Times v. Target Corporation
- Gabriel Gorenstein
- 1:18-cv-02993
- U.S. District Court · Southern District of New York
- 8
In Times v. Target Corporation, Judge Gorenstein denied Isaac Rodriguez’s three motions because claim preclusion barred his proposed claims.
Isaac Rodriguez’s efforts to pursue claims or obtain discovery in the Times v. Target Corporation class action were blocked by the court’s ruling; Target prevailed on its opposition to his three motions.
What happened
Times v. Target Corporation began as a class action alleging that Target’s criminal-background-check policy had a discriminatory effect on African American and Latino job applicants. The court approved a settlement in 2019, and Isaac Rodriguez was later included as a class member before asking to exclude himself.
Rodriguez later sued Target individually in Arizona, alleging race and national-origin discrimination under Title VII. The Arizona court granted Target summary judgment based on delay and Rodriguez’s failure to establish an initial discrimination case, and the Ninth Circuit affirmed. Rodriguez then filed three motions in this case seeking to enforce or undo the settlement and obtain discovery.
The court ruled that claim preclusion barred Rodriguez from pursuing these matters because his earlier case involved the same discrimination claim, was decided on the merits, and involved the same plaintiff and defendant. The court therefore denied all three motions and did not consider the underlying discrimination arguments. Judge Gabriel W. Gorenstein issued the order.
The detailed version
- Times v. Target Corporation · No. 1:18-cv-02993
- Gabriel Gorenstein
- Apr. 10, 2025
Background
The original plaintiffs filed this class action against Target on April 5, 2018. They alleged that Target’s use of criminal-background checks had a discriminatory effect based on race or national origin, in violation of Title VII of the Civil Rights Act of 1964. The complaint alleged that the policy harmed African American and Latino job applicants.
The court approved a settlement class on October 29, 2019, and finally approved the settlement on December 4, 2019. Isaac Rodriguez later moved to intervene as a class member. The parties agreed to include him as a class member, but Rodriguez received a settlement check and returned it because he wanted to exclude himself from the class. The court granted his request for exclusion on September 14, 2020.
On September 16, 2020, Rodriguez filed a separate case against Target in the United States District Court for the District of Arizona. He alleged that Target discriminated against him and denied or failed to consider him for employment because of his race and national origin through its criminal-background-check policy. The Arizona court granted Target summary judgment on August 31, 2022, finding that Target was entitled to judgment based on laches, meaning unreasonable delay, and that Rodriguez had not established an initial case of discrimination. The Ninth Circuit affirmed that ruling in 2024.
The Motions
In December 2024, Rodriguez filed three motions in this case. One sought to enforce the settlement and prevent Target from relying on statute-of-limitations and laches defenses. Another sought to vacate the settlement, revive his disparate-impact discrimination claim, and set the matter for trial based on alleged breach of contract and fraudulent inducement. The third sought discovery.
Target opposed all three motions, arguing that claim preclusion—also called res judicata—barred Rodriguez’s claims because of the prior Arizona case.
Court’s Analysis
The court explained that claim preclusion prevents a party from relitigating claims that were or could have been raised in an earlier case when three requirements are met: the earlier case ended in a decision on the merits, the later case involves the same parties or legally connected parties, and the later claims arise from the same underlying facts.
The court found all three requirements satisfied. First, the Arizona court’s summary-judgment ruling counted as a decision on the merits. Second, Rodriguez was the plaintiff in the Arizona case and was seeking to become a plaintiff in this case. Third, both cases concerned the same alleged employment discrimination arising from Target’s criminal-background-check policy.
The court rejected Rodriguez’s argument that his proposed settlement-enforcement, breach-of-contract, or fraudulent-inducement theories avoided claim preclusion. It stated that the relevant question was whether the two cases arose from the same underlying facts, not whether Rodriguez could have tried to enforce the settlement in Arizona. The settlement resolved the claims in this case and did not change the claim-preclusion analysis. The court also stated that claim preclusion applies even when particular arguments or issues were not addressed in the earlier litigation.
Disposition
The court held that Rodriguez’s proposed claims were barred by claim preclusion. It further held that he could not litigate claims in this case and was not entitled to discovery. The court denied Rodriguez’s motions at Docket Numbers 66, 68, and 70. Because the claims were precluded, the court did not address Rodriguez’s substantive arguments concerning the underlying employment-discrimination claim.
Read the full 8-page opinion on CourtListener, the free public archive maintained by the Free Law Project.