Rogers v. Target Corp.
- Louis Stanton
- 1:24-cv-07883
- U.S. District Court · Southern District of New York
- 4
In Rogers v. Target Corp., Judge Stanton dismissed the amended complaint because it did not clearly state a legally recognizable claim.
Joshua Rogers’s case against Target Corp. was dismissed. The court also warned Rogers that future frivolous or harassing filings could lead to restrictions on filing new cases without paying fees.
What happened
In Rogers v. Target Corp., Joshua Rogers sued Target Corp. and alleged that loss-prevention employees harassed him, spread defamatory statements, and failed to report events to police. He sought $75 million and several forms of unusual injunctive relief. Rogers represented himself and was allowed to proceed without paying filing fees.
The court had previously dismissed his original complaint because it did not clearly explain his claims or the reasons the court had authority to hear them, but allowed him to file an amended complaint. The court found that the amended complaint still did not give Target fair notice of the claims or the facts supporting them.
Judge Louis L. Stanton dismissed the amended complaint for failure to state a claim and declined to allow another amendment. The court directed the clerk to enter judgment and warned that further frivolous or harassing litigation could lead to a filing restriction requiring permission before Rogers could file new cases without paying fees.
The detailed version
- Rogers v. Target Corp. · No. 1:24-cv-07883
- Louis Stanton
- July 1, 2025
Background
Joshua Rogers, proceeding without a lawyer and without paying filing fees, sued Target Corp. His original complaint alleged that Target loss-prevention personnel allowed a rumor to affect their judgment. It also included allegations about medical issues, shoplifting in New York City, and being harmed by a hospital and others.
Chief Judge Swain previously dismissed the original complaint because it did not provide a short and plain statement that gave Target fair notice of the claims or their legal grounds. The order allowed Rogers to file an amended complaint.
The amended complaint alleged that Target loss-prevention officers failed him, that people identified as Target employees made defamatory statements, and that he was harassed when he entered the store. It also referred to alleged hate crimes, police reporting, COVID-19, and emotional harm. Rogers requested $75 million in damages and several forms of injunctive relief.
Court’s analysis
The court concluded that the amended complaint had the same basic defect as the original complaint. Its allegations did not provide a short and plain statement giving Target fair notice of the claims Rogers was asserting or the grounds for those claims. The court therefore dismissed the amended complaint for failure to state a claim on which relief may be granted. This is a pleading-based dismissal: the court ruled that the complaint was legally inadequate, rather than deciding whether the alleged events actually occurred.
The court explained that a person proceeding without a lawyer is generally given an opportunity to amend a defective complaint, but that another amendment may be denied when a previous amendment failed to cure the defects. The court determined that the defects could not be cured by another amendment and declined to give Rogers another opportunity to amend.
Disposition and warning
The court dismissed the action under the federal statute governing screening of complaints filed without payment of filing fees. It directed the clerk to enter judgment dismissing the case. Judge Louis L. Stanton also warned that further vexatious or frivolous litigation in the court could result in an order barring Rogers from filing new actions without paying fees unless he first received permission. The opinion states that Rogers had filed 20 cases without a lawyer in the district since 2024 and that the court had previously issued a similar warning.
Read the full 4-page opinion on CourtListener, the free public archive maintained by the Free Law Project.