As the district court correctly ex- plained, "the only relevant allegation" in the amended complaint was "that the harassment topics were personal attacks on [Lamb's] character, skills, ability, and desire to provide quality resolution to customers." Doc. 20 at 10 (citation modified). We agree with the district court that given the absence of any allegations indicating that the "harassment was severe, physically threatening[,] or hu- miliating," the amended complaint "fail[ed] to sufficiently allege facts" to state a plausible claim for a hostile work environment. Id.
2.
We now turn to Lamb's retaliation claim. As we mentioned above, Title VII's anti-retaliation provision makes it unlawful for an employer to discriminate against an employee because she op- posed a practice made an unlawful employment practice by Ti- tle VII. See 42 U.S.C. § 2000e-3(a). To state a claim for retaliation, a plaintiff must allege that, among other things, she "engaged in stat- utorily protected activity." Moore v. Grady Mem. Hosp. Corp.,
834 F.3d 1168, 1176 (11th Cir. 2016) (citation modified). We accept that an employee who complains that she was subject to a hostile work environment engaged in protected activity. To engage in pro- tected activity, a plaintiff is not required to make a "formal com- plaint" to her employer. Furcron v. Mail Ctrs. Plus, LLC, 843 F.3d
16
25-12445 Opinion of the Court 17 1295, 1311 (11th Cir. 2016). Still, she must have "explicitly or im- plicitly communicated" her belief that the employer's practice con- stituted unlawful employment discrimination. Id. (citation modi- fied). An employee who complains to her employer about unfair treatment but does not connect the treatment to a protected clas- sification does not engage in statutorily protected activity. See Coutu v. Martin Cnty. Bd. of Cnty. Comm'rs, 47 F.3d 1068, 1074 (11th Cir. 1995).
We conclude that Lamb failed to state a retaliation claim be- cause the amended complaint did not plausibly allege that she en- gaged in protected activity. Certainly, Lamb alleged that she re- ported Raulerson's treatment to her supervisor and company exec- utives. But the allegations show that she reported only that Raulerson's communications lacked civility and included harsh comments about her job performance. Because nothing in the amended complaint suggests that Lamb's reports to JGM indicated that Raulerson's comments and actions were tied to her race or sex, we conclude that she failed to plausibly allege that she engaged in statutorily protected conduct and thus failed to state a retaliation claim. See id.
3.
We now consider whether the amended complaint stated a plausible Title VII claim for wrongful termination based on race or sex. To withstand a motion to dismiss, a plaintiff bringing a Ti- tle VII race or sex discrimination claim that she was wrongfully ter- minated must "provide enough factual matter (taken as true) to
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18 Opinion of the Court 25-12445 suggest intentional race [or sex] discrimination." Davis v. Coca-Cola Bottling Co. Consol., 516 F.3d 955, 974 (11th Cir. 2008) (quoting Twombly, 550 U.S. at 556). In other words, the complaint must
"provide enough factual material to raise a reasonable inference, and thus a plausible claim," that the employer terminated the em- ployee because of her race or sex. Speaker v. U.S. Dep't of Health & Hum. Servs., 623 F.3d 1371, 1386 (11th Cir. 2010).5 Here, we conclude that the allegations in Lamb's amended complaint, taken as true, do not suggest intentional discrimination. We agree entirely with the district court's analysis that the amended complaint failed to state a claim because it included no allegations that suggested that JGM's decision to terminate Lamb was "motivated by race [or] gender." Doc. 20 at 14.
B.
We now consider Lamb's challenge to the magistrate judge's decision not to recuse himself from this case. Lamb argues that the magistrate judge was required to recuse himself because he was never assigned to her case and thus lacked any authority to issue orders in it. According to Lamb, the magistrate judge lacked
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25-12445 Opinion of the Court 19 authority because the parties had not consented to proceeding be- fore him. We see no error. Instead, we conclude that the magistrate judge had authority to enter the non-dispositive orders in this case and issue the report and recommendation that the court dismiss the amended complaint.
A federal statute sets forth the powers of magistrate judges. See 28 U.S.C. § 636. Under this statute, when the parties consent, a magistrate judge may "conduct any or all proceedings in a jury or nonjury civil matter and order the entry of judgment in the case."
Id. § 636(c)(1).
The same statute also authorizes a magistrate judge to act in certain cases without the consent of the parties. A district court may "designate a magistrate judge to hear and determine any pre- trial matter" in a civil case, unless the matter concerns a dispositive motion, such as a motion to dismiss, or certain other specified mo- tions. Id. § 636(b)(1)(A). As to pretrial matters that do not concern dispositive motions, a district court may "reconsider" a magistrate judge's ruling only when "it has been shown that the magistrate judge's order is clearly erroneous or contrary to law." Id. A party must seek review of a magistrate judge's order from the district court "within 14 days after being served with" the magistrate judge's order. Fed. R. Civ. P. 72(a).
As for dispositive motions, such as a motion to dismiss, the same statute authorizes the district court to designate a magistrate judge to conduct hearings and to submit a recommendation re- garding the disposition of the motion. 28 U.S.C. § 636(b)(1)(B). If a
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20 Opinion of the Court 25-12445 party serves a timely objection to the magistrate judge's recom- mendation, then the district court makes "a de novo determination of those portions of the . . . recommendations to which objection is made." Id. § 636(b)(1); see Fed. R. Civ. P. 72(b)(3). In this case, Lamb is correct that the parties never consented to proceeding before a magistrate judge. Even so, the magistrate judge was authorized to act in this case. This is because the North- ern District of Georgia has a standing order directing that any case in which a party asserts a Title VII claim is referred to a magistrate judge to "hear and determine any pretrial matters pending before the Court and to conduct hearings and submit reports and recom- mendations to the full extent allowed by 28 U.S.C. § 636(b)(l)(A) and (B)." N.D. Ga. Standing Order 18-01. After considering § 636 and the standing order, we conclude that the magistrate judge did not exceed his authority in this case, even though the parties did not consent to proceeding before a magistrate judge.
C.
Finally, Lamb challenges the denial of her motion seeking sanctions under Federal Rule of Civil Procedure 11. This rule provides that by presenting a pleading, written mo- tion, or other paper to a court, an attorney "certifies that to the best of [his or her] knowledge, information, and belief," the "factual contentions have evidentiary support or . . . will likely have eviden- tiary support after a reasonable opportunity for further investiga- tion or discovery." Fed. R. Civ. P. 11(b)(3). If a court determines that Rule 11(b) has been violated, it may impose a sanction on the
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25-12445 Opinion of the Court 21
"attorney, law firm, or party that violated the rule or is responsible for the violation." Fed. R. Civ. P. 11(c). The purpose of Rule 11 is to discourage frivolous claims or defenses and abusive litigation tactics. Didie, 988 F.2d at 1104.
In this case, Lamb, in effect, sought sanctions based on alleg- edly false statements that JGM made to an EEOC investigator be- fore this lawsuit was filed. She identifies no sanctionable conduct while the case was pending. Neither the magistrate judge in deny- ing the motion nor the district court in overruling Lamb's chal- lenge to the magistrate judge's order was an abuse of discretion. See id.
IV.
For the above reasons, we AFFIRM.
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