Waggener van Meter v. Mondelez International, Inc.

Background

Megan Waggener van Meter filed a proposed class action against Mondelez International, Inc. She alleged that Mondelez’s sustainability and sourcing labels misled consumers into believing that its products were obtained according to environmentally and socially responsible standards. Her complaint asserted claims under the California Consumers Legal Remedies Act, California’s Unfair Competition Law, and for unjust enrichment. She sought to represent a nationwide class of people who bought Mondelez products carrying specified sustainability-related claims.

Mondelez moved to dismiss the complaint and later moved to transfer the case to the Northern District of Illinois. Waggener van Meter moved to strike a filing by Mondelez. Mondelez sought transfer because a similar proposed class action, Gollogly v. Mondelez Int’l, Inc., No. 24-cv-7368 (N.D. Ill.), was pending in that district. The court described the two cases as arising from the same operative facts and noted that Waggener van Meter did not dispute that the Illinois case was duplicative.

Transfer Analysis

The court applied 28 U.S.C. § 1404(a), which allows a federal court to transfer a case when the alternative district is a proper venue and the convenience of the parties, witnesses, and the interests of justice favor transfer.

The court found that the case could have been filed in the Northern District of Illinois because Mondelez’s principal place of business is in Chicago. It gave Waggener van Meter’s choice of the Northern District of California less weight because the case was a proposed class action and the alleged mislabeling did not occur in that district. That factor weighed against transfer, but only minimally.

The convenience of the parties was neutral. Although Mondelez argued that Illinois was more convenient because its headquarters and both sides’ counsel were there, Mondelez agreed that Waggener van Meter’s deposition could occur remotely or in California. The convenience of the witnesses was also neutral because Mondelez did not identify the witnesses or explain the nature and importance of their testimony. The ease of accessing evidence slightly favored transfer because the relevant documents were in Illinois and the court viewed Illinois as the case’s “center of gravity.”

The court found the applicable-law factor neutral because federal courts can apply other states’ laws. It also found the local-interest factor neutral: California had an interest in protecting its residents, while Illinois had an interest in disputes involving companies headquartered there. The feasibility of coordinating or consolidating the two similar cases strongly favored transfer. The court concluded that handling the cases together in Illinois would prevent duplicative and unnecessary efforts. It did not analyze the relative congestion and trial-time factor because neither party addressed it and Mondelez had the burden of showing that transfer was warranted.

Ruling

Judge Celi Martinez-Olguin granted Mondelez’s motion to transfer the action to the Northern District of Illinois under Section 1404(a). The court denied Mondelez’s motion to dismiss and Waggener van Meter’s motion to strike as moot. The order addressed the proper forum and case-management considerations; it did not decide whether Mondelez violated California law, whether its labels were misleading, or whether the proposed class should be certified.