Navarro v. Target Corporation
- 0:25-cv-01243
- U.S. District Court · District of Minnesota
- 3
In Navarro v. Target Corporation, the court transferred the action to Minnesota and denied Target’s dismissal motion as moot.
Grace Navarro, the proposed class and the general public she seeks to represent, and Target Corporation. The case will proceed in the District of Minnesota, while Target’s motion to dismiss was denied as moot.
What happened
In Navarro v. Target Corporation, Target asked the Eastern District of California to dismiss the action for lack of standing and failure to state a claim. Target also asked to transfer the case to the District of Minnesota.
The court reviewed the magistrate judge’s recommendations and Plaintiff Grace Navarro’s objections. It agreed that transfer was appropriate because three substantially similar class actions against Target were already pending in Minnesota and had been assigned to the same judges.
The court granted Target’s motion to transfer venue, denied Target’s motion to dismiss as moot, and transferred the action to the District of Minnesota. The opinion is signed by the court because the judge’s name is not fully legible in the provided text.
The detailed version
- Navarro v. Target Corporation · No. 0:25-cv-01243
- Apr. 2, 2025
Background
Grace Navarro brought this putative class action on behalf of herself, others similarly situated, and the general public. Target Corporation moved to dismiss for lack of standing and failure to state a claim. Target separately moved under 28 U.S.C. § 1404(a) to transfer the case from the Eastern District of California to the District of Minnesota.
A magistrate judge recommended granting the transfer motion and denying the dismissal motion as moot. Navarro objected, and Target responded. The district court conducted a new review of the disputed recommendations as required by 28 U.S.C. § 636(b)(1)(C).
Analysis
The court agreed that transfer was appropriate but modified the magistrate judge’s reasoning in one respect. The magistrate judge had considered whether the first-to-file rule should apply. The court did not decide that issue, explaining that transfer was appropriate even if the rule applied.
The court gave substantial weight to three other similar class actions pending in the District of Minnesota. Those actions had been related and assigned to the same district and magistrate judges. The court found that the cited California case involving related litigation was different because the cases there differed in parties and posture. Here, the Minnesota cases were substantially similar to Navarro’s action, supporting transfer for convenience and sound judicial administration.
The court also rejected Navarro’s argument that the transfer analysis unfairly focused on Target’s expenses. It agreed that some convenience considerations affected both sides, but concluded that transfer would likely involve few non-party witnesses in California and would generally maximize convenience and minimize costs, particularly because of the three similar Minnesota cases.
Ruling
Judge information is not fully legible in the provided opinion text; the signature appears to begin with “Charis,” but the court’s full name cannot be stated reliably.
The court ordered:
- The magistrate judge’s findings and recommendations were adopted, based on the modified reasoning.
- Target’s motion to transfer venue was granted.
- Target’s motion to dismiss was denied as moot.
- The action was transferred to the United States District Court for the District of Minnesota.
The court therefore transferred the case without deciding Target’s dismissal arguments.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.